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License Agreement

This privacy policy of the LocalHub Social Network (hereinafter referred to as the Policy) is part of the User Agreement (https://local-hub.ru/user-agreement-rintech/).

Any use of the Social Network and/or Website means the User's unconditional acceptance of the Policy terms.

In case of disagreement with these conditions, the User must refrain from using the Social Network and/or Website in any form and under no circumstances provide the Administration with their personal data.

TERMS AND DEFINITIONS

Policy — this Policy regarding ensuring confidentiality and the procedure for processing personal data of Users of the Social Network. The current version of the Policy, which is a public document, is available to any Internet User when accessing the Social Network.

Personal Data or abbreviated as PD — any information relating to a directly or indirectly identified or identifiable natural person – the Personal Data Subject.

Personal Data Subject — a natural person to whom personal data relates.

Data Confidentiality — a mandatory requirement for the Administration or persons authorized by it who have received access to Personal Data, not to allow their dissemination without the consent of the Personal Data Subject or other legal basis.

Blocking of Personal Data — temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).

Information — messages or data regardless of the form of their presentation.

Administration Information System — a combination of personal data contained in the Administration's databases and information technologies and technical means ensuring their processing.

Processing of Personal Data — any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transmission (dissemination, provision, access), anonymization, blocking, deletion, destruction of personal data.

Administration – RINTECH Limited Liability Company (TIN 6950229495, OGRN 1196952007471), legal address: Russian Federation, 630005, Novosibirsk Oblast, Novosibirsk, Gogol Street, Building 44).

In the implementation of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data", the Administration acts as the Personal Data Processing Operator.

Personal Data Operator – a state body, municipal body, legal entity or natural person, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

Provision of Personal Data — actions aimed at disclosing personal data to a specific person or circle of persons.

Applicable Legislation — legislation of the Russian Federation.

Dissemination of Personal Data — actions aimed at disclosing personal data to an indefinite circle of persons.

Collection of Personal Data — targeted process of obtaining personal data by the Administration directly from Users.

Destruction of Personal Data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or as a result of which material carriers of personal data are destroyed.

Storage of Personal Data — a process involving the presence of personal data in systematized form at the Administration's disposal.

Cross-border Transfer of Personal Data – transfer of personal data to the territory of a foreign state to a foreign state authority, foreign natural person or foreign legal person.

Cookie Files (Cookies) — a small fragment of data sent by a web server and stored on the user's digital device – computer, laptop, tablet, smartphone, etc. The web client (usually a web browser) each time when attempting to open a page of the corresponding website resends this data fragment to the web server as part of an HTTP request. Cookie files do not allow identifying the identity.

Anonymization of PD – results of the Administration's actions to prevent the technical possibility of establishing the affiliation of PD of a specific User.

For the purposes of application and interpretation of the Policy, the main terms defined below are used (unless the Policy explicitly states otherwise). Other terms used in the Policy not specified above have meaning and are interpreted in accordance with their meaning specified in the User Agreement.

1. GENERAL PROVISIONS

1.1. This Policy establishes the rules for ensuring confidentiality and the procedure for processing Personal Data (PD) of Users as PD Subjects by the Administration, when Users visit and use the Social Network, use the Social Network functionality in accordance with the terms of the User Agreement. PD processing is carried out in the form of collection, storage, clarification and destruction of PD in the Administration's Information Systems.

1.2. The Policy is developed to ensure the protection of rights and freedoms of citizens when processing their PD by the Administration, as well as to establish responsibility of Administration employees who have access to personal data for non-compliance with requirements for processing and protecting PD.

1.3. This Policy contains information on the basic principles, purposes, procedure and conditions for processing PD, as well as information on the requirements implemented by the Administration for protecting processed PD, and is intended to ensure the protection of rights and freedoms of PD subjects when processing their PD by the Administration.

1.4. The current version of this Policy is constantly published (placed) on the Social Network page on the Internet at the network address / in order to ensure unlimited access to it.

1.5. This Policy is developed in accordance with the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data". PD processing is carried out on the territory of the Russian Federation, on the territories of foreign states that are parties to the Council of Europe Convention on the Protection of Individuals with regard to Automatic Processing of Personal Data, as well as other foreign states ensuring adequate protection of the rights of personal data subjects and in accordance with the legislation of the Russian Federation.

1.6. Using the Social Network means the User's unconditional acceptance of the Policy and the specified conditions for processing PD.

2. BASIC CONDITIONS FOR PD PROCESSING

2.1. The Administration's Policy regarding the processing of Users' PD in the Social Network consists in the fact that PD must be processed only in cases established by law, based on the main directions of the Administration's activity and taking into account the balance of interests of the Administration and PD subjects. PD processing by the Administration is carried out taking into account the need to ensure the protection of rights and freedoms of PD subjects, including the protection of the right to inviolability of private life, personal and family secrecy, based on the following principles:

2.2. The Administration has no right to receive and process PD of subjects containing information about racial, national belonging, political views, religious and philosophical beliefs, state of health, except with the written consent of the PD subject and except in cases when the above data is provided by the User to other Users, as well as in cases where processing of such PD is imposed on the Administration by the legislation of the Russian Federation.

2.3. Transfer (exchange, etc.) of PD is carried out on the basis of the PD subject's consent, including in the form of consent expressed through the social network functionality or in the form of a document signed by a simple electronic signature, as well as in other cases provided for by legislation.

2.4. Transfer of PD to state bodies is carried out in accordance with the requirements of current legislation and this Policy.

2.5. PD of the subject may be provided to other persons only with the written permission of the PD subject himself, except for cases of providing PD to Users by the PD subject using the Social Network or when PD transfer without the consent of the subject is permitted by current legislation of the Russian Federation.

3. CATEGORIES OF PD AND PURPOSES OF THEIR PROCESSING

3.1. Users' PD may be processed through the Social Network for the following purposes:

The Administration does not verify the accuracy of information provided by the User, as well as the User's legal capacity, except in cases specified in the User Agreement or other documents regulating the Social Network operation.

3.2. Processing of special categories of PD, in particular concerning racial, national belonging, criminal record, political views, religious or philosophical beliefs, is not carried out by the Administration.

3.3. The Administration never collects PD secretly from Users. The Social Network Administration may use tools for tracking visit statistics, determining the level of user interest and other similar tools that collect and analyze only anonymized information (not PD).

3.4. The Social Network may automatically save cookie files (small technical text files) on Users' devices that do not contain PD and are not used to identify the User. If the User does not wish to save these files on their device, they can change their web browser settings at any time and delete already saved files using the standard browser functionality or the User's mobile device. Detailed information about the use of cookie files is given in Section 10 of this Policy.

3.5. Also, technical information means information that is automatically transmitted to the Administration during the use of the Social Network using software installed on the User's device, namely:

3.5.1. Data about the User's activity in the Social Network, in particular about visited pages, date and time of transitions;

3.5.2. Diagnostic and technical information including, among other things, unique identifiers of the system or hardware, computer and equipment information, system software and applications, additional devices, about the use of various modules and functional capabilities of the Social Network, problems in the work of the Social Network and/or providers, which is periodically collected in order to provide and improve the Social Network, facilitate delivery of Social Network updates, technical support of the Social Network;

3.5.3. Information and data about the speed and time of loading/generation/response of the Social Network;

3.5.4. Information about the device with which the User used the Social Network: IP address and device type, information about the operating system, as well as other information;

3.5.5. Data on interaction with advertising announcements of the Administration shown outside the Social Network, their quantity, frequency and depth of viewing.

3.6. The User may change the types, types or volumes of transmitted data by setting appropriate parameters in the web browser or mobile device settings, or refuse such transmission completely, agreeing at the same time that some individual functional capabilities of the Social Network may partially or completely change or stop functioning in the mode or volume provided in the documentation.

4. COMPOSITION AND LEGAL BASES FOR PD PROCESSING

4.1. Source of obtaining PD: PD subject.

4.2. Composition of processed PD:

4.3. The legal basis for PD processing by the Administration is a set of legal acts, in fulfillment of which and in accordance with which the Administration carries out PD processing and protection of PD subjects' rights.

4.4. The legal bases for PD processing using the Social Network include the following provisions of the legislation of the Russian Federation: Article 10 of the Federal Law of July 27, 2006 No. 149-FZ "On Information, Information Technologies and on Protection of Information", Article 18 of the Federal Law of March 13, 2006 No. 38-FZ "On Advertising", Items 1 and 5 of Part 1 of Article 6, Article 10, Article 11, Part 3 of Article 14 of the Federal Law of July 27, 2006 No. 152-FZ "On PD" and other provisions of normative legal acts depending on specific processing purposes.

4.5. The basis for PD processing when concluding a civil contract is Part 1, Item 5 of Article 6 of Federal Law No. 152-FZ "On PD" (PD processing is necessary for the performance of a contract to which the PD subject is a party, beneficiary or guarantor, as well as for concluding a contract at the initiative of the PD subject or a contract under which the PD subject will be a beneficiary or guarantor).

4.6. The basis for PD processing for maintaining correspondence (receiving and providing feedback on complaints, letters, wishes, requests) is Part 1, Item 5 of Article 6 of Federal Law No. 152-FZ "On PD" (PD processing is carried out with the consent of the PD subject expressed by checking the corresponding "checkbox" using the social network functionality).

5. PROCEDURE AND CONDITIONS FOR PD PROCESSING

5.1. PD processing in the Social Network is carried out using and without using automation tools for the periods necessary to achieve the processing purposes. The condition for termination of PD processing by the Administration may be the achievement of their processing purposes, withdrawal of the PD subject's consent to process their PD, termination of the Administration's activity, closure of the Social Network or change of its functionality.

5.2. Using the social network functionality, the Administration carries out collection, recording, retrieval and use of Users' PD. If necessary, the Administration may carry out cross-border PD transfer within the limits established by Applicable Legislation. The Administration checks whether the state to the territory of which PD is transferred ensures adequate protection of PD subjects' rights before the beginning of cross-border PD transfer.

5.3. Other operations with personal data, including storage, are carried out without using the Social Network and are regulated by the Administration's internal documents.

5.4. In order to carry out communications with Users, the Administration ensures the functioning of feedback forms and processing of incoming appeals through them. Appeals are not saved in the Social Network, but are received by the Administration's authorized employees for subsequent work. At the same time, the Administration processes only PD entered by Users in the relevant fields of feedback forms. For example, such data may be (depending on the specific feedback form): full name; contact details; data contained in the message and documents attached to it, and others. Response to User's appeals is carried out by Administration employees both using and without using the social network functionality.

5.5. The Social Network functionality supports mailings for Users. The subject matter of messages is determined by the User's own choice and may include advertising, manufacturer and service overviews, news, reference information and other materials. At the Administration's discretion, mailings may be carried out using Users' PD or without their use, namely:

5.5.1. by the Administration's decision and subject to Users' consent, PD (for example, full name, contact details, email address and others) may be collected through the relevant mailing web form and used for individualizing the mailing, sending targeted advertising and solving other similar tasks;

5.5.2. mailing without using PD is carried out only to email addresses or mobile phone numbers that the User specifies in the relevant web form. At the same time, no other information relating to a directly or indirectly identified or identifiable natural person is requested or collected.

5.6. In all cases, PD processing by the Administration is carried out with the User's consent, unless otherwise provided by the legislation of the Russian Federation.

5.7. To achieve the stated processing purposes, the Administration may communicate PD to third parties, including its affiliated companies, as well as entrust PD processing to other persons on the basis of an agreement containing confidentiality conditions and other mandatory provisions prescribed by Applicable Legislation.

5.8. When collecting PD, the Administration always proceeds from the following:

The Administration may contact the User and ask them to clarify PD before considering the User's message on the merits if there are doubts about the fulfillment of the above conditions.

5.9. When collecting PD, the Administration ensures recording, systematization, accumulation, storage, clarification (update, change), retrieval of PD of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

5.10. Users' PD are confidential information in accordance with Applicable Legislation. The Administration takes measures necessary and sufficient to ensure the fulfillment of obligations provided by the legislation of the Russian Federation in the field of PD. As necessary, the Administration performs the following measures aimed at protecting the rights of PD subjects:

5.11. PD security is achieved by excluding unauthorized, including accidental, access to personal data, the result of which may be destruction, change, blocking, copying, dissemination of PD, as well as other unauthorized actions. The Administration must ensure protection of PD from their unlawful use or loss.

5.12. Ensuring PD security is achieved by the Administration, in particular by:

5.13. Confidentiality measures during collection, processing and storage of PD apply to both paper and electronic (automated) information carriers. The Administration has the right to apply technical protection methods and other methods provided for PD protection that do not contradict the legislation of the Russian Federation.

5.14. Objects of protection are: documents containing PD; PD, as well as technical means (including computer equipment, machine media, means and systems of communication and data transmission, technical means of processing alphanumeric, graphic, video and speech information), system, applied, special software, information technologies, as well as information protection means as part of PD information systems in which PD processing is carried out.

5.15. The Administration hereby publishes information about the implemented requirements for PD protection. As necessary and taking into account threats actual for information systems ensuring the Social Network functioning, the Administration implements the following requirements (or ensures their implementation by organizations attracted under contract):

5.16. The Administration guarantees that the information provided by the User is not combined with statistical data, is not provided to third parties and is not disclosed, except as provided for in the Policy.

5.17. The Administration does not sell or transfer User information separately. Such information may only be transferred in case of partial or complete reorganization of the Administration.

5.18. The Administration takes technical and organizational measures to provide the User with the ability to access the information provided by them, edit such information, determine third-party access settings to such information.

6. PROCEDURE FOR RESPONDING TO PD SUBJECT REQUESTS

6.1 The Administration strives to ensure maximum transparency in PD processing and prompt response to requests and appeals received from Users, the Authorized body for protection of PD subjects' rights and other government bodies.

6.2. Requests, appeals and other messages regarding inaccuracy of PD, illegality of their processing, withdrawal of consent, PD subject's access to their data, as well as on any other issues related to PD processing and protection, should be sent to the Administration's email.

7. RIGHTS OF PD SUBJECTS AND ADMINISTRATION

7.1. User (PD Subject) has the right:

7.1.1. To receive information related to the processing of their PD, including access to their personal data and receiving a copy of any record containing their PD, except in cases provided for by the legislation of the Russian Federation.

7.1.2. To clarify their PD, carry out their blocking or destruction in cases established by law. The User may delete or change information provided by the User at any time by performing the necessary actions using the feedback form. At the same time, the User understands that the Administration may continue using such information in cases permitted by Russian legislation. Consent to receive information mailings and advertising materials may be withdrawn by the User at any time by sending the Administration a relevant notification in the same way.

7.1.3. To appeal actions (inaction) of the Administration in competent government bodies.

7.1.4. To protect rights and legitimate interests, including demanding compensation for damages and/or compensation for moral harm in a court or other procedure established by law.

7.1.5. To withdraw consent to PD processing.

7.1.6. To configure the desired level of confidentiality of their own PD when the relevant Social Network functionality is available.

7.1.7. To disclose their own PD to other Users and/or third parties at their own discretion by sending personal messages and by other means available in the Social Network.

7.1.8. Using the Social Network functionality, to establish confidentiality levels determined by the following categories:

a) information available to all Users of the Social Network;

b) information available to all Users of the Social Network, except for a certain category of Users;

c) information available to persons having the status of the User's friends, as well as persons having the status of their friends;

d) information available only to persons having only the status of the User's friends on the Website;

e) information available only to some persons having the status of the User's friends on the Website;

f) information available to some categories of Users (in case the User using the Social Network functionality configures the privacy of their own PD, including the visibility of the User's Personal Page);

g) information available only to the User.

Independent disclosure by the PD Subject of their own PD in case of causing any harm to the User by third parties releases the Administration from any responsibility for unlawful disclosure of PD.

The Administration has the right to change confidentiality levels. Users are informed about such changes by the methods specified in the User Agreement.

7.1.9. Independently, if there is technical possibility on the User's device or in software means on the User's device, to prohibit the device or software means from transmitting information through the Social Network necessary for implementing advertising targeting.

7.1.10. The User has the right using the Social Network functionality to receive information about when and from which devices authorization was made to their Personal Page.

7.1.11. To exercise other rights provided for by the legislation of the Russian Federation in the field of PD.

7.2. Administration has the right:

7.2.1. To carry out statistical and other research based on anonymized information provided by the Administration. The Administration has the right to provide access to such research to third parties for implementing advertising targeting. The User gives their consent to such research and to receiving targeted advertising by accepting the Policy. The User may refuse such consent at any time by contacting the Administration.

7.2.2. To provide information about the User to law enforcement agencies or other state bodies within the framework of a court process or within the framework of an investigation based on a court decision, forcibly executable request or in the manner of cooperation, as well as in other cases provided for by Russian legislation.

7.2.3. To provide information about the User based on motivated requests of third parties exclusively for cases of detecting and preventing fraudulent actions, for eliminating technical malfunctions or security problems.

7.2.4. In order to ensure more reliable protection of information about Users, the Administration has the right to use, including, linking the page to the User's mobile phone, as well as other means available in the Social Network at the relevant moment in time.

8. LIMITATION OF ADMINISTRATION LIABILITY

8.1. The Social Network is not a publicly available source of personal data. At the same time, in case of certain actions by the User, their personal data may become available to an indefinite circle of persons, which the User hereby gives their consent to.

8.2. The Website Administration recommends that Users responsibly approach the issue of the volume of information about themselves placed on the Website, as well as configuring the level of confidentiality.

8.3. The Administration informs Users of the Social Network that this Policy applies only to the Social Network. The Administration does not control and is not responsible for the use of third-party websites to which the User may, at their discretion and at their own risk, follow links placed through the Social Network by other Users of the Social Network.

8.4. The Administration is not responsible for actions of third parties who, as a result of using the Internet or Social Network services, received access to information about the User in accordance with the level of confidentiality selected by the User, for the consequences of using information that, by the nature of the Social Network, is available to any Internet user.

9. UPDATING, CORRECTION, DELETION AND DESTRUCTION OF PD

9.1. In case of confirmation of the fact of inaccuracy of PD or illegality of their processing, PD may be updated by the Administration, or their processing is terminated by the Administration.

9.2. Upon achieving the purposes of PD processing, as well as in case of withdrawal by the PD subject of their consent to process them, PD are subject to destruction, except in cases established by Applicable Legislation.

10. FINAL PROVISIONS

10.1. This Policy enters into force from the moment of approval, is put into effect by the Administration's order and действует бессрочно (until its cancellation or replacement by a new version of the Policy).

10.2. The requirements of this Policy apply to all Administration employees who have access to personal data, as well as to all Users of the Social Network.

10.3. The Administration has the right to unilaterally make changes and/or additions to this Policy. The new version of the Policy enters into force from the moment of its publication (placement) on the Social Network page at the network address /, unless otherwise provided by the new version of the Policy. In case of changes affecting Users' rights, the Administration has the right to send information about these changes to Users at their contact details or notify them of changes in another way.

10.4. In case of a dispute related to the application or compliance with this Policy, the Administration and the relevant PD subject will make every effort to resolve it through negotiations and/or mutual compromises. If the conflict is not resolved through negotiations and/or mutual compromises, the dispute shall be resolved in the manner established by the current legislation of the Russian Federation (Applicable Legislation).

11. ADMINISTRATION DETAILS

RINTECH Limited Liability Company

TIN 6950229495, OGRN 1196952007471

Legal address: Russian Federation, 630005, Novosibirsk Oblast, Novosibirsk, Gogol Street, Building 44.

11.1. Contact information:

E-mail: ceo.sap@rinteh.com.