Personal data processing policy

1. General provisions

1.1 this Policy concerning the processing of personal data (hereinafter – the "Policy") has been prepared in accordance with paragraph 2 h .1 article 18.1 of the Federal law of the Russian Federation "On personal data" №152-FZ dated 27 July 2006 (the "Act") and determines the position of the TH "RUSTA" (hereinafter "Marketplace") in the field of processing and protection of personal data (hereinafter personal data) in respect of rights and freedoms, describes the features of the collection, storage, use and transmission of personal data implemented the requirements for their protection, as well as information on the rights of persons to whom the relevant personal data.

1.2 personal data means any information relating directly or indirectly to a specific or identifiable natural person (citizen).

1.3 personal data processing is defined as any action( operation) or set of actions (operations)

with personal data performed using automation tools and/or without using such tools. Such actions (operations) include in particular: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.4 the security of personal data is understood as the protection of personal data from unlawful and / or unauthorized access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with respect to personal data.

1.5 the Policy applies to all actions related to the processing of personal data on the site https://abctica.com (hereinafter referred to as

the" Site") and the contact center, in the Marketplace information systems.

1.6 By placing an Order and registering on the Site, creating an Account, the User through the appropriate functionality of the Site provides consent to the processing of their personal data, in accordance with the procedure and conditions described in the Policy and provided for by applicable law. The use of the Site or contact center by the User also means their unconditional consent to the rules of the Privacy Policy and the conditions for processing personal data specified in it. If the User does not agree with the terms of this Policy, the User should refrain from using the Site and Contact center.

1.7 This Policy applies to personal data collected both before and after the implementation of this Policy.


2. Legal basis and purpose of Personal Data processing Marketplace

2.1 Marketplace processes and secures personal data for the exercise of its Marketplace by the legislation of Russia of the functions, powers and duties including, but not limited to, in accordance with the Constitution of the Russian Federation, Federal laws, in particular Federal law No. 152-FZ of 27 July 2006 "On personal data", regulations, and other defining cases and features of processing of personal data by the specified Federal laws of the Russian Federation, guidelines and methodical documents FSTEK Russia and FSB of Russia, and also the Civil code of the Russian Federation, Tax code of the Russian Federation, The law of the Russian Federation No. 2300-1 of 7 February 1992 "On protection of consumer rights", Federal law No. 402-FZ of 6 December 2011 "On accounting", as well as by the personal data operators, the Charter and local acts of Marketplace.

2.2 Marketplace is the operator of personal data in accordance with the Law.

2.3 personal data may be Processed by the Marketplace in the following cases and on the following legal grounds:

- personal data shall be processed only with the consent of the data subject, expressed in any form, allowing you to confirm the receipt of the consent, including the manner specified in clause 1.6. of this Policy;

- to achieve the objectives stipulated by international Treaty of the Russian Federation or by law, to implement and fulfill the legislation of the Russian Federation on personal data operator functions, powers and duties;

- for the execution of the contract of purchase and sale of the Goods or any other contract between the seller and the user of the Website who is a natural person, including acting on behalf of a legal entity with the necessary scope of legal capacity and who intends to register or placing an Order for Goods through the Site (the "Buyer") concluded with the use of the Site, side of which either the beneficiary or the guarantor which is the subject of personal data, including in the case of implementation by operator of its right to the assignment of rights (claims) under such contract and for the contract at the initiative of the personal data subject or of the contract under which the data subject will be the beneficiary or surety;

- for the purpose of execution of the Terms of use when using the Website;

- to implement the rights and lawful interests of the operator or third parties or to achieve important public purposes, provided that doing so does not violate the rights and freedoms of the data subject;

- for statistical or other marketing and research

purposes under the condition of compulsory depersonalization of the personal data, including in connection with the need to meet the stated Policy objectives nastoyashey.

2.4. Subjects of personal data processed through the Site and employees of the Contact center are, among others, users of the Site, buyers and recipients of Goods (if the buyer specified another person as the recipient of the Goods); any other natural persons applying to the Marketplace with applications /appeals.

2.5 Marketplace processes personal data, including that of the following persons:

i. Buyers (Users) in order to:

- the conclusion and execution of contracts, one party of which the User is, in accordance with the Terms of the order and delivery of the Site, including the contract of retail purchase and sale of Goods, including the prisoner remotely on the Website, the contract of compensated rendering of services;

- providing information on Products, promotions and special offers;

- informing about the Order status;

- assistance in settlement of claims between the Buyer and the Seller;

- the execution of the instructions of the Seller

regarding collection and transfer of funds in payment for the Goods;

- execution of orders of Buyers and Sellers in connection with the return of the Goods;

- placing the Users and Customers reviews about the Goods and (or) the Sellers;

- the analysis of the quality of Marketplace services and improve the quality of customer service the Marketplace;

- identification of Users and Buyers in the stock, the process of accrual accounting, the use of loyalty points of the loyalty programs Users and Buyers;

- the realization of the Marketplace of commitments to hold Shares; the performance of other Terms of use when using the Website;

in any other cases expressly stipulated by law.

ii. Recipients of Goods purchased by Customers for the purpose of delivering such Goods;

iii. other persons applying to the Marketplace with claims about alleged violations of their rights and the rights of third parties, in order to process incoming claims, transmit information about received claims to persons whose actions allegedly may have led to a violation of the relevant rights, assist in settling claims, and decide on applying the liability measures provided for In the terms of use of the site to Sellers or Buyers.

iv. all users of the Site in order to comply With the terms of use of the site when using the Site, analyze and improve the quality of service to Users, Buyers and Sellers.

v. Employees of the Marketplace for the purpose of implementing employment agreements in accordance with the Legislation of the Russian Federation.

Vi. Counteragents of the Marketplace, whose personal data is processed as part of the implementation of contractual relations between the parties.


3. Categories of personal data processed by Marketplace

3.1 the Marketplace handles the following categories of personal data recipients: the information obtained in the registration and order registration (surname, name, patronymic, telephone number, email address, a cookie), the information obtained in the interaction with the Customers (gender, age of Buyer, passport data, payment means data, city of residence and/or address) in connection with the placement or execution of customer Orders (data on method of delivery, method and condition of payment, and if the ultimate consignee of the Goods differs from the Buyer, also a surname, a name, a first name, delivery address and telephone number of the consignee), the claims of the Buyer (by the Buyer via the Website, contact centre or otherwise) posted by the Buyer reviews about the Goods and (or) Sellers, information about geolocation.

3.2 Marketplace processes the following categories of personal data of personal data subjects who file claims of alleged infringement of their rights with Marketplace: surname, first name, patronymic, passport data (data of another identity document), contact information (phone and / or Fax numbers, email address) of the rightholder or other person whose right was allegedly violated, and / or the applicant, if he / she acts as an authorized representative of the rightholder or other person whose right was allegedly violated, information about the applications received, the course and result of their consideration.

3.3 the Personal data specified in the paragraphs of this section above may be obtained by Marketplace in one of the following ways:

- provided by the subjects of personal data by filling out appropriate forms on the Site, by sending correspondence or e-mails to the e - mail addresses of the Marketplace;

- received from third parties in the cases provided for in this section. In particular, personal data of Buyers may be obtained by the Marketplace directly from Sellers or other counteragents of the Marketplace in connection with the execution of Seller's orders and / or other actions provided for by applicable law.


4. Principles and conditions of Personal Data processing

4.1 when processing personal data Marketplace adheres to the following principles:

- processing of personal data is carried out on the basis of law;

- personal data are not disclosed to third parties and are not distributed without the consent of the data subject, except those stipulated by Russian legislation of cases;

- definition of specific legitimate purpose prior to the processing (including collection) of personal data;

- integrating the databases, including databases containing personal data the processing of which is carried out for the purposes incompatible with each other, is not allowed;

- the processing of personal data is limited to the specified, explicit and legitimate purposes;

- processed personal data shall be destroyed or depersonalized when withdrawal of consent to the processing of personal data subject, the purposes of processing or in case of loss necessary to achieve these purposes, unless otherwise provided by Federal law;

- the content and scope of personal data processed correspond to the stated purposes of processing. Processed personal data are not excessive in relation to the declared purposes of processing;

- the processing of personal data ensures the accuracy of personal information and their sufficiency, in cases of necessity and urgency of personal data in relation to the declared purposes of their processing;

- personal data shall be stored in the form that allows to identify the data subject for no longer than required for the purpose of processing of personal data if the retention period of personal data not set by Federal law, the contract, which a party, beneficiary or guarantor which is the subject of personal data.

4.2 Marketplace does not process personal data related to race, ethnicity, political opinions, religious, philosophical or other beliefs, health status, personal life, membership in public associations, including trade unions, or biometric data. The marketplace does not perform voice input and verification of personal data using unsecured data transfer channels. The transfer of data by personal data subjects to employees of the contact center is voluntary and implies that the received data will be used in accordance with this Policy.

4.3 the Marketplace is entitled to entrust the processing of personal data to third parties with the consent of the personal data subject,

expressed by providing consent, on the basis of a contract concluded with such third parties, in the following cases:

- to handle complaints of Customers and (or) Users, third parties via voice and non-voice channels of communication, including electronic mail, online chat application for mobile devices and (or) social network;

- for the delivery of Goods to the Buyers and Recipients

- in order to raise funds to pay for the Goods on behalf of the Seller.

- to assess the quality of Marketplace services and improve the quality of customer service Marketplace (Users and Buyers);

- to prepare proposals and terms of service;

- to conduct statistical or other marketing research.

4.4 Persons who process personal data on the basis of a contract (operator's order) concluded with Marketplace, including Merchants and delivery services, must comply with the principles and rules for processing and protecting personal data provided for by applicable law. For each third party, the agreement defines a list of actions (operations) with personal data that will be performed by a third party processing personal data, the purpose of processing, establishes the obligation of such a person to maintain confidentiality and ensure the security of personal data during their processing, specifies the requirements for the protection of processed personal data in accordance with applicable law.

4.5 the Marketplace is entitled to transfer personal data to third parties with the consent of the personal data subject in the following cases:

4.5.1 Sellers and delivery services for the purpose of fulfilling the customer's Order, including, in the case of the demand of return of Goods purchased on the Website, in order to review the requirements and return and refund, in the cases provided for by the Rules of order and other sections of the Site, including, subject to obtaining the Marketplace statements about the infringement of intellectual property or other rights of third parties to resolve claims received, in case of receipt of other statements, opinions, claims, complaints, messages, or documents, addressed to the Seller, in other cases and purposes as described in the Rules of the order;

4.5.2 in order to protect the rights and legitimate interests of the Marketplace or third parties in cases where the personal data subject violates any of the terms of the Site's user documents and / or this Policy;

4.5.3 by a court decision that has entered into force or in cases established by applicable law;

4.6 in order to comply With the terms of use of the site when using the Site, analyze and improve the quality of service to Users and Buyers, for statistical or other marketing and research purposes, the Marketplace develops, improves, optimizes and implements new functionality of the Site. To ensure that the specified User or Buyer agrees and instructs the Marketplace be done in compliance with applicable law, the processing (including collection, recording, systematization, accumulation, storage, clarification (update, change), mapping, extraction, use, depersonalization, blocking, deletion and destruction) of the account and any other personal data of the User or Buyer, including available partner, acting on behalf of the Marketplace transfer available to the Marketplace account and any other personal data of the User's or Purchaser's partners pursuant to such order is submitted for processing, and receiving from partners on the results of processing of analytical information, including the results of automated processing such data, including in the form of integer and/or text values and identifiers.

4.7 the Marketplace has the right to transfer personal data to third parties with the consent of the personal data subject, as well as in cases where the possibility of transferring personal data to third parties is expressly provided for by Russian law does not require the consent of the personal data subject.

4.8 in order to comply with the requirements of the current legislation of Russia and its contractual obligations, Marketplace processes personal data both with and without the use of automation tools. The set of processing operations includes collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data.

4.9 the Marketplace does not make decisions that give rise to legal consequences for the subject of personal data or otherwise affect his rights and legitimate interests based solely on automated processing of personal data.

4.10 the Marketplace does not check and, as a rule, does not have the ability to check the relevance and reliability of the information provided by personal data subjects obtained through the Site. The marketplace assumes that personal data subjects, acting reasonably and in good faith, provide reliable and sufficient personal data and keep it up to date.


5. Rights of personal data subjects

5.1 a personal data Subject whose personal data is processed by the Marketplace has the right to:

i. change (update, Supplement) the personal data provided to them at any time by logging in to the Personal account in cases where this is allowed by the functionality of the Site;

ii. delete the personal data provided to them by sending a written notice to the Marketplace specifying the personal data to be deleted;

iii. to from the Marketplace:

- confirmation of the processing of personal data and data on existence of personal data related to the respective personal data subject;

- data on legal grounds and the purpose of processing personal data;

- information about the applied Marketplace, the ways of personal data processing;

- information on the name and location of the Marketplace;

- information on persons (except for workers Marketplace) that have access to personal data or which may be disclosed personal data on the basis of an agreement with the Marketplace or on the basis of the Federal law;

- the processed personal data relating to the data subject, and information about the source of their receipt, unless a different procedure for the granting of such personal data is not stipulated by law;

- information on the timing of the processing of personal data, including terms of their storage;

- information on the exercise of the personal data subject's rights stipulated by the legislation about personal data;

- name and address of the persons processing personal data on behalf of the Marketplace;

- other data envisaged by the Law;

iv. demand that the Marketplace clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;

v. revoke your consent to the processing of personal data at any time by sending an email with an electronic signature to the following email address: info@abctica.com, or by sending a written notification to the address of the Marketplace. Upon receipt of such notification, the processing of the personal data of the personal data subject will be terminated and his personal data will be deleted, except in cases where the processing can be continued in accordance with the legislation of the Russian Federation. In this case, the sending of such a notification about the withdrawal of consent by the User and/or the Buyer should also be considered a notification of unilateral refusal to execute the relevant Order and entails the impossibility of its execution;

vi. demand that the Marketplace correct any illegal actions in relation to their personal data;

vii. take measures provided for by law to protect their rights and legitimate interests, including compensation for damages and / or compensation for non-pecuniary damage in court.

5.2 the Rights provided for in the sub-clauses of this section above may be restricted in accordance with the requirements of Russian law and / or in cases where the Marketplace processes personal data on other legal grounds than the consent of the personal data subject.


6. Responsibilities Of The Marketplace

In accordance with the requirements of the Act, the Marketplace shall:

1) provide the data subject upon request information concerning the processing of personal data, either on legal grounds to grant the waiver within thirty days from the date of receipt of the request of personal data subject or his representative;

2) at the request of the data subject to clarify, blocking or deletion of processed personal data, if personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the declared processing purposes within a period not exceeding seven working days from the date of submission of the personal data subject or his representative data confirming these facts;

3) keep a register of complaints of personal data subjects, which should contain the requests of the data subject to receive personal data, as well as the facts you supply personal information on these requests;

4) notify the data subject about the processing of personal data if personal data were received not from data subject. With the exception of the following cases:

- the data subject informed of the implementation of the Marketplace processing of personal data;

- personal data received by the Marketplace in connection with the execution of the contract to which either the beneficiary or the guarantor which is the subject of personal data or on the basis of the requirements of current legislation;

- the personal data made publicly available personal data subject or obtained from a public source;

- Marketplace carries out the processing of anonymous personal data for statistical or other research purposes, if this does not violate the rights and legitimate interests of the data subject;

- the provision of personal data subject of the information contained in the notification of processing of personal data, violates the rights and legitimate interests of third parties;

5) in the case of achieving the purpose of processing personal data immediately cease the processing of personal data and to destroy the relevant personal data within a period not exceeding thirty days from the date of achievement of the purpose of personal data processing, unless otherwise provided by the contract, which a party, beneficiary or guarantor which is the subject of personal data, in other agreements between the Marketplace and the subject of personal data or if the Marketplace is not entitled to carry out personal data processing without consent of personal data subject on grounds provided by Law or other Federal laws;

6) if the personal data subject withdraws consent to the processing of their personal data, terminate the processing of personal data and destroy personal data within a period not exceeding thirty days from the date of receipt of the specified withdrawal, unless otherwise provided by an agreement between the Marketplace and the personal data subject. The destruction of personal data, the Marketplace must notify the subject of personal data;

7) in case of receipt of the request of personal data subject about the cessation of processing of personal data in the purpose of promotion of goods, works and services in the market, to immediately stop the processing of personal data;

8) when collecting personal data including via the Internet, the Marketplace provides a record, systematization, accumulation, storage, clarification (updating, changing), extraction of personal data of Russian citizens using databases located on the territory of the Russian Federation.


7. Protection of personal data

7.1 when processing personal data, the Marketplace takes the necessary legal, organizational and technical measures to protect personal data from unauthorized and / or unauthorized access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with respect to personal data.

7.2 such measures include, inter alia:

- appointment of a person responsible for organizing the processing of personal data and a person responsible for ensuring data security;

- development and approval of local acts on the processing and protection of personal data;

- application of legal, organizational and technical measures to ensure the security of personal data.

- monitoring of the measures taken to ensure personal data security and protection level of personal data information systems;

- assessment of the harm that may be caused to the data subject in case of violation of requirements of legislation on personal data, the ratio of said harm and take a Marketplace of measures aimed at ensuring the implementation of obligations envisaged by the legislation on personal data;

- the conditions to prevent unauthorized access to the material carriers of personal data and ensure the safety of the personal data;

- acquaintance of employees of the Marketplace, directly involved in the processing of personal data, the provisions of Russian legislation on personal data including requirements for the protection of personal data, local acts concerning the processing and protection of personal data.


8. Terms of processing (storage) of personal data

8.1 Terms of processing (storage) of personal data are determined based on the purposes of personal data processing, in accordance with the term of validity of contracts with personal data subjects, the requirements of current legislation:

- personal data of registered Users is stored for the entire duration of the User's account;

- personal data of an unregistered User and the recipient of the Product (if another person is specified as the recipient of the Product) are stored for three years from the moment of execution of the Order of such User;

- Personal data of other persons applying to the Marketplace with claims of alleged violation of their rights during the entire period of processing and consideration of the relevant claims and for three years from the date of completion of processing and (or) consideration of the claim, unless the law provides for a different Statute of limitations for the relevant disputes.

8.2 Personal data whose processing (storage) period has expired must be destroyed, unless otherwise provided for by the legislation of the Russian Federation. Storage of personal data after the termination of their processing is allowed only after their depersonalization.


9. Procedure for receiving clarifications on the processing of personal data

9.1 personal data Subjects whose personal data is processed by the Marketplace can obtain clarification on the processing of their personal data by contacting the Marketplace in person or by sending a corresponding written request to the address of The marketplace's location.


10. Automatically collected information

10.1 the Marketplace may collect and process the following information, including information that is not personal data:

- information about the interests of Users on the Site based on the search queries of users of the Website about ongoing and proposed sale of goods for the purpose of providing relevant information to Users when using the Website, as well as consolidation and analysis of information about which sections of the Website and the goods are in greatest demand among Users of the Website;

- information about the interests of Users of the contact center based on the received User requests to the contact center with the goal of providing relevant information to Users when using the contact centre as well as a synthesis and analysis of information about what the capabilities of the contact center are most in demand among Users of the contact centre;

- information, which forms a system Seller rating: User feedback about the Seller, information on the execution of Orders, and other information;

10.2 the Marketplace performs processing and storage of User's search query of the Website with the aim of collecting and creating client usage statistics sections of the Website.

10.3 the Marketplace automatically receives certain types of information obtained in the course of User interaction with the Site, e-mail correspondence, etc. this refers to technologies and services, such as web protocols, Cookies, Web tags, as well as third-party applications and tools. However, Web tags, Cookies and other monitoring technologies do not allow you to automatically receive personal data. If the Site User chooses to provide their personal data, for example, when filling out a feedback form or when sending an email, then only then will the processes of automatic collection of detailed information be started for the convenience of using the websites and / or for improving user interaction.

10.4 If the Marketplace can reasonably associate the information specified in this Section with a particular User's Account then such information may be processed jointly with the personal data and other personal information of such User.


11. Changes to the Policy; other provisions

11.1 the Marketplace may periodically make changes to this Policy, including to reflect changes in the scope of services provided by the Marketplace or changes in the functionality of the Site, as well as changes in legislation. The new version of the above-mentioned privacy policy comes into effect from the moment of its publication, unless it specifies a different time period for its entry into force.