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LIMITED LIABILITY COMPANY “BALTZER” (LLC BALTZER)

OGRN 1147746126505 INN/KPP 7704856721/770401001

Personal data processing consent Personal data processing and security policy
The version is approved by
Director General of
LLC Baltzer
Order No 5 dated 15.10.2018

Personal data processing and security policy
  1. General provisions
    1. Personal data processing and security policy (hereinafter referred to as the “Policy”) was drafted in compliance with the Federal law “On personal data” No 152-ФЗ dated 27.07.2006 to protect human civil and political rights and freedoms in terms of personal data processing, including protection of privacy right, personal and family secrets.
    2. This Policy stipulates personal data processing order of personal data subjects - visitors (hereinafter referred to as the “Users”) of the Website baltzer.com and its subdomains (hereinafter referred to as the “Website”) and measures aimed at personal data security at Limited Liability Company “Baltzer”, viewed as Personal Data Controller (hereinafter referred to as “BALTZER”).
    3. This Policy stipulates and covers a system of basic principles and conditions, applied in terms of personal data processing, the scope of personal data to be processed, processing objectives, acquisition, transfer, storage and protection of information related to Users. This Policy is applied to all information, which can be obtained by BALTZER as to Website Users.
    4. All persons, engaged in personal data processing at BALTZER, should familiarize with and follow the Policy.
    5. This Policy is published by BALTZER in pursuance of p. 2 art. 18.1. of the Federal law “Оn personal data” No 152-ФЗ dated 27.07.2006 in the corresponding information and telecommunication network with free access available.
  2. Key terms
    1. Website is a collection of graphical and information materials, including computer software programs and databases, ensuring their availability in Internet at the address baltzer.com and its subdomain;
    2. Data Controller (or BALTZER) — Limited Liability Company “Baltzer” (location: RF, 119019, Moscow, 9 Arbat str., b. 2, OGRN 1147746126505 dated 14.02.2014, INN 7704856721, KPP 770401001, tel.: +7 (499) 579 9177, fax: +7 (495) 697 4016, e-mail: info@baltzer.com), which owns the Website and which independently or jointly with other persons organizes and/or processes personal data, determines personal data processing objectives, the scope of personal data, subject to processing and actions (operations) with personal data.
    3. User (or Customer) — a competent individual (who has attained the age of 18), who visited the Website and provided its personal data to Data Controller.
    4. Personal data — any information, directly or indirectly related to Website user.
    5. Personal data processing — any action (operation) or cumulative action (operation) with personal data, arranged with/without the use of computer, including collection, recording, systematization, acquisition, keeping, specification (renewal, change), retrieval, use, transfer (distribution, provision, access), including with transfer through BALTZER internal network, Internet, including cross-border transfer (including to countries without due rights protection of personal data subjects), reproduction, electronic copying, depersonalization, blocking, deletion and destruction.
    6. Automated personal data processing — personal data processing using hardware.
    7. Personal data distribution — actions aimed at disclosure of personal data to any number of unspecified persons (personal data transfer) or at familiarization of any number of unspecified persons with personal data, including personal data publication in mass media, distribution in information and telecommunication networks or other access granting to personal data.
    8. Personal data provision — actions aimed at disclosure of personal data to a certain person or group (personal data transfer) or at familiarization of a certain person or group or other access granting to personal data.
    9. Cross-border personal data transfer — personal data transfer to a foreign state agency, foreign individual or foreign legal entity.
    10. Personal data depersonalization — actions resulting in impossibility to determine the owner of personal data (User/another BALTZER Customer) without additional information.
    11. Personal data blocking — temporary suspension of personal data processing (unless processing is required for personal data specification).
    12. Personal data destruction — actions resulting in impossibility to recover personal data in personal data information system and/or resulting in destruction of personal data tangible media.
    13. Personal data information system — personal data aggregate of databases and information technologies/facilities ensuring its processing.
    14. Customer and User Relationship Management system - Customer Relationship Management (hereinafter referred to as — CRM) - software, used by BALTZER to automate strategies of interaction with Users and other Customers, particularly for up-selling purposes, marketing optimization and service enhancement for Users and other Customers by saving the corresponding information and interaction history, establishment and improvement of business processes and subsequent results analysis.
    15. Cookie file – is a small text file or data piece, downloaded/saved on PC or another User’s device (for instance, smartphone or tablet), used by the User to visit the Website. Cookie files usually comprise the source Website name, their lifespan (i.е. the period of their storage on device) and randomly generated unique number. BALTZER uses two types of cookie files on Website: session cookies and persistent cookies. Session cookies represent temporary files, stored on the User’s device while the User navigates the Website. Persistent cookies remain on device for a long period of time or until the User manually deletes them (cookie lifespan depends on a certain file and the User’s Browser settings). Other similar technologies - pixel tags and tracking bugs – represent electron images, called single-pixel (1×1) or empty GIF-images.
  3. Personal data processing principles and conditions
    1. BALTZER personal data processing is arranged based on the following principles:
      • legality and equitable basis;
      • personal data processing limitation: by reaching certain predetermined and legal objectives;
      • prevention of personal data processing, inconsistent with personal data acquisition objectives;
      • prevention of databases integration, comprising personal data processed for undue objectives;
      • processing of personal data, consistent with processing objectives;
      • correspondence of the scope of personal data processed to the stated processing objectives;
      • prevention of personal data processing beyond the scope of the stated processing objectives;
      • ensuring personal data accuracy, sufficiency and relevance with regard to personal data processing objectives;
      • personal data destruction or depersonalization after reaching data processing objectives or in case of no further need of reaching the stated objectives, if BALTZER is unable to cure the breach in terms of personal data protection, unless otherwise stipulated by the federal law.
    2. In terms of personal data processing their accuracy, sufficiency and, if required, relevance with regard to personal data processing objectives should be stipulated.
    3. BALTZER processes personal data upon availability of at least one of the below-mentioned conditions:
      • personal data is processes based on the User’s consent;
      • personal data processing is required for the purposes, stipulated by the international agreement of the Russian Federation or the law, in terms of functions, authorities and obligations imposed on BALTZER under the legislation of the Russian Federation;
      • personal data processing is required for delivery of justice, execution of court order, the order of other bodies or officials, subject to execution in compliance with the legislation of the Russian Federation on enforcement proceedings;
      • personal data processing is required to execute the contract, whereunder the User acts as the party, beneficiary or guarantor, and for the purposes of contract conclusion at the User’s initiative or contract conclusion, whereunder the User acts as the beneficiary or guarantor;
      • personal data processing is required for the purposes of rights and legal interests of BALTZER or third parties or to reach public goals without violation of the User’s rights and liberties;
      • processing of personal data, open to public by the User or at its request (hereinafter referred to as the “public personal data”);
      • personal data processing, subject to publication or obligatory disclosure in compliance with the federal law.
    4. Personal data confidentiality. BALTZER and other persons, having access to personal data, shall neither disclose nor distribute personal data without the User’s consent, unless otherwise stipulated by the federal law or this Policy.
    5. Publicly accessible sources of personal data. For dataware purposes BALTZER may create publicly accessible sources of personal data of BALTZER Users and other Customers, including pictures and videos of events organized by BALTZER and third parties (partners) put online. Publicly accessible sources of personal data (based on the written consent of BALTZER Users/other Customers) may include the name, surname, patronymic, position, place of employment, family status (spouse), children, relatives), other social data, area of interests and collection area, other personal data, reported by BALTZER Users/Customers.
      6. Information about BALTZER User/Customer should be at any time deleted from publicly accessible sources of personal data at its request, at the request of Authorized agency on protection of rights of personal data subjects or based on court resolution.
    6. Sensitive personal data. BALTZER can process sensitive personal data, related to race, nationality, political views, religious or philosophical views, state of health, intimate life if:
      • the User provided its written consent for its personal data processing;
      • personal data is made publicly available by the User;
      • personal data processing is arranged in compliance with the legislation on state social care, labor legislation, legislation of the Russian Federation on pensions and state pension provision, on labor pensions;
      • personal data processing is required to protect the User’s life, health or other vital interests or life, health or other vital interests of other persons, should it be reasonably impossible to obtain the User’s consent;
      • personal data processing is required to establish or exercise the User’s or third party rights, as well as in terms of delivery of justice;
      • personal data processing is arranged in compliance with the legislation on mandatory classes of insurance or insurance legislation.

      7. Sensitive personal data processing, arranged in cases stipulated by clause 4 article 10 of the Federal law No 152-ФЗ “On personal data” dated 27.07.2006, should be immediately ceased, if processing objectives are no longer relevant, unless otherwise stipulated by the federal law.

      Personal data processing on previous convictions can be arranged by BALTZER only in cases and in the order stipulated by the federal laws.

    7. Biometrics data. Biometrics data represent information on a person’s physiological and biological features, used to establish its identity, and can be processed by BALTZER only with the written consent of BALTZER User/Customer.
    8. Personal data processing assignment to another person. BALTZER shall be entitled to assign personal data protection to another person with the User’s consent, unless otherwise stipulated by the Federal law, based on the contract made with such a person. The person, arranging personal data processing by the order of BALTZER, should observe personal data processing principles and regulations, stipulated by the federal law No 152-ФЗ “On personal data” dated 27.07.2006 and this Policy.
    9. Processing of personal data of Russian citizens. In terms of personal data acquisition, including via Internet, BALTZER should ensure recording, systemization, accumulation, storage, specification (updating, change), retrieval of personal data of Russian citizens using databases in the territory of the Russian Federation, save for the following cases:
      • personal data processing is required to reach the objectives, stipulated by the international agreement of the Russian Federation or law to exercise BALTZER functions, authorities and obligations stipulated by the legislation of the Russian Federation;
      • personal data processing is required for delivery of justice, execution of court order, the order of another body or official, subject to execution in compliance with the legislation of the Russian Federation on enforcement proceedings (hereinafter referred to as “Execution of court order”);
      • personal data processing is required to exercise the powers of federal executive bodies, state non-budgetary funds bodies, executive authorities of the Russian Federation constituents, local government authorities and functions of organizations, participating in rendering state and municipal services, stipulated by the federal law “On arrangement of Provision of State and Municipal Services” No 210-ФЗ dated 27.07.2010, including personal data subject registration in unified portal for state and municipal services and (or) regional portals of state and municipal services;
      • personal data processing is required for professional activities of journalists and (or) lawful activities of mass media or scientific, literature or other creative activity without violation of the User’s rights and legal interests.
    10. Cross-border transfer of personal data. BALTZER should assure that the foreign state, acting as personal data recipient, ensures appropriate protection of rights of personal data subjects before any transfer is arranged. Cross-border transfer of personal data to foreign states, which don’t ensure appropriate protection of rights of personal data subjects, can be arranged in the following cases:
      • User’s written consent to cross-border transfer of its personal data;
      • Contract execution with the User acting as its party.
  4. Processed personal data of a User (including cookie files and similar technologies)
    1. The list of User’s personal data processed by BALTZER is stated in Consent to personal data processing (hereinafter referred to as the “Consent”), viewed as integral part of this Policy.
    2. Depersonalized data of visitors is also collected and processed on the website (including cookie files and other similar technologies: pixel tags, tracking bugs etc.), i.e. not related to personal identification of certain Users based on this information using Internet statistic services (Yandex Metrika, Google Analytics etc.).
      1. Information, collected by cookie files and other similar technologies, is of generalized nature. Its use contributes to knowing the User better and obtaining of information on its user experience (user data), including with a view of learning the way the User uses the Website, how it responds to email newsletters and other content, to remember its preferences and to adapt the Website content to the User’s preferences. This is required for convenience purposes and to simplify Website use, to speed-up future Website activities, for Website functioning purposes, retargeting, collection of statistical information for statistical studies /reviews with a view of analysis (assessment of efficiency) and improvement of BALTZER services and Website (its contents), to ensure safe and secure servicing in terms of online transactions and render services, meeting the User’s demands etc.
      2. BALTZER uses the following types of files:
        1. Mandatory cookie files – files, required for correct Website operation and enabling the User to navigate the Website and use its functions and features. Without mandatory cookie files BALTZER will not be able to provide certain services or functions, and the Website will not operate efficiently.
        2. Preference cookie files - files, collecting important information on the User’s preferences, helping to remember the User, language and other local settings, adapt the Website in terms of the stated information.
        3. Functional cookie files and analytical cookie files - files, related to performance, efficiency and analytics, helping BALTZER to understand the way Users interact with the Website, to reveal problems in its operation (for instance, error messages), to help to assess the efficiency of advertising campaigns and optimize them for Users.
        4. Advertising cookie files – files used to deliver targeted/context advertising, helping BALTZER to assess the efficiency of advertising campaigns. BALTZER can share these files at the corresponding advertising systems and spaces, where BALTZER’s ads are placed.
        5. Marketing cookie files - advertising cookie files, used for marketing purposes: market analysis, network fraud detection, including false clicks on ads by a person not interested in advertisement.
        6. Other similar technologies (pixel tags and tracking bugs) - files, used for promotion of BALTZER’s and/or third parties’ (partners’) services and events, for Website development.
        7. Third party cookie files - files, used for tracking Users, market analysis, offering and rendering third-party services to User. In this event third parties can trace information on User’s Internet activity, including the Website. BALTZER cannot prevent acquisition of information, related to the way the User uses Website content, by third parties, third-party websites or outer domains.
        8. Access buttons to social networks – references to websites of social networks, owned by third parties, used for the Users to share the link on Website page in social networks or to make electronic bookmarks.
        9. Third-party web services - web services, used to display certain elements (images, video, presentations etc.), for arrangement of enquiries, payment of objects and services via payment systems etc.
      3. If a User doesn’t accept the use of cookie files and other similar technologies, it should make the corresponding settings in its Browser and should not use the Website. The majority of Internet browsers are initially set for automatic acceptance of cookie files and other similar technologies. A User can change the settings of its Browser, to block and delete cookie files and other similar technologies or to notify the User on their sending to its device. For the purposes above a User should read the guidance to the corresponding Browser on its official website. If a User uses several devices and/or Browsers for Internet access, the corresponding settings should be changed on each of them.

        To change Browser settings and be instructed on cookie files and other similar technologies, a User can use the following links:

        If cookie files and other similar technologies are deactivated, not all Website functions will be available to the User, and the User will not be able to obtain customized information when vising the Website.

      4. In terms of rendering certain services to Users BALTZER can use personal data provided in terms of transaction together with the data collected using cookie files and other similar technologies.
    3. When a User visits the Website page BALTZER processes the data and can transfer it to third parties (partners). BALTZER cooperates with a certain number of third parties, whose cookie files can also be installed on the User’s computer, including on behalf of BALTZER, so that they could offer their services to the User. To get the detailed information on third party cookie files (on the use of User’s data by third parties), as well as information on refusal to receive (use User’s data by third parties) them or their deletion, the User should familiarize with the corresponding terms of data use by third parties and their confidentiality policy (policy related to processing and security of personal data).

      If a User agrees with personal data processing by BALTZER, it can continue using the Website.

      If a User doesn’t want its data to be processed by BALTZER, the User should contact BALTZER technical support by e-mail admin@baltzer.com and leave the Website.

  5. User’s rights
    1. A User shall be entitled to obtain information from BALTZER, related to its personal data processing, unless such right is limited in compliance with the federal laws. A User shall be entitled to request from BALTZER correction of its personal data, their blocking or destruction if its personal data is not full, is outdated, inaccurate, illegally obtained or is not required for the stated processing purpose, and take the measures aimed at its rights protection stipulated by the legislation.
    2. Should any inaccuracy of personal data be revealed, a User may update them by sending the corresponding request to BALTZER with reference to “Personal data updating” to the e-mail: admin@baltzer.com or the corresponding written notification to BALTZER Director General at the address: RF, 119019, Moscow, 9 Arbat str, b. 2, to be sent by registered mail, return receipt requested, or delivered by hand against acknowledgement.
    3. If a User considers that BALTZER processes its personal data with violation of the requirements of the Federal law “On personal data” No 152-ФЗ dated 27.07.2006 or otherwise violates its rights and liberties, the User is entitled to appeal against BALTZER’s actions or failure to act in the Authorized agency on protection of rights of personal data subjects or in a judicial proceeding.
    4. A User shall be entitled to protect its rights and legal interests, including losses recovery and (or) emotional distress damages.
  6. Objectives of personal data processing
    1. In the table below the objectives of personal data processing (use purposes on Website) with specification of the corresponding personal data types, including cookie files, are summarized:
      Type of personal data, including cookie files
      (clause of the Consent)       		Personal data processing objective (use purposes on Website)
      (clause of the Consent)
      surname, name, patronymic (cl. 5.1.1.); e-mail (cl. 5.1.2.); telephone number (cl. 5.1.3.) User registration on Website (6.1.1.); identification of User, registered on Website (6.1.2.); access granting to Website services (6.1.3.); User’s access to personalized Website resources, user account (6.1.4.); rendering customer and technical support services to User in case of any problems related to Website use (6.1.6.); communication with User to establish and maintain business relations (6.1.7.); sending notifications, requests, advertising, service messages, newsletters and marketing information to User, including information related to BALTZER activities, services rendered by BALTZER or third parties (partners); on events held by BALTZER and third parties (partners), on drafted BALTZER’s related guidelines, offers, research and publications by e-mail or telephone (6.1.10.); managing User’s participation in events of BALTZER and third parties (partners) (6.1.11.); confirmation of authenticity and integrity of personal data, provided by User (6.1.16.)
      information on Browser used (cl. 5.1.4.); information on device and its screen resolution, connection and configuration, information on operating system. Device ID (for instance IMEI code for telephones), regional and language parameters (cl. 5.1.5.) Website operation and improvement (6.1.5.); rendering customer and technical support services to User in case of any problems related to Website use (6.1.6.)
      information on Website activity, related to profile, information of Website account profile (cl. 5.1.6.) rendering customer and technical support services to User in case of any problems related to Website use (6.1.6.); fulfilment of obligations, including with a view of BALTZER’s rendering information (consulting) services to the User (6.1.8.)
      information on clickthrough on Website sourced from e-mails (cl. 5.1.7.); information on the source of User’s arrival to Website (from which website/ad); information on webpages opened and buttons clicked by User (cl. 5.1.8.); information on IP-addresses of devices used by the User to open the e-mail (cl. 5.1.9.) retargeting and acquisition of statistical information, its assessment and analysis (6.1.12.)
      information, provided by a User in terms of support request from BALTZER - information, which helps BALTZER to provide support (for instance authentication data, contents of chats and other communication with BALTZER). When contacting BALTZER telephone conversations can be traced and recorded, video monitoring and recording can be arranged in terms of personal contact (cl. 5.1.10.) rendering customer and technical support services to User in case of any problems related to Website use (6.1.6.); communication with User to establish and maintain business relations (6.1.7.)
      passport information or information of any other identity document, residence/registration address with ZIP code (cl. 5.4.1.) fulfilment of obligations, including with a view of BALTZER’s rendering information (consulting) services to the User (6.1.8.); managing User’s participation in events of BALTZER and third parties (partners) (6.1.11.); accounting records maintenance, recording and keeping of contracts (6.1.14.); tracking User’s location and observance of BALTZER access control: for user identification during passage to BALTZER’s territory, buildings, premises and/or offices, to ensure personal security of BALTZER employees, Customers, to preserve material and other values, managed by BALTZER, to prevent fraud, to reveal and investigate incidents in BALTZER’s territory, buildings, premises and/or offices (6.1.15.); confirmation of authenticity and integrity of personal data, provided by User (6.1.16.)
      contact information, postal address, address for delivery (pick-up) of objects and other similar contact information (cl. 5.4.2.) communication with User to establish and maintain business relations (6.1.7.); fulfilment of obligations, including with a view of BALTZER’s rendering information (consulting) services to the User (6.1.8.); processing of User’s requests and applications and sending information to User on its requests and applications as well as their execution status (6.1.9.); sending notifications, requests, advertising, service messages, newsletters and marketing information to User, including information related to BALTZER activities, services rendered by BALTZER or third parties (partners); on events held by BALTZER and third parties (partners), on drafted BALTZER’s related guidelines, offers, research and publications by e-mail or telephone (6.1.10.); confirmation of authenticity and integrity of personal data, provided by User (6.1.16.)
      login credentials, passwords, password hints and other information, related to security and used to check authenticity and access to profiles (cl. 5.4.3.) access granting to Website services (6.1.3.); User’s access to personalized Website resources, user account (6.1.4.)
      demographic data, information on age, year, month, date of birth, place of birth, sex, citizenship, country and preferred language (cl. 5.4.4.) retargeting and acquisition of statistical information, its assessment and analysis (6.1.12.); creation of personal data information systems, CRM maintenance, creation of Website user database (6.1.13.)
      payment information, data, required for payment, banking details, information on financial transactions (cl. 5.4.5.) fulfilment of obligations, including with a view of BALTZER’s rendering information (consulting) services to the User (6.1.8.); managing User’s participation in events of BALTZER and third parties (partners) (6.1.11.); recording and keeping of contracts. (6.1.14.)
      interactions, information on BALTZER’s services rendered/being rendered. Information on purpose, date and time of access to BALTZER’s territory, building, premises and/or offices. In certain cases information, provided by User to use services, for instance, search queries. In other cases the information created by BALTZER, for instance notifications (cl. 5.4.6.) processing of User’s requests and applications and sending information to User on its requests and applications as well as their execution status (6.1.9.); creation of personal data information systems, CRM maintenance, creation of Website user database (6.1.13.); tracking User’s location and observance of BALTZER access control: for user identification during passage to BALTZER’s territory, buildings, premises and/or offices, to ensure personal security of BALTZER employees, Customers, to preserve material and other values, managed by BALTZER, to prevent fraud, to reveal and investigate incidents in BALTZER’s territory, buildings, premises and/or offices (6.1.15.)
      area of interests and data acquisition trends, information on User’s interests and favorites, for instance, on acquisition of items, subjects followed by User, news, favorite exhibitions, galleries, auctions. Apart from data directly provided by User, information on the User’s interests and acquisition trends can also be obtained or derived from other data acquired (cl. 5.4.7.) processing of User’s requests and applications and sending information to User on its requests and applications as well as their execution status (6.1.9.); sending notifications, requests, advertising, service messages, newsletters and marketing information to User, including information related to BALTZER activities, services rendered by BALTZER or third parties (partners); on events held by BALTZER and third parties (partners), on drafted BALTZER’s related guidelines, offers, research and publications by e-mail or telephone (6.1.10.); creation of personal data information systems, CRM maintenance, creation of Website user database (6.1.13.)
      search queries and commands run in terms of Website use with search capability or similar functions (cl. 5.4.8.) Website operation and improvement (6.1.5.); rendering customer and technical support services to User in case of any problems related to Website use (6.1.6.)
      voice data in case of BALTZER contacting by telephone, voice data, such as search queries and voice commands, which may have background sounds (cl. 5.4.9.); text, handwriting and key board input data and related information. For instance in terms of handwriting input data acquisition the information on location of handwriting input facility at device is acquired (cl. 5.4.10.) communication with User to establish and maintain business relations (6.1.7.); fulfilment of obligations, including with a view of BALTZER’s rendering information (consulting) services to the User (6.1.8.); managing User’s participation in events of BALTZER and third parties (partners) (6.1.11.)
      pictures of User, images and the related information, such as image meta data (cl. 5.4.11.) identification of User, registered on Website (6.1.2.); managing User’s participation in events of BALTZER and third parties (partners) (6.1.11.); creation of personal data information systems, CRM maintenance, creation of Website user database (6.1.13.)
      contacts and relations, information on persons, with whom the User communicates, maintains relations, exchanges data, friends, family status, spouse, children, relatives (cl. 5.4.12.); social data, information on User’s connections and interactions with other users and organizations (social position), for instance, information on education, profession, qualification, employment and position, place of employment, whose interests it represents, experience, information on tax registration, individual insurance account number, background and preceding employment, previous convictions, military service, elective posts, state service, membership in various associations, including professional etc. (cl. 5.4.13.); property status, due diligence (income, credits, debts, immovable property, deposits etc.), salary (cl. 5.4.14.); other Website input data, business and other ratable personal qualities, and any other identification information related to User (cl. 5.4.15.) creation of personal data information systems, CRM maintenance, creation of Website user database (6.1.13.); for execution of the active legislation of the Russian Federation (6.1.17.)
      contents of files and messages entered, sent, received, created and controlled by User. Contents collected by BALTZER:
      • correspondence, including audio, video, text (keyboard input, handwriting, dictation or otherwise), in messages, e-mails, telephone calls, invitations to events or chats;
      • pictures, images, songs and other multimedia files and documents;
      • reviews, polled data, assessments, feedback on BALTZER’s/third parties’-partners’ services and/or events (cl. 5.4.16.)
      		 communication with User to establish and maintain business relations (6.1.7.); fulfilment of obligations, including with a view of BALTZER’s rendering information (consulting) services to the User (6.1.8.); processing of User’s requests and applications and sending information to User on its requests and applications as well as their execution status (6.1.9.); sending notifications, requests, advertising, service messages, newsletters and marketing information to User, including information related to BALTZER activities, services rendered by BALTZER or third parties (partners); on events held by BALTZER and third parties (partners), on drafted BALTZER’s related guidelines, offers, research and publications by e-mail or telephone (6.1.10.); creation of personal data information systems, CRM maintenance, creation of Website user database (6.1.13.)
      video or records, records of events, undertakings and activities in BALTZER territory/building. While visiting BALTZER premises, office and other facilities/recorded events of BALTZER and third parties-partners, BALTZER can process User’s image and voice data (cl. 5.4.17.) managing User’s participation in events of BALTZER and third parties (partners) (6.1.11.); tracking User’s location and observance of BALTZER access control: for user identification during passage to BALTZER’s territory, buildings, premises and/or offices, to ensure personal security of BALTZER employees, Customers, to preserve material and other values, managed by BALTZER, to prevent fraud, to reveal and investigate incidents in BALTZER’s territory, buildings, premises and/or offices (6.1.15.)
      Mandatory cookie files (cl. 4.2.2.1.), Preference cookie files (cl. 4.2.2.2.), Functional and analytical cookie files (cl. 4.2.2.3.)

      User ID

      Security
      Language

      Location

      Device
      Referrer (website with Website link clicked by User) and recent visit and activity
      Clickstream       		for correct Website operation (efficient functioning); free User’s navigation on Website; for Website use convenience and simplicity, to speed-up future work on Website; for use of all Website functions and options; to provide all BALTZER services; to remember the User, its preferences, language and other local settings, for Website adaptation (Website content) based on information above; to understand the way the User interacts with the Website, email newsletters and other content; to reveal the challenges in Website operation (for instance, error reports), to assess advertising campaigns efficiency and their optimization for Users; for retargeting, acquisition of statistical information for statistical studies /reviews to analyze (assess the efficiency) and to improve BALTZER’s services and Website (contents); to provide secure and safe servicing in terms of online transactions etc., including without limitation:
      to recognize the User and obtain information on its user experience (user data); for the Users to see only their own information
      for control and security check at BALTZER
      to remember the language selected by User, and for due display of correct parameters
      provisional User’s address (city, region, country, ZIP code) based on its IP-address

      to determine the type of device and its display resolution
      for correct understanding of User’s preferences

      for understanding of pages visited by User. If during its visit the User gets error report, the corresponding information is saved in event log for reporting and resolution purposes
      advertising (cl. 4.2.2.4.) / marketing (cl. 4.2.2.5.) cookie files to deliver targeted/context advertising, helping BALTZER to assess the efficiency of advertising campaigns; for marketing purposes: market analysis, network fraud detection, including false clicks on ads by a person not interested in advertisement
      other similar technologies: pixel tags and tracking bugs (cl. 4.2.2.6.) for promotion of BALTZER’s and/or third parties’ (partners’) services and events, for Website development
      third party cookie files (cl. 4.2.2.7.), access buttons to social networks (cl. 4.2.2.8.), third-party web services (cl. 4.2.2.9.) for tracking Users; market analysis, offering and rendering third-party’s services to User; for the Users to share the link on Website page in social networks or to make electronic bookmarks; to display certain elements (images, video, presentations etc.), for arrangement of enquiries, payment of object and services via payment systems etc.
  7. The order of collection, transfer, storage and processing of other personal data types
    1. BALTZER shall ensure integrity of personal data and takes all reasonable personal data protection measures, preventing access of unauthorized persons to personal data.
    2. BALTZER shall not be liable for any security incident consequences, including data loss or corruption, resulting from authorized access of third parties to Website using the User’s login and password.
    3. BALTZER employees, responsible for violation of regulations governing personal data protection and processing, shall bear material, disciplinary, administrative, civil or criminal liability in the order, stipulated by the federal laws.
    4. Other BALTZER’s rights and obligations, related to personal data processing, shall be stipulated by the legislation of the Russian Federation in the area of personal data.
  8. Personal data processing terms
    1. The terms of personal data processing are determined with due consideration of:
      • stipulated personal data processing objectives;
      • validity terms of contracts with Users, other BALTZER's customers (their representatives), partners (their representatives) and their Consents for personal data processing;
      • terms, stipulated by the Order of RF Ministry of Culture No 558 “On approval of the List of standard administrative archive documents, drafted in the process of activities of state agencies, local government authorities and organizations with specification of their storage terms” dated 25 August 2010.
  9. Cease of personal data processing
    1. BALTZER shall cease personal data protection in the following cases:
      • conditions presupposing personal data processing cease or upon expiration of the corresponding terms;
      • reaching processing objectives or no further need to reach the stated objectives;
      • at Users’ request, should personal data, processed by BALTZER be incomplete, outdated, inaccurate, illegally obtained or be not required for the stated processing objective;
      • identification of any illegal personal data processing, should it be impossible to ensure personal data processing legitimacy;
      • withdraw of the User’s consent to personal data processing or expiration of consent validity term (if personal data is processed by BALTZER solely based on User’s Consent);
      • in case of discontinuation of BALTZER activities following liquidation or reorganization of BALTZER and/or liquidation of www.baltzer.com Website.
  10. Personal data security
    1. Security of personal data, processed by BALTZER, is ensured through legal, organizational and technical means, stipulated to fulfill the requirements of federal legislation in the area of personal data security.
    2. To prevent unauthorized (illegal) or accidental access to personal data (their destruction, change, blocking, copying, provision, distribution, as well as other misconduct as to personal data) BALTZER shall assume the following measures:
      • Local regulations related to personal data processing issues, including Regulations on personal data processing and security, this Policy.
      • Internal control of personal data processing compliance with the Federal law and the corresponding legal regulations, requirements related to personal data protection, local regulations requirements, this Policy.
      • Appointment of official, responsible for arrangement of personal data processing and security.
      • Limited number of persons, who have access to personal data processing; namely the Head of BALTZER has approved the document stipulating the list of persons, who must have access to personal data, processed in information system, in terms of their official duties.
      • Employees, directly engaged in personal data protection, are familiarized with the provisions of legislation of the Russian Federation on personal data, including requirements to personal data security, requirements stipulated by this Policy and other documents, determining BALTZER policy as to personal data processing, local regulations related to personal data processing.
      • Publication and placement of document, stipulating personal data processing and security policy, on BALTZER stand.
      • Regulations on access to personal data, processed in personal data information system, registration and recording of all activities with personal data in personal data system.
      • Recording, storage and handling of carriers with personal data information.
      • Hard copy data is stored in safes or lockable metal cases. Personal data storage locations are determined.
      • Personal data security hazards are determined during their processing, threat models are formed on their basis.
      • Personal data security systems developed based on threat models.
      • Control of information security facilities operability and efficiency.
      • Isolated access of users to information resources and information processing software hardware.
      • If required firewalling, intrusion detection, vulnerability analysis and data cryptographic protection facilities are used.
      • Pass control to BALTZER premises and offices.
      • Physical security of information systems (technical facilities and data carriers), stipulating third party access control to information system premises, due prevention of unauthorized entry to information system premises and data carriers storage location.
      • Security and fire alarm in the building.
      • Recovery of personal data, modified or destructed due to unauthorized access.
    3. BALTZER uses the following security facilities: security and fire alarm, security of BALTZER buildings, territory, premises and offices; electronic digital signature; antivirus tools for information security and personal data security system restore facilities; user identification and authentication at sign-in using relatively constant password of at least six alpha numeric characters; availability of personal data security system restore facilities.
    4. BALTZER assumes the following personal data security measures in compliance with the requirements of RF Government:
      • personal data storage locations (tangible media) determined.
      • determination of the list of persons, processing personal data and having access to it.
      • separate storage of personal data (tangible media), processed for various purposes.
      • recording of tangible media.
      • information security facilities, used to ensure personal data security in terms of processing in information systems, are registered in the corresponding documents.
      • no uncontrolled access or presence of unauthorized persons in the premises used for personal data processing.
      • integrity of personal data carriers and information security facilities.
  11. Feedback and final provisions
    1. A User can contact BALTZER to get answers to all the questions related to processing of its personal data, by sending the corresponding request to e-mail admin@baltzer.com or at the address: RF, 119019, Moscow, 9 Arbat street, b.2.
    2. BALTZER shall be entitled to enter changes and additions to this Policy at any time at its own discretion.
    3. The changes to this Policy shall enter into force as from publication of a new version on the Website. The use of the Website by User after entry of the corresponding changes represents its consent and approval of the new version of this Policy.
    4. The date of the latest available version should be stated at the beginning of this Policy.
    5. This Policy shall be subject to update in case of any change of RF legislation on personal data.
    6. BALTZER recommends to periodically reread this Policy to familiarize with its latest available version.
    7. Should any major changes be introduced in this Policy, the information can be sent to e-mail stated by User.
    8. Using the Website, ticking off the text box “I herewith give my written Consent to personal data processing and certify that I have familiarized with the Policy related to personal data processing and security and agree with its terms” and/or sending the drafted form for registration on Website, a User accepts all the terms of this Policy and Personal data processing consent (viewed as integral part of this Policy, Annex No 1), and should trace all potential changes.
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