Confidentiality policy

This confidentiality policy (hereinafter the “confidentiality policy”) explains how “SNEG” Ltd (State registration no. 1164101051003 Taxpayer ID no. 4101173984) processes personal data and sets forth a system of core principles for the processing of personal data in the company.

The confidentiality policy has been prepared in accordance with the Russian federal law on the processing of personal data no. 152-FZ of 27 July 2006 and applies to all information on this site. 


1.1 The confidentiality policy uses the following terms:

1.1.1. “Site administration” – employees authorised to manage the site, acting on its behalf, who organise and/or carry out the processing of personal data, and also determine the purposes of the processing, the personal data to be processed or actions (operations) to be performed on the personal data.

1.1.2. “Personal data” – any information directly or indirectly related to the identified or identifiable natural person (data subject).

1.1.3. “Processing of personal data” – any action (operation) or a set of actions (operations) performed, with or without the use of automation tools, on personal data, including collection, recording, systematisation, gathering, storage, clarification (updates, changes), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data.

1.1.4. “Confidentiality of personal data” – a mandatory requirement in place in order for the site administration to prevent intentional distribution of personal data without the consent of the data subject or on other legal grounds.

1.1.5. “Site user (hereinafter the “user”)” – a person who has access to the website via the internet and uses this site for his/her own purposes.

1.1.6. “Cookies” – small pieces of data sent by a web server and stored on the user’s computer, which the web client or web browser sends to the web server in an HTTP request each time it tries to open a page of the corresponding site.

1.1.7. “IP address” – a unique network address, built using Internet Protocol (IP), for identifying a device on a computer network.


2.1. By using the website, the user accepts this confidentiality policy and the terms and conditions for the processing of user’s personal data.

2.2. In case of disagreement with the terms and conditions of the confidentiality policy, the user must stop using the site.

2.3. This confidentiality policy applies solely to this site. The site administration does not control and is not responsible for third-party sites, which the user may and can access via the links available on this site. The confidentiality policy applies to all operations performed by “SNEG” Ltd. on personal data with or without the use of automation tools.

2.4. The site administration does not verify the accuracy of personal data provided by the user.

2.5. All persons admitted to the processing of personal data and involved in the organisation of the processing, safety and security of personal data must familiarise themselves and comply with the confidentiality policy.


3.1. The confidentiality policy establishes the responsibilities of the site administration with regards to the intentional disclosure of personal data, which the user provides on request by the site administration (for example, when registering on the site, making an order, signing up for notifications, etc.).

3.2. Personal data processed within the framework of this confidentiality policy are provided by the user by way of completing specific forms on the site, and which include as a rule the following information:

3.2.1. User’s surname, first name;

3.2.2. User’s contact telephone number;

3.2.3. User’s e-mail address;

3.2.4. User’s address and other details.

3.3. The site administration also makes every effort to protect personal data that are automatically transferred when visiting the site:  

IP address;

cookies information;

browser information (or another programme that enables access to the site);

time of access;

URLs of accessed pages;

referrer (address of a previously accessed page), etc.

3.3.1. Disabling the cookies may result in the impossibility to open the site. 

3.3.2. The site collects statistics about IP-addresses of the persons accessing it. This information is used for the purposes of detecting and solving any technical issues that may arise and controlling the correctness of the operations performed.  

3.4. Any personal data specifically referred to above (purchase history, browsers used, operational systems, etc.) may not be intentionally disclosed, unless provided for in 5.2. and 5.3. of this confidentiality policy.


4.1. User’s personal data may be used by the site administration for the following purposes:

4.1.1. Identification of the user registered on the site to place an order and (or) sign an agreement.

4.1.2. Establishing contact with the user, including sending notifications, requests concerning the use of the site, provision of services, processing user’s requests and applications.

4.1.3. Providing the user, with the latter’s consent, information about product updates, special offers, prices, newsletters and other information on behalf of the site or on behalf of the site’s partners.

4.1.4. Engaging in advertising activities with the user’s consent.


5.1. The processing of the user’s personal data is carried out without any time limit, in any legal way, including in personal data information systems with or without the use of automation tools.

5.2. The user agrees that the site administration is entitled to transfer personal data to third parties, in particular, courier services, postal service providers, telecommunications operators, solely for the purpose of fulfilling user’s requests made on the site subject to the offer agreement.

5.3. User’s personal data may be transferred to competent state authorities only on the grounds and in the manner provided for by applicable legislation.


6.1. The user undertakes:

6.1.1. to provide true and correct personal data required to use the site.

6.1.2. to update or supplement the personal data provided in case of any changes thereto.

6.1.3. to take any steps necessary to protect access to one’s own personal data stored on the site.

6.2. The site administration undertakes:

6.2.1. to use the data received solely for the purposes specified in clause 4 of this confidentiality policy.

6.2.2. not to disclose the user’s personal data, unless required otherwise in accordance with clauses 5.2. and 5.3. of this confidentiality policy.

6.2.3. to block for a period of verification any personal data of the user concerned as soon as he/she, a legal representative thereof or a competent personal data protection body has made a request to that effect, should any inaccuracies or illegal actions have been identified.


7.1. The site administration is responsible for the deliberate disclosure of the user’s personal data in accordance with the applicable law, with the exception of the cases provided for in clauses 5.2., 5.3. and 7.2. of this confidentiality policy.

7.2. In case of loss or disclosure of personal data, the site administration cannot be held responsible if this confidential information:

7.2.1. Became public before its loss or disclosure.

7.2.2. Was received from a third party prior to having been received by the site administration.

7.2.3. Was obtained by third parties through unauthorised access to the site’s files.

7.2.4. Was disclosed with the user’s consent.

7.3. The user is responsible for the legitimacy, correctness and truthfulness of the provided personal data in accordance with applicable legislation.


8.1. A voluntary settlement proposal must be submitted before making a court claim concerning a dispute arising from the relationship between the user and the site administration.

8.2. The recipient of the settlement proposal shall within 30 calendar days from the date of the receipt thereof, notify the claimant in writing of the proposal’s outcome.

8.3. In the event of failure to reach a settlement, the dispute will be referred to the judicial authority in accordance with the legislation in force.

8.4. This confidentiality policy and the relationship between the user and the site administration are subject to the legislation in force.


9.1. The site administration has the right to make changes to this confidentiality policy without the user’s consent.

9.2. The new confidentiality policy comes into effect from the moment it is has been posted on the site, unless envisaged otherwise by the new version of the confidentiality policy.

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