Moscow, Russia

Date of publication: March 27, 2023

1. What this Policy covers

This Privacy Policy (the “Policy”) will apply to any information, including personal data within the meaning of applicable Russian laws (“Personal Information”) that RNC, NPP (“RNC”) may obtain from you during your use of the website https://ruscorpora.ru/, any RNC other websites, programs, or products (collectively, the “Website”), and during the performance by RNC of any agreements (contracts) entered into with you in connection with your use of the Website. 

2. Who processes information

To enable you to use the Website, your Personal Information will be collected and used by RNC, NPP (Non-Profit Partnership), a legal entity, duly organized under the laws of Russian laws, with its registered office located at: 2 Gogolevsky Boulevard, Moscow, 119019 (Primary State Registration Number (OGRN) 1127799008875).

3. What is the purpose of this Policy?

RNC is committed to protecting your Personal Information and respecting your privacy. Therefore, during your use of the Website, RNC will protect and process your Personal Information in strict compliance with applicable Russian laws.
Fulfilling our duties to protect your Personal Information, in this Policy, we would like to inform you most transparently about:

(a)    Why and how RNC collects and uses (‘processes’) your Personal Information when you are using the Website;

(b)    What is the role and duties of RNC as a legal entity that makes a decision on why and how to process your Personal Information;

(c)    What tools you can use to reduce the scope of the Personal Information that RNC collects about you; and

(d)    What rights you have with respect to the processing of your Personal Information.

4. What Personal Information RNC collects about you

The Personal Information collected during your use of the Website and of any websites, programs, products, or services of Partners may vary, depending on whether you use your account to access them or not. Where you log into your account, the Personal Information collected by RNC about you during your use of the Website may be matched and linked with the other Personal Information collected by RNC during your use of your account (for example, your identity, contact details, age and sex, if these data have been provided to RNC). RNC will not verify the Personal Information that you have provided and cannot assess its accuracy or whether you have sufficient legal capacity to provide your Personal Information. Nevertheless, RNC assumes that you provide accurate and sufficient Personal Information and update it in a timely manner.
RNC may collect the following categories of Personal Information about you during your use of the Website: 

(i)    The Personal Information that you provided when registering (creating an account), such as your name, telephone number, email address, and place of employment;

(ii)    Electronic data (HTTP headers, IP address, cookie files, web beacons/pixel tags, browser identifier, hardware and software information, Wi-Fi network data);

(iii)    The date and time of accessing the Website;

RNC will not collect any sensitive personal information purposefully (such as race, political opinions, data concerning health or biometric data). RNC will not collect data to profile a user to the extent to which it may materially affect your rights and freedoms under applicable Russian laws.

5. What are the legal basis and the purposes of the processing of your Personal Information?

RNC may not process your Personal Information without a sufficient legal basis. Therefore, RNC will process your Personal Information only if:

(i)    the processing is required to perform the agreements (contracts) between you and RNC;

(ii)    the processing is required to comply with statutory obligations;

(iii)    it is provided for in applicable Russian laws, the processing is required to pursue the legitimate interests of RNC where such processing does not materially affect your interests or your fundamental rights and freedoms. Please note that when processing your Personal Information on this basis, RNC will always endeavor to maintain the balance between its legitimate interests and the protection of your privacy.

RNC will process your Personal Information to pursue its legitimate interests, for example:

(a)    to have a better understanding of how you interact with the Website;

(b)    To enhance, change, personalize, or otherwise improve the Website in the interests of all users;

(c)    To achieve specific purposes or to meet the requirements of applicable Russian laws, we may request your separate consent to the processing of your Personal Information. 

RNC will always process your Personal Information for a specific purpose and only the Personal Information that is relevant to that purpose. In particular, we will process your Personal Information:

(i)    To provide you with access to the Website;

(ii)    To provide you with access to your account;

(iii)    To send you notifications, requests, and information related to the Website, perform the agreements (contracts) with you, and process your requests and applications;

(iv)    To protect your rights and the rights of RNC;

(v)    To collect, process, and provide statistics, big data, and other research;

(vi)    To detect security threats for the Website, users, RNC and/or third parties, including a due diligence review of you where an agreement is to be entered into using the Website.

6. How RNC protects your Personal Information

In most cases, Personal Information will be processed automatically without access to it by any of RNC employees. If there is a need for such access, it may be provided only to those RNC employees or authorized officials that need it to perform their duties. To protect data and keep them confidential, all employees must comply with the internal policies and procedures related to the processing of Personal Information. They must also comply with all technical and organizational security measures aimed at protecting your Personal Information.

7. Where your Personal Information is stored and processed

Your Personal Information will be stored in the Russian Federation.
For Russian users: RNC will record, systematize, accumulate, store, rectify (update, alter), and retrieve the personal data of Russian citizens using databases situated in Russia.
If you are located in a territory that requires your consent to transfer your Personal Information to another jurisdiction, then, by using the Website, you give RNC your explicit and unambiguous consent to such transfer or storage and/or processing of information in Russia.

8. For how long we store your Personal Information

RNC will store your Personal Information for as long as it is necessary to achieve the purpose, for which it has been collected, or to comply with applicable Russian laws or regulations.

Unless otherwise required by law or agreement with you, the email messages and documents that you store in the RNC system as part of the Website will be stored until you have an account, but you may delete them at any time.

If you would like your Personal Information to be deleted from the RNC databases, you may delete necessary Personal Information through the interface of the Website (where applicable) yourself or send a request to RNC to do so. 

10. Your rights

10.1. What rights do you have?

If it is provided for in applicable Russian laws, you will have the right to access your Personal Information processed by RNC in accordance with this Policy.

If you believe that any information that RNC stores about you is incorrect or incomplete, you may log into your account and rectify your Personal Information yourself.

If it is provided for in applicable Russian laws, you will have the right to:

review the information that RNC stores about you;

request the deletion of your Personal Information, or a portion of it, and withdraw your consent to the processing of your Personal Information;

request restriction of the processing of your Personal Information; 

object to the processing of your Personal Information, if it is provided for in applicable Russian laws.

RNC will respond to such requests in accordance with applicable Russian laws.

When you are using the Website, the transfer of your Personal Information may be made with your consent expressing your free will and interest (in particular, under an agreement with you) and does not constitute a duty under law.

10.2. How you may exercise your rights

To exercise the rights referred to above, please log into your account, and if there is no special function in the interface, please contact RNC.

If you are not satisfied with how RNC processes your Personal Information, please contact us, and we will consider your complaint. If you are not satisfied with RNC’s response, you will have the right to file a complaint with a competent authority.

11. Updating this Policy

This Policy may be modified. RNC will have the right to modify this Policy at its discretion, including, but not limited to, where modifications are due to changes in applicable Russian laws and where modifications are due to changes in the Website.
RNC undertakes not to make any material modifications, not to impose any additional burdens or restrictions on your rights established by this Policy without notifying you. You will be notified of such modifications. Notifications may be displayed on the Website (for example, as a pop-up window or a banner) before such modifications take effect, or may be sent to you via other communication channels (for example, e-mail, if you have provided us with your contact details).