This Personal Data Policy (the “Policy”) sets forth the terms and conditions for processing personal data when using the websites operated by PJSC Cherkizovo Group (registered at: 5B Lesnaya St., Moscow 125047, Russia) (the “Company”).
The Policy has been drafted in line with Federal Law No. 152-FZ On Personal Data dated July 27, 2006.
It defines the general terms of collecting, processing, and storage by the Company of personal data of website visitors, existing and potential customers, consumers of products, as well as other personal data subjects, which may contact the Company by means of its websites. Personal Data means any information related directly or indirectly to a particular or identifiable individual (the “personal data subject”).
Agreement on the use of the websites (the “User Agreement”) is a notice of the beginning of personal data processing and request for consent to it from a personal data subject – a visitor to the Company's website.
The Company may process personal data solely provided that the purposes, scope and methods of its processing match those of its initial collection and of which the personal data subject has been informed in this Policy, the User Agreement or in any other way permitted by law.
In particular, the Company may process the following personal data in order to achieve the purposes listed below:
collecting, obtaining, recording, systematizing, accumulating, storing, correcting (updating, changing), using, transferring (providing or granting access), blocking, deleting, destroying.
The Company does not process biometric data, as well as data relating to race, ethnicity, political views, religious or philosophical beliefs, intimate life. The Company prohibits making decisions solely on the basis of automated personal data processing, where such decisions have legal consequences for the personal data subjects or otherwise affect their rights and legitimate interests. The Company does not distribute personal data or provide access to it via publicly available sources without a required consent of the personal data subject.
Web analytics tools are used to ensure the operation of the website and to conduct technical analysis of visitors’ behavior:
Cookies are small files that are created and stored by the browser when a person visits the Company’s website. Cookies are stored on a device for a maximum of 12 months, unless otherwise established by another document of the Company, and help track website quality and usage and conduct marketing activities on the Internet.
Visiting and using websites inherently involves the creation and storage of cookies. However, user can delete cookies from the device at any time in browser settings. User can also refuse to accept cookies, but in this case some functions of the websites may not work.
Tracking pixels are invisible links that help collect analytical information about the user’s surfing through website pages.
The following types of web analytics tools are used on the Company’s websites:
|Technical and functional cookies||These files generated by website engines are used to ensure that the websites run smoothly, as well as to store website settings selected by the user|
|Marketing and analytics cookies and pixels||Marketing cookies and pixels from Yandex.Metrica and Google Analytics web analytics services are used to collect and statistically analyze data related to the use of the websites|
The Company processes personal data for the above purposes in the following cases:
In order to achieve the stated purposes of personal data processing and provided there are legal grounds for that, personal data processing involves companies of Cherkizovo Group, contractors, providers of website hosting services and support of information systems in use. It may also involve other third parties.
Third parties are allowed to process the Company’s personal data solely based on an order to process personal data meeting the requirements of applicable Russian laws.
Also, personal data may be provided to state authorities pursuant to applicable federal laws.
The Company may process personal data on behalf of third parties.
Personal data collected by web analytics systems is also processed by third party organizers of such systems (in particular, Yandex LLC, Google, Facebook). In this case, personal data processing in web analytics systems is carried out in pursuance of the User Agreement.
The Company processes personal data based on the following principles:
The Company takes necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, deletion, modification, blocking, copying, disclosure, or distribution, as well as from any other wrongful acts as regards personal data, and complies with personal data processing principles and rules provided for in the Federal Law On Personal Data and other regulations, including:
The Company has appointed a person responsible for organizing personal data processing.
Internal documents binding on all employees of the Company, as well as relevant contracts with partners, counterparties, and other third parties, where these documents relate to them, set out the procedures for personal data processing and protection.
During personal data processing, subjects have the right to:
In addition to the above methods, subjects who have subscriptions for information and advertising communications may unsubscribe from such communications by activating the automatic “Unsubscribe” function by clicking the relevant link in the email containing the communication. In this case, communications will no longer be sent to the email address from which the function has been activated.
In case of any questions and requests concerning personal data processing, subjects may send a written request to the address: 5B Lesnaya St., Moscow, 125047.
The Policy is subject to revision in case of changes in the purposes, scope, methods, and terms of personal data processing on the Company’s websites. Any changes will be published and will become effective as soon as they are posted on the Company’s website.Confidentiality policy DOCX, 27 kb