Annex 5 to Order No. 30-E of ANO MEC Annex 20 to Order of ANO MEC No. 336/2 dated 15 December 2021
Privacy Policy
1. Terms Used in This Agreement
1.1. The Operator means the Autonomous Non-Profit Organization “Moscow Export Center” (hereinafter, ANO MEC) and the employees of ANO MEC authorized to manage the websites who organize and (or) carry out the processing of personal data and determine the purposes of personal data processing, the composition of the personal data to be processed and the actions (operations) performed with personal data.
1.2. The Website means the set of texts, graphic elements, design, images, software code, photo and video materials and other results of intellectual activity of the Operator available on the Internet under the domain name https://moscow-export.com and all its subdomains.
1.3. The User means any person who has visited the Website, filled in the fields of online forms on the Website and accepted the terms of the privacy policy (hereinafter, the Agreement).
1.4. Personal Data means the data provided by the User in the online forms of the Website (hereinafter, the Services) (full name, email address, telephone number, etc.).
1.5. Processing of Personal Data means the list of actions with the User's Personal Data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision of access), depersonalization, blocking, deletion and destruction of the Personal Data of the person who sent the request, and transfer at the request of a court, including to third parties, subject to measures ensuring the protection of Personal Data from unauthorized access.
2. General Provisions
2.1. Under this Agreement, Personal Data means:
2.1.1. data that the User provides about themselves when registering (creating an account) or when using the Exporter's Personal Account, or by filling in the fields of online application forms on the Services, including the Personal Data in the “Profile” section. Information that must be provided to the Services is specially marked with an asterisk. Other information is provided by the User at their discretion;
2.1.2. data that is automatically transmitted to the Services in the course of their use by means of software installed on the User's device, including data collected using the Yandex.Metrica web analytics service: IP address, cookie data, information about the User's browser (or other program used to access the Services), technical characteristics of the hardware and software used by the User, the date and time of access to the Services, the addresses of the requested pages and other similar information;
2.1.3. other information about the User whose processing is provided for by the User Agreement and the Privacy Policy.
2.2. This Privacy Policy applies only to the websites available at https://moscow-export.com and all its subdomains.
2.3. The Operator is not responsible for third-party websites that the User may access via links available on the Services specified in clause 2.2 of this Agreement.
2.4. If the User does not agree with the terms of the Privacy Policy, the User must refrain from transferring Personal Data to the Operator and from using the Services.
3. Purposes of Processing Users' Personal Data
3.1. The Services collect and store only the Personal Data necessary to provide services and/or to perform agreements and contracts with the User, except where the legislation of the Russian Federation requires Personal Data to be stored for a period established by law.
3.2. The User's Personal Data is processed for the purposes of:
3.2.1. identifying the User registered on the Services in order to collect the necessary statistical information and provide the User with the relevant services;
3.2.2. making calls to the User and sending the User informational messages, including by email and short messages (SMS), provided that the User has consented to receiving mailings:
3.2.2.1. by ticking the boxes “I agree to receive email notifications” and (or) “I agree to receive SMS notifications” when using the Service;
3.2.2.2. by ticking the boxes “I agree to receive email notifications” and (or) “I agree to receive SMS notifications” when sending an application for a service from the personal account.
3.2.3. providing the User with access to personalized resources of the Services;
3.2.4. establishing feedback with the User, including sending notifications and requests regarding the use of the Services and the provision of services, and processing requests and applications from the User; security and fraud prevention;
3.2.5. determining the User's location for development purposes;
3.2.6. confirming the accuracy and completeness of the Personal Data provided by the User;
3.2.7. creating an account to access restricted services of the Services, if the User has consented to the creation of an account;
3.2.8. providing the User with effective customer and technical support in case of problems related to the use of the Services;
3.2.9. creating, analyzing and monitoring the customer base.
4. Conditions for Processing Users' Personal Data and Transferring It to Third Parties
4.1. The confidentiality of the User's Personal Data is maintained, except where the User voluntarily provides information about themselves for public access by an unlimited number of persons.
4.2. The Operator may transfer the User's Personal Data to third parties in the following cases:
4.2.1. the User has consented to such actions;
4.2.2. the transfer is necessary for the User to use a particular service or for the performance of a particular agreement or contract with the User;
4.2.3. the transfer is provided for by Russian or other applicable legislation within the procedure established by law.
4.3. For the purposes of collecting statistical data, providing information, consulting and methodological support to Users and providing services, and solely to the extent necessary to achieve these purposes, the Operator transfers the following Personal Data of the User:
4.3.1. surname, first name, patronymic;
4.3.2. telephone number;
4.3.3. email address;
4.3.4. TIN (taxpayer identification number) (for an individual);
4.3.5. OGRNIP, the primary state registration number of an individual entrepreneur (if the request comes from an individual entrepreneur).
4.4. The Operator transfers the said Personal Data to the following authorities and organizations:
4.4.1. Department for Entrepreneurship and Innovative Development of the City of Moscow, TIN 9710068955;
4.4.2. State Budgetary Institution “Small Business of Moscow”, TIN 7703766666;
4.4.3. ANO “Human Capital Development”, TIN 7710364647;
4.4.4. State Budgetary Institution “Moscow Innovation Agency”, TIN 7703770430;
4.4.5. Moscow Innovation Cluster Foundation, TIN 9710075695;
4.4.6. Small Business Credit Assistance Fund of Moscow, TIN 7709664188.
(the list may be changed depending on the relations that actually arise between ANO MEC and third parties)
4.5. The User's personal data is processed without time limit by any lawful means, including by entering it into electronic databases, lists (registers) and internal reporting forms, and in personal data information systems with or without the use of automation tools. Users' personal data is processed in accordance with Federal Law No. 152-FZ “On Personal Data” of 27 July 2006 (hereinafter, the Personal Data Law).
4.6. The Operator takes the necessary organizational and technical measures to protect the User's Personal Data from unlawful or accidental access, destruction, modification, blocking, copying and distribution, as well as from other unlawful actions of third parties.
4.7. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's Personal Data.
5. Obligations of the Parties
5.1. The User must:
5.1.1. provide the Personal Data necessary to use the Services;
5.1.2. update and supplement the Personal Data provided if it changes.
5.2. The Operator must:
5.2.1. use the information received solely for the purposes specified in this Privacy Policy;
5.2.2. keep confidential information secret, not disclose it without the User's prior written permission, and not sell, exchange, publish or otherwise disclose the User's Personal Data transferred to it, except as provided for by this Privacy Policy;
5.2.3. take precautions to protect the confidentiality of the User's Personal Data in accordance with the requirements of the legislation of the Russian Federation and the Operator's local regulations;
5.2.4. block the Personal Data relating to the User concerned from the moment of the request of the User, their legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification, if inaccurate Personal Data or unlawful actions are detected.
5.3. By acceding to this Agreement, including when undergoing additional verification by confirming their telephone number by entering in the relevant field the code sent in a short message (SMS) to the telephone number specified by the User in the data entry form for submitting an application, and by leaving their data, the User:
5.3.1. confirms that all the data they have provided belongs to them personally;
5.3.2. acknowledges that they have carefully read this Agreement and the User Agreement in full and that the texts of these agreements are clear to them;
5.3.3. consents to the Operator processing the Personal Data provided as part of the information for the purpose of concluding this Agreement between the User and the Operator and its subsequent performance;
5.3.4. consents to receiving calls and informational mailings by email and short messages (SMS) from the Operator, provided that the User has consented to receiving mailings:
5.3.4.1. by ticking the boxes “I agree to receive email notifications” and (or) “I agree to receive SMS notifications”;
5.3.4.2. by ticking the boxes “I agree to receive email notifications” and (or) “I agree to receive SMS notifications” when sending an application for a service from the personal account.
5.3.5. agrees to the terms of Processing of Personal Data without reservations or restrictions, namely to the Operator performing the actions provided for in clause 3 of Part 1 of Article 3 of the Personal Data Law, and confirms that in giving such consent they act freely, of their own will and in their own interest;
5.3.6. is aware that without agreeing to the User Agreement and the Privacy Policy, the User will not be able to use the Services (submit an application for a service).
6. Liability of the Parties
6.1. An Operator that fails to fulfil its obligations is liable for losses incurred by the User in connection with the unlawful use of Personal Data in accordance with the legislation of the Russian Federation.
6.2. In the event of the loss or disclosure of confidential information, the Operator is not liable if such confidential information:
6.2.1. was or became public before its loss or disclosure;
6.2.2. was received from a third party before it was received by the Operator;
6.2.3. was disclosed with the User's consent.
7. Final Provisions
7.1. The Operator may amend this Agreement. When amendments are made, the date of the last update is indicated in the current version. The new version of the Agreement enters into force when it is posted, unless otherwise provided by the new version of the Agreement.
7.2. The current version of the Agreement is available at: https://moscow-export.com/docs/privacy.
7.3. This Agreement and the relations between the User and the Operator arising in connection with the application of the Agreement are governed by the legislation of the Russian Federation.
7.4. The Agreement is valid indefinitely from the moment the User provides their Personal Data and may be revoked by the User at any time by sending a corresponding order or statement in simple written form.