Policy of Confidentiality

1. DEFINITION OF TERMS 

1.1. The current Personal Data Confidentiality Policy (hereinafter, Confidentiality Policy) uses the following terms: 

Internet Store Site Administration (hereinafter, Site Administration).  Experts representing the Company’s interests whose duties include site management i.e. organization and/or processing of incoming personal data. To perform their duties, they shall clearly understand purposes of data processing, what data shall be processed and what actions (operations) shall be performed with incoming information. 

Personal Data: information directly or indirectly pertaining to an individual identified or to be identified (also called personal data subject).

Personal Data Processing: any operation (action) or a number of operations the Administration performs with personal data.  They may be collected, recorded, systematized, accumulated, stored, amended (when required, updated or modified), extracted, used, transmitted (distributed, provided, made accessible), depersonalized, blocked, removed or even destroyed.  Such operations (actions) may be carried out either automatically or manually. 

Confidentiality of Personal Data: binding requirement applying to the Operator or other person handling the User’s data to keep the available information in secret and not divulge it to third parties unless the User providing the personal data grants his or her consent thereto or legal grounds for disclosure exist. 

Internet Store Site User (hereinafter, User): person visiting the Internet store site and using its programs and products. 

Cookies: short fragments of data transmitted by a web browser or a web client to a web server in a HTTP request every time the User wants to open the Internet store page.  Fragments are kept at the User’s computer. 

IP address: unique network address of a node in an TCP/IP-based computer network.

2. GENERAL

2.1. Visiting the Internet store site and using its programs and products imply automatic acceptance of its Confidentiality Policy including provision by the User of personal data for processing. 

2.2. If the User does not accept the applicable Confidentiality Policy, he or she shall leave the Internet Store. 

2.3. The applicable Confidentiality Policy shall apply only to the Internet Store Site.  If the User following links deployed in the website visits third parties’ resources, the Internet Store shall not be responsible for his or her acts. 

2.4. The Site Administration is not obliged to check correctness of personal data provided by the User who accepts the Confidentiality Policy. 

3. SUBJECT OF CONFIDENTIALITY POLICY

3.1. By virtue of the current Confidentiality Policy, the Internet Store Administration shall not disclose personal data communicated by Users who register at the site or make orders for purchase of goods and maintain full confidentiality of the data in question. 

3.2. To communicate personal data, the User shall fill in electronic forms available at the Internet Store Site.  User’s personal data subject to processing include:  

— last name, first name, patronymic; 

— contact telephone number; 

— e-mail address; 

— address where the goods he or she purchases shall be delivered; 

— User’s residence address. 

3.3. The Internet Store shall protect data automatically transmitted when viewing ad slots and visiting pages with statistic system scripts (pixels) installed.  The data include: 

— IP address; 

— cookies information; 

— information of browser (or other program via which ads are viewable); 

— site visit time; 

— address of the page where the ad slot is deployed; 

— referrer (address of the previous page). 

3.4. Blocking cookies may result in no access to sections of the Internet Store Site requiring authorization. 

3.5. The Internet Store collects statistics of all IP addresses of all visitors.  This information is required to identify and resolve technical problems and supervise the legality of financial payments. 

3.6. Any other personal details not referred to above (when and what purchases are made, what browser is used, what operation system is installed, etc.) shall be kept safely and shall not be divulged.  The current Confidentiality Policy provides for exceptions for the events described in par.  5.2 and 5.3.

4. OBJECTIVES OF COLLECTING USER’S PERSONAL INFORMATION 

4.1. The Internet Store Administration collects User’s personal data in order to:  

1. Identify the User who has completed the procedure of registration at the Internet Store Site to make an order and/or purchase goods of the store remotely. 

2. Grant the User access to personalized resources of the site in question.  

3. Establish feedback with the User which means in particular mailing of enquiries and notices on the use of the Internet Store Site, processing of user enquiries and orders and provision of other services.  

4. Identify the User’s location to make payments safe and prevent fraud.  

5. Make sure that the data provided by the User are full and correct.  

6. Make an account for purchases if the User wishes so.  

7. Advise the User of the status of his or her order in the Internet Store.  

8. Process and receive payments, confirm taxes or tax benefits, object to payments and decide whether it is expedient to extend to a specific User a credit facility.  

9. Resolve as quickly as possible the User’s problems in using the Internet Store due to efficient customer and technical support.  

10. Duly advise the User of updated products, introduce him or her to unique offers, new prices, news of the business of the Internet Store or its partners and other information if the User wishes so.  

11. Advertise goods of the Internet Store if the User wishes so.  

12. Grant the User access to sites and services of the Internet Store assisting him or her thereby in receiving products, updates and services. 

5. METHODS AND TERMS OF PERSONAL INFORMATION PROCESSING 

5.1. Term of processing the User’s personal data shall not be restricted.  Processing procedure may have any form permitted by applicable laws.  In particular, using information systems of personal data which may be maintained automatically or without automation means. 

5.2. The User’s personal data processed by the Site Administration may be transferred to third parties including courier services, mail officers and electrical communication operators.  This is done in order to fulfil the User’s order he or she makes at the Internet Store Site and deliver goods to the address.  The User’s consent to such transfer is provided for by the site policy. 

5.3. Personal data processed by the Site Administration may also be transferred to authorized governmental agencies of the Russian Federation subject to legal requirements and procedures stipulated by Russian laws. 

5.4. In case personal data are lost or disclosed, the Site Administration shall advise the User thereof. 

5.5. The Site Administration shall make every effort to prevent third parties’ access to the User’s personal data (except par.  5.2, 5.3). Such information shall not become accessible to third parties even by chance so that they could not destroy, modify, block, copy or distribute it or do any other illegal acts.  To protect users’ data, the Administration has a number of organizational and technical measures. 

5.6. If personal data are lost or disclosed, the Site Administration shall be ready jointly with the User to take any possible measures to prevent losses or other negative effects caused by such a situation. 

6. OBLIGATIONS OF THE PARTIES

6.1. The User shall:  

1. Provide information on him- or herself meeting the Internet Store’s requirements.  

2. Update and expand data he or she has provided if they change. 

6.2. The Site Administration shall:  

1. Apply the information received solely for the purposes specified in section 4 of the applicable Confidentiality Policy.  

2. Protect confidentiality of data received from the User.  Disclose them solely subject to the User’s written consent.  The Administration also may not sell, exchange, publish or otherwise disclose personal data provided by the User excluding par.  5.2 and 5.3 of the applicable Confidentiality Policy.  

3. Take preventive measures so that the User’s personal data remain strictly confidential in the same way as such information remains confidential in the current business practice.  

4. Block user personal data as soon as the User or his or her legal representative requests so.  Request of blocking may also be made by an agency authorized to protect rights of the User giving the Site Administration his or her data for the period of audit in case incorrectness of personal data provided or illegality of acts is identified. 

7. LIABILITY OF THE PARTIES

7.1. The Site Administration shall be liable for its failure to perform its duties and losses suffered by the User due to unauthorized use of the information he or she has provided.  I.a., Russian laws require so.  The current Confidentiality Policy provides for exceptions for the events described in par.  5.2, 5.3 and 7.2.

7.2. In a number of cases, the Site Administration shall not be liable if user data are lost or disclosed.  To wit, when they:  

1. Become generally available before they are lost or disclosed.  

2. Had been provided by third parties before the Site Administration received them.  

3. Have been disclosed by the User’s consent. 

8. SETTLEMENT OF DISPUTES

8.1. If the User objects to actions of the Internet Store Administration and intends to defend his or her rights in court, before making an action, he or she shall make a claim (propose an amicable resolution of the conflict in writing). 

8.2. After the Administration receives the claim, it shall within 30 calendar days give the User written notice of its review and measures taken. 

8.3. If the parties fail to agree, their dispute shall be referred to court where it is to be resolved in accordance with the applicable Russian laws. 

8.4. Relations between the User and the Site Administration are regulated in the Confidentiality Policy in accordance with the applicable Russian laws. 

9. ADDITIONAL TERMS

9.1. The Site Administration may modify the current Confidentiality Policy without requesting the User’s consent. 

9.2. New Confidentiality Policy shall come into effect as soon as information thereof is published in the Internet Store Site, unless the new Policy provides for a different method of publication. 

9.3. Please send any suggestions, recommendations, requests or questions on this Confidentiality Policy to info@zion-rus.com. 

9.4. The current Confidentiality Policy is available at https://zion-rus.com/politika-konfidentsialnosti/. 

Updated on 23 August, 2021