INTELLECTUAL PROPERTY / TMT PRACTICE
User Agreement
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USER AGREEMENT dated 27.11.2019
Version 1.0 from 27.11.2019
This User Agreement (hereinafter – «Agreement») regulates the relations between a Limited Liability Company «Gorodissky & Partners Law Firm», a legal entity that exists under Ukrainian legislation and is registered to an address: 25 (A) Vyacheslava Chernovola street, Office 227, 01135 Kiev, Ukraine (hereinafter – «Firm»), and any person (hereinafter – «User») visiting (using) the website on the Internet at https://gorodissky.ua (hereinafter - «Website»).
By using the Website in any way, the User thereby accepts in full the following conditions of this Agreement, joins this Agreement and assumes all the obligations and risks described below.
YOU ARE A USER AND ARE OBLIGED TO READ THIS AGREEMENT BEFORE YOU WORK WITH THE WEBSITE. IF YOU DISAGREE WITH THIS AGREEMENT, DO NOT USE THE WEBSITE.
1. General provisions
1.1. The Firm is the owner of the Website and the administrator of the domain name gorodissky.ua. The Firm provides an access to the Website in accordance with this Agreement, and the User undertakes to use the Website properly within the limits of this Agreement.
1.2. The main purpose of the Website is to inform a wide range of Users about activities of the Firm, as well as to ensure communication between the Users and the Firm by means of web-forms («Feedback forms») and mailing lists. The information on the Firm profile may be updated from time to time without any public warnings.
1.3. The Website does not contain public offers for the provision of legal, patent and other services of the Firm.
1.4. The information on the Website is not regarded as legal, financial, tax, audit or any other advice and should be regarded as purely reference in character. The Firm is not liable for the use of this information by the User. It is necessary to seek advice from the relevant specialist of the Firm prior to any actions or refusal (refrain) from performing any actions, based on the information on the Website.
1.5. The Website contains (may contain) information on the Firm, the affiliates and business partners of the Firm. The Firm makes every effort to ensure the relevance of this information. However, the User is encouraged to independently contact the indicated offices/persons to clarify the issues of their activities using contact details provided on the Website.
1.6. Modification of the terms of this Agreement is allowed to unilaterally implement without a separate User notification. The version of the Agreement published on the Website is always current. The User is obliged to check the current terms of the Agreement once in a while.
1.7. This Agreement is drawn up in the Ukrainian, Russian and English languages. In cases of disagreement between the Ukrainian, Russian and English texts, the Ukrainian text has precedence.
2. Intellectual property rights
2.1. The Firm is the holder of exclusive copyright or the rights of use in relation to the Website in general, as well as all the results of intellectual activities provided on it, inter alia, texts, photographs, diagrams, graphic drawings, other images, programs for computers, including source files and object codes, video and audio recordings, other subjects of copyright, database, trademarks and service marks, as well as the layout and configuration of the above-listed objects on the pages of the Website, the Website design, including its look, color palette, structure and fonts (hereinafter jointly – «Content»).
2.2. The User is obliged to comply with the rights of the Firm for the Content and shall refrain from any action that might lead to the violations of the Firm’s rights for the Content or facilitate the commission of such violations by the third party.
3. Use of the Website
3.1. The Firm provides to the User a non-exclusive free-of-charge right to use the Content all over the world in the following ways:
— to access the Content and familiarize with it by launching the Website in the browser window during the User’s Internet session;
— to record the pages of the Website or their fragments on a data storage device (for example, a hard disk or flash drive) or print them in paper-based form for the purpose of using the Website in its primary role (paragraph 1.2 of the Agreement), provided that the following restrictions are observed by the User: (i) it is prohibited to distribute the copies (printouts) of the Website pages or their fragments, as well as multiple copying (printing) the Website pages that cannot be justified by the above mentioned purpose of the use; (ii) it is prohibited to remove, modify or hide the intellectual property protection signs or intellectual property notifications; (iii) it is prohibited to record (print) the pages of the Website or their fragments in case they contain a restraining notice regarding such actions or the software preventing such actions; (iv) it is prohibited to make changes and additions to the Content;
— to quote the Content in its entirety justified by the legitimate purpose of quoting, provided that the Website shall be indicated as the source of quotation (by inserting a hyperlink).
3.2. The User is not authorized to grant sub-licenses for the rights specified in paragraph 3.1 of the Agreement.
3.3. The rights outlined in paragraph 3.1 of the Agreement are assigned to the User, provided that the User complies with all the provisions of this Agreement. In the event of violation of any of these provisions the User’s rights to use the Website are deemed to be automatically terminated (without special notice from the Firm) from the moment of such a violation.
3.4. The Firm has the right at own discretion to withdraw or restrict access to the Website to individual Users or groups of Users without giving reasons.
3.5. The User is prohibited:
— to reproduce the Content in periodical publication and subsequently distribute copies of this publication, transmit the Content by air or cable broadcasting and make it available to the public without the prior consent of the Firm;
— to have access to the Website settings that are not intended for all Users or unauthorized Users;
— to use other Users’ login names and passwords or take other actions to impersonate another User;
— to use the Content by any means not listed in paragraph 3.1 of the Agreement, including but not limited to transformation, decompilation and its inclusion in composite works;
— to create phishing web resources, as well as any other web resources that are similar to the extent of its confusion with the Website or the Content;
— to perform any actions with the source code of the Website;
— to bypass the navigation system of the Website and take actions aimed at causing the improper operation of the Website, a slowdown or interruption of its functioning, an artificial increase in server and networks overload;
— to bypass antiviruses, firewalls and other means of protection installed on the Website and its hosting service;
— to search and exploit the vulnerabilities of the Website;
— to access the Website by using web-bots, except official search robots owned by search engines;
— to use the Feedback forms for purposes other than those specified by the Firm;
— to send malware, advertisement, spam or fraudulent e-mails through the Feedback forms;
— to track other Users’ activities and establish their identity;
— to take any actions that are contrary to the legislation of Ukraine and (or) the State where the User is located;
— to incite other persons to commit the above-mentioned actions;
— to commit other actions forbidden by the terms of this Agreement.
4. Feedback forms
4.1. The Firm may place Feedback forms on the Website for applications for the vacant positions, subscriptions to information and marketing mailings, communication with the staff of the Firm and submitting other messages (hereinafter jointly – «Messages»).
4.2. Some Feedback forms may contain a field for indicating the organization that is represented by the User. If this field is filled out, the Firm regards the User as an authorized representative of the specified organization. In all other cases, the User sends Messages on his own behalf and solely in his own interest.
4.3. Messages shall be relevant for the purpose of the Feedback form (it is indicated in the headline), otherwise they may be deleted without consideration.
4.4. Feedback form for employees of the Firm may be posted on the Website. The User should take into account that the Messages addressed to a particular employee may be available to other employees (for example, assistants or employees responsible for processing correspondence). In this regard, the User should refrain from sending private Messages or strictly confidential materials that are not intended for the public disclosure except the direct addressee.
4.5. Feedback forms are not intended for sending any materials containing a secret protected by law (attorney/client privilege, secrecy of the investigation, banking secrecy etc.).
4.6. Clients, contractors and other counterparties of the Firm shall not use the
Feedback forms for correspondence on the contracts concluded with the Firm during the work.5. Mailings
5.1. An information and marketing mailing function may be implemented on the Website. The Firm is the holder of the disseminated information. If necessary, any interested individuals might be guided by information on the name, location and address, as well as e-mail address of the Firm, given in this Agreement.
5.2. The Users are able to change the terms of subscription and unsubscribe at any time in the corresponding sections of the Website. The Firm has the right at own discretion to cancel the subscription of any User or reject the User’s subscription without explanation. The Firm is not entitled to unilaterally change the terms of mailing with respect to the subject of messages sent.
5.3. When subscribing, it is forbidden to use an e-mail address which does not belong to the User.
6. Personal cabinet
6.1. The restricted access section may be maintained on the Website that is intended for clients of the Firm (hereinafter – «Personal cabinet»). The User needs to pass the procedure of registration and authentication for gaining access to the Personal cabinet.
6.2. The registration procedure is performed once and consists in creating unique login and password for the User – the client of the Firm. The login name and password is provided in agreement with the Firm. The Firm may establish regulations regarding periodical replacement of login names and passwords for security purposes.
6.3. The authentication procedure is performed every time the User intends to use the Personal cabinet. This procedure consists in entering login and password assigned to the User in the web-form fields, accordingly, the information about that matter shall be transmitted to the Firm after clicking on the relevant button of the web-form. From that point, the User is considered to be an authorized representative of the Firm’s client and perform all the activities on the Website on behalf of a designated client prior to the logout from the Personal cabinet.
6.4. The User, namely the client of the Firm, has no right to take screenshots, as well as save or print the pages of Personal cabinet, unless this type of function is provided on the relevant pages.
7. External references
7.1. The Website may contain references to other web-resources of a third-party. The Firm applies every effort to ensure removing any references to unreliable, fraudulent or any other similar web-resources. However, their work is not governed by this Agreement. The Firm is not responsible for the content of web-resources belonging to the third party and their functioning, including possible harm that could be caused to the Users on the referred web-resources.
8. Insecurity
8.1. AN ACCESS TO THE WEBSITE IS PROVIDED TO THE USER ON AN «AS IS» BASIS. THE FIRM HEREBY DISCLAIMS ANY WARRANTY WITH RESPECT TO THE CONTENT AND THE WEBSITE. AMONG OTHERS, THE FIRM CANNOT GIVE GUARANTEES TO THE USER THAT: (i) the Website does not contain software errors, shall work without outages, is also consistent with the User’s devices and shall be correctly displayed on such devices; (ii) the Website and its separate pages shall be constantly available to the User; (iii) the Website contains complete, comprehensive, accurate, error-free and suitable for the User’s needs information about the Firm and its activities and reference, news, analytical materials on the legal and other issues; (iv) the pages of the Website shall look the same as they do online while printing or recording on a machine-readable storage device; (v) the Website does not contain information denied or restricted in the country of the User’s location; (vi) the Website does not contain information that, in the User’s view, might be incorrect or offensive.
8.2. When using the Website, the User is obliged to rely on his own antiviruses, firewalls and other information security assets. The Firm makes every possible effort to ensure the protection of the Website from the hacker attacks, cybercrimes and other harmful and dangerous activities committed by unidentified external parties that might harm the User. However, the Firm disclaims any warranty concerning illegal use of the Website and its Content by the third parties that could result in damage to the User.
9. Limitation of liability
9.1. The Firm is not liable for any violation of obligations under the Agreement and incurring User’s loss as the result of using the Website, save in cases of intent of the Firm. The Firm is not liable for causing any other harm to the User, unless it caused through the fault of the Firm.
9.2. The User is liable for the violation of this Agreement, as well as intellectual rights and other rights of the Firm in its entirety in accordance with the applicable legislation (paragraph 11 of the Agreement), and also the legislation in force in the User’s location (if the User’s actions constitute a crime or any other offence under the law of this State).
10. Confidentiality
10.1. The User login and password (to login to Personal cabinet) is considered confidential information. The User has no right to disclose logins and passwords to the third parties, as well as use and store them in such a way that the third party can get an access to them.
10.2. The User’s personal data is a confidential information and is processed in accordance with the Policy of «Gorodissky & Partners Law Firm, LLC» regarding personal data processing on the Website.
10.3. Messages sent through the Feedback form are considered to be confidential information and shall not be disclosed by the Firm, except in the following cases: (i) the User who sent the Message asked by himself in written form for its disclosure to the third party or its promulgation; (ii) the Message is to be disclosed as directed by the competent court upon legitimate demand of law enforcement bodies and other public authorities on an equal basis with applicable legislation (paragraph 11 of the Agreement); (iii) access to the Message is given to the contractors of the Firm delivering technical support, maintenance of the Website and information systems of the Firm on condition that a confidentiality agreement extending to the Messages were signed with them; (iv) Messages contain information on the committed or prepared crimes, administrative offences or offence indications.
10.4. Use of cookies
Personal data is never collected by the Firm in secret from the Users. The statistics service may be applied on the Website, as well as identifying of public interest and other similar instruments collecting and analyzing only non-personal data.
The Website can automatically save cookies on the Users’ computers (small text files of a technical nature) not containing personal data and are not used to identify the User. In case the User does not want to save the specified files on his computer, he can at any time change the browser settings and delete the saved files by using the standard browser functionality.
11. Applicable law and dispute resolution
11.1. This Agreement and all relations of the Parties due to the use of the Website are regulated by the law of Ukraine.
11.2. All disputes arising in connection with the present Agreement or related to the use of the Website shall be settled through the courts at the location of the Firm.
12. Feedback
12.1. Requests on issues related to the Website and allegations of copyright infringement and (or) related rights should be sent by e-mail: office@gorodissky.ua or to the following mailbox: 25 (A) Vyacheslava Chernovola street, Office 227, 01135 Kiev, Ukraine
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WEBSITE DATA PRIVACY POLICY
1. GENERAL
1.1 This Website Data Privacy Policy (the Policy) is adopted by Law Firm «Gorodissky & Partners» Ltd. registered at 25, Bolshaya Spasskaya str., bldg. 3, Moscow, 129090, Russia, taxpayer identification number (TIN) 7702195561, primary state registration number (OGRN) 1027739045630 (hereinafter referred to as the Operator). The Policy applies to personal data processing through websites www.gorodissky.ru and www.gorodissky.com administered by the Operator (jointly, the Websites).
1.2 This Policy is based on the Constitution of the Russian Federation, the Federal Law On Information, Information Technologies and Information Security No. 149-ФЗ dated 27 July 2006, the Federal Law On Personal Data No. 152-ФЗ dated 27 July 2006 and other data protection and processing regulations of Russia.
1.3 This Policy sets forth the main principles, purposes, procedure and conditions of the personal data processing and the implemented data security requirements. The purpose of this Policy is to ensure that the data subjects rights and freedoms are protected.
1.4 This Policy is permanently published (posted) on the Websites to ensure unimpeded access to this Policy.
1.5 The personal data is processed in the Russian Federation and in accordance with the laws of the Russian Federation (the Applicable Laws).
2. MAIN TERMS AND DEFINITIONS
2.1 Unless otherwise expressly stated herein, this Policy shall be applied, construed and interpreted according to the following terms in singular or plural, whether capitalized or regular.
— Applicable Laws shall mean the laws of the Russian Federation.
— Feedback Forms shall mean web forms intended for sending electronic messages to the Operator.
— Information shall mean details (messages, data), regardless of their form.
— Operator shall mean Law Firm Gorodissky & Partners LLC.
— Data Blocking shall mean temporary suspension of personal data processing (except where the processing is required to clarify personal data).
— Collection of Personal Data shall mean a dedicated process of obtaining the Personal Data directly from the User.
— Destruction of Personal Data shall mean any actions resulting in impossibility to restore the contents of the Personal Data in the Personal Data Information System and (or) in the destruction of media containing Personal Data.
— Distribution of Personal Data shall mean any actions aimed at the public disclosure of the Personal Data.
— Personal Data Information System shall mean a set of personal data contained in databases together with information technologies and data processing tools.
— Data Processing shall mean an action (operation) or set of actions (operations) with the Personal Data as described in this Policy.
— Provision of Personal Data shall mean any actions aimed at the disclosure of personal data to a particular person or a particular group of persons.
— Personal Data shall mean any information relating to a directly or indirectly identified or identifiable individual (data subject).
— Personal Data Storage shall mean a process of keeping systematized Personal Data in the Operators possession.
— Personal Data Subject shall mean an individual to whom the Personal Data pertain.
— Policy shall mean this Website Data Privacy Policy.
— User shall mean an individual visiting (using) the Websites according to the User Agreement .
— Websites shall mean the websites www.gorodissky.ru and www.gorodissky.com administered by the Operator.
3. DATA PROCESSING PRINCIPLES
3.1 The privacy policy for the Websites is that the Personal Data must be processed only in cases and according to the procedure specified by law with a view to the main business of the Operator and the balance of interests of the Operator and the Data Subjects. The Personal Data shall be processed in a way ensuring legal protection of the Data Subjects rights and freedoms including the protection of their right to privacy, personal and family secrets. The Data Processing shall be based on the following principles:
— Operator shall process the Personal Data on a legal and fair basis;
— Data Processing shall be limited to concrete, pre-determined and lawful purposes;
— Data Processing incompatible with the purposes of the Collection of Personal Data is prohibited;
— Integration of databases containing the Personal Data, which is processed for the purposes incompatible with each other, is prohibited;
— Personal Data shall be processed only if it meets the Data Processing purposes;
— Contents and scope of the Personal Data being processed shall meet the declared processing purposes; it is prohibited to process excessive Personal Data as compared to the declared processing purposes;
— Accuracy, sufficiency and, where necessary, relevancy to the purposes of the Data Processing shall be ensured. The Operator shall take all necessary actions (or ensure that they are taken) to delete or clarify incomplete or inaccurate Personal Data;
— Personal Data shall be stored in the form enabling identification of the Data Subject for no longer than it is required for the purposes of the Data Processing unless otherwise agreed and the Data Subject shall act as a party, beneficiary or guarantor under such agreement. Unless otherwise established by law, the processed Personal Data shall be destroyed when the processing purposes are achieved or become irrelevant.
4. PERSONAL DATA CATEGORIES AND PROCESSING PURPOSES
4.1 The User Personal Data may be processed on the Websites for the following purposes:
— Communications;
— Mailings and promotion of services;
— Events registration;
— User account; and
— Other purposes determined as set forth in the Operators internal documents.
Specific purposes may be also specified in a Feedback Form.
4.2 The Feedback Forms shall be composed in a way ensuring that the contents and scope of the Personal Data are consistent with the declared processing purposes.
4.3 The Operator shall not process sensitive categories of the Personal Data, such as race, national identity, criminal record, political views, and religious or philosophical beliefs. No biometric Personal Data of the User (for example, photos) shall be processed on the Websites.
4.4 The Operator shall never collect the Personal Data secretly. The Websites may contain analytical services calculating visits, assessing the level of visitors interest and any other similar tools collecting and analysing solely depersonalized information (not personal data). The Websites may automatically save cookies (small technical text files) to the User computer. Such cookies shall not contain the Personal Data and they shall not be used for establishing the identity of the User. If the User does not want to save the said files to his or her computer, he or she may at any time change the browser settings and delete the files already saved using the standard functions of the browser.
4.5 The Operator shall not use the Websites to process any financial information or credit card details of the User.
5. LEGAL GROUNDS FOR DATA PROCESSING
5.1 The legal grounds for the Data Processing include a set of legal acts, according to which the Operator processes the Personal Data and protects the Data Subjects rights.
5.2 The legal grounds for the Data Processing with the use of the Websites include the following legal rules: Article 10 of the Federal Law On Information, Information Technologies and Information Security No. 149-ФЗ dated 27 July 2006, Article 18 of the Federal Law On Advertising No. 38-ФЗ dated 13 March 2006, Article 6 (1) (1, 5) and Article 14(3) of the Federal Law On Personal Data No. 152-ФЗ dated 27 July 2006, and other regulations depending on the specific processing purposes.
6. DATA PROCESSING PROCEDURE AND CONDITIONS
6.1 The Personal Data shall be processed on the Websites with and without the automation tools within the time period as necessary for the processing purposes. The Operator may cease the Data Processing upon achieving the processing purposes, Data Subjects consent withdrawal, winding-up of the Operator business or the Websites, or changing the Websites functions.
6.2 The Operator uses the Websites to collect, record, extract and use the User personal data. The Operator may perform transborder transfer of the Personal Data if and where necessary and subject to the Applicable Laws. Prior to a transborder transfer, the Operator shall check whether the country where the Personal Data will be transferred ensures an adequate level of protection of the Data Subjects rights.
6.3 Other operations with the Personal Data, including storage, shall be carried out without the Websites. These operations are regulated by the Operator internal documents.
6.4 In order to communicate with the Users, the Operator provides the Feedback Forms and processes the submitted inquiries for the purpose of liaising with the Users. The Operator does not keep the inquiries on the Websites. All inquiries are forwarded for processing to the authorized employees. The Operator shall process only those User Personal Data that is specified in appropriate fields of the Feedback Forms. For example, such Personal Data may include the following (depending on a specific Feedback Form): full name; contact details; data contained in the CV and its attachments; name of the employer; position; message content; and others. The Operator’s employees do not use the Websites for sending responses to the User’s inquiries.
6.5 The Websites offer mailings to the Users. The Users may determine the mailing topics, such as: advertisements, reviews of laws and case law, news, reference information, and other materials. The Operator may organize the mailings with or without the User Personal Data as described below:
6.5.1 Subject to the User’s consent, the Organizer may collect the Personal Data (for example, full name, contact details, positions, employer name, etc.) through the relevant mailing web-form and use it to customize the mailings, direct targeted advertisements, and for other similar purposes;
6.5.2 User may key in his/her email address in the relevant mailing form. In such a case, no Personal Data shall be processed and no information relating to a directly or indirectly identified or identifiable individual shall be requested or collected.
6.6 The Users may register for an informational or marketing event on the Websites. Full name, contact details, position, and other Personal Data may be processed for the registration purposes. The User may receive the registration confirmation or refusal by e-mail or phone.
6.7 The Users’, acting as the Operator’s clients shall complete their online registration to use their accounts. For this purpose, they shall provide the Operator with their full names, contact details (i.e. emails), logins and passwords chosen by the Users, and other Personal Data through the relevant Feedback Form.
6.8 The Operator shall always process the Personal Data upon the User consent unless otherwise prescribed by the laws of Russia.
6.9 For the declared purposes, the Operator may disclose the Personal Data to third parties, including its affiliated companies, and assign the Data Processing to a third party processor according to an agreement which must contain confidentiality clauses and other mandatory clauses prescribed by the Applicable Laws.
6.10 The Operator always collects the Personal Data based on the following:
— all Personal Data belongs only to the User who filled out the Feedback Form (use of third-party data is prohibited);
— User is 18 or older and he/she is legally capable; and
— User has provided accurate and up-to-date Personal Data.
If the Operator believes that any of the above conditions is not met, the Operator may request that the User clarify the Personal Data prior to considering his/her message.
6.11 When collecting the Personal Data, the Operator shall ensure recording, systematizing, accumulating, storing, clarifying (updating, changing) and retrieving of the Personal Data of the Russian Federation citizens with the use of the databases located in the territory of the Russian Federation.
6.12 The Users’ Personal Data constitute confidential information according to the Applicable Laws. The Operator shall take actions necessary and sufficient to ensure due performance of the obligations prescribed by the Russian personal data law. If necessary, the Operator shall take the following actions aimed at protecting the Data Subjects’ rights:
— Appointment of the data protection officer;
— Adoption of the Privacy Policy, other internal policies on the Data Processing matters, data breach revealing, preventing and elimination procedures;
— Application of legal, organizational and technical measures ensuring the security of the Personal Data as prescribed by the Applicable Laws;
— Internal control and/or audit of the compliance of the Data Processing with the Russian personal data law and other regulations adopted in accordance with them, the requirements to Personal Data protection, the Operator’s Privacy Policy and other internal policies;
— Assessment of harm that may be caused to the Data Subjects in case of a data breach, correlation between the said harm and measures taken by the Operator to ensure performance of the obligations established by the Russian personal data law;
— Acquaintance of the Operator’s employees directly processing the Personal Data with the provisions of the Russian personal data law, including the data protection requirements, the Privacy Policy, other internal policies on Personal Data Processing, and/or training of the said employees; and
— Ensuring unrestricted access to the Privacy Policy and to the information on the implemented data protection requirements including the publication of this Policy on the Websites.
6.13 The Personal Data security shall be ensured by the Operator, in particular, by:
— Determining the data security threats during the processing in the Personal Data Information Systems;
— Applying organizational and technical measures to ensure the data security during its processing in the Personal Data Information Systems according to the data protection requirements corresponding to the data protection levels established by the Government of the Russian Federation;
— Applying the information security tools that were assessed according to the prescribed procedure for compliance assessment;
— Assessing the efficiency of the measures taken to ensure data security before putting the Personal Data Information Systems into operation;
— Keeping records of digital media;
— Detecting unauthorized access to the Personal Data and implementing the relevant measures;
— Recovering the Personal Data modified or destroyed as a result of the unauthorized access;
— Setting forth the rules for access to the Personal Data processed in the Personal Data Information Systems and ensuring the registration and record of all actions taken with regard to the Personal Data in the Personal Data Information Systems; and
— Controlling the data security measures and the data protection level relevant for the Personal Data Information System.
6.14 The Operator hereby publishes the information on the implemented data protection requirements. As necessary and subject to the threats relevant to the information systems ensuring the operation of the Websites, the Operator shall comply with the following requirements (or ensure their implementation by the third-party processors):
— Ensures the security of premises accommodating the information systems to prevent any person without appropriate access rights from uncontrolled intrusion or stay in these premises;
— Ensures the safety of data media;
— Adopts a list of employees whose work duties require access to the Personal Data processed in the information systems (by a CEO’s decision);
— Uses information security tools, of which compliance with the information security requirements of the applicable laws is duly assessed and confirmed, when such tools are necessary for the neutralization of actual threats; and
— Appoints an employee or a business unit as a data protection officer.
7. DATA SUBJECTS’ RIGHTS
7.1 The User shall have the right to
— Receive the information relating to his or her Data Processing, access to his/her Personal Data, and receive a copy of any record containing his/her Personal Data, except for the cases prescribed by the laws of Russia;
— Detail his/her Personal Data, block or destroy when so prescribed by law;
— Appeal against the Operator’s actions (omissions) to the competent authorities;
— Protect his/her rights and legitimate interests including the compensation of damages and/or moral hazard in a judicial or other appropriate legal procedure;
— Revoke his/her consent to the Data Processing; and
— Exercise any other rights provided by the Russian personal data law.
8. PERSONAL DATA UPDATE, CORRECTION, DELETION AND DESTRUCTION
8.1 If it is revealed and confirmed that the Personal Data is inaccurate or processed illegally, this Personal Data shall be updated or the Data Processing shall be terminated.
8.2 Unless otherwise prescribed by the Applicable Laws, the Personal Data shall be destroyed upon achieving the Data Processing purposes or revoking the Data Subject’s consent.
9. RESPONSES TO REQUESTS AND INQUIRIES
9.1 The Operator uses its best efforts to process the Personal Data transparently and promptly respond to requests and inquiries received from the Users, the Data Protection Authority and other state authorities.
9.2 Requests, inquiries, and other messages about the inaccuracy of Personal Data, illegal Data Processing, revocation of consent, Data Subject’s access to his or her data, and any other issues concerning the Data Processing and protection, shall be sent to pat@gorodissky.ru or by regular mail to: 25, bldg 3, Bolshaya Spasskaya street, Moscow, 129090, Russia.
10. FINAL PROVISIONS
10.1 This Policy shall enter into force when published (posted) on the Websites and remain effective until cancelled or replaced with a new version.
10.2 The Operator may unilaterally amend or supplement this Policy. The new version of this Policy shall enter into force when it is published (posted) on the Websites unless otherwise specified in that new version. Should the amendments affect the Users’ rights, the Operator may notify the Users of these amendments by sending a notice according to their contact details or otherwise.
10.3 In case of any dispute connected with the application or fulfilment of this Policy, the Operator and the affected Data Subject shall use their best efforts to resolve it through negotiations and (or) mutual compromises. In case the dispute is not resolved through negotiations and (or) mutual compromises, the dispute shall be resolved according to the laws of Russia.
