St. Petersburg «01» January 2015

Count Orlov LLC is the official operator that processes personal data: in accordance with the Federal Law of the Russian Federation No. 152 on the basis of order No. 72 of 03.24.2014 of the Federal Service for Supervision in the Sphere of Communications, Information Technology and Mass Media ( RosKomNadzor).

Within the framework of this document, the rules (hereinafter referred to as the Rules) are described that determine the procedure for processing, storing and protecting information about individuals using the services of Count Orlov LLC, information about which is posted on the website https://count-orlov.com ( hereinafter referred to as the Site). By leaving data on the site, you agree to the Privacy and Information Protection Policy.

1. DEFINITION OF TERMS

1.1. The following terms are used in this Privacy Policy:

1.1.1. «Administration of the site count-orlov.com» (hereinafter referred to as the Administration of the site) — employees authorized to manage the site, acting on behalf of Count Orlov LLC, who organize and (or) process personal data, and also determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

1.1.2. «Personal data» — any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).

1.1.3. «Processing of personal data» — any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.1.4. «Confidentiality of personal data» is a mandatory requirement for the Operator or other person who has gained access to personal data to prevent their dissemination without the consent of the subject of personal data or other legal grounds.

1.1.5. “Site user (hereinafter referred to as the User) is a person who has access to the Site via the Internet and uses the Site.

1.1.6. «Cookies» is a small piece of data sent by a web server and stored on a user’s computer, which the web client or web browser sends to the web server each time in an HTTP request when trying to open the page of the corresponding site.

1.1.7. «IP-address» is a unique network address of a node in a computer network built using the IP protocol.

 

2. GENERAL PROVISIONS

2.1. The use of the site by the User means acceptance of this Privacy Policy and the terms of processing of the User’s personal data.

2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the site.

2.3. This Privacy Policy applies only to the site. The Site does not control and is not responsible for third-party sites to which the User can click on the links available on the Site.

2.4. The site administration does not verify the accuracy of the personal data provided by the Site User.

 

3. SUBJECT OF THE PRIVACY POLICY

3.1. This Privacy Policy establishes the obligations of the Site Administration to not disclose and ensure the privacy protection of personal data that the User provides at the request of the Site Administration when registering on the site.

3.2. Personal data allowed for processing under this Privacy Policy is provided by the User by filling out forms on the count-orlov.com Website in the forms «Contact us», «Leave a review», «Submit an application» and include the following information:

3.2.1. surname, name, patronymic of the User;

3.2.2. User’s contact phone number;

3.2.3. e-mail address (e-mail);

3.2.4. country, city of the User;

3.2.5. place of work and position of the User;

3.3 Count Orlov LLC uses cookies to improve the quality of the website, make it easier to use the website and improve the user experience. Cookies allow the company to monitor and analyze the use of the website. LLC «Count Orlov» does not collect any personal data or information about persons using cookies.

3.4. Count Orlov LLC protects Data that is automatically transmitted when viewing ad units and when visiting pages on which statistics collection scripts (Yandex.Metrica and Google.Analytics) are installed: IP address; information about the browser (or other program that provides access to display ads); access time; the address of the page on which the ad unit is located; referrer (address of the previous page).

3.4.1. LLC «Count Orlov» collects statistics on the IP-addresses of its visitors. This information is used to identify and solve technical problems, as well as to protect your website from users who carry out DDOS attacks on the company’s website.

3.5. Any other personal information not specified above (browsing history, used browsers and operating systems, etc.) is subject to reliable storage and non-proliferation, except as provided in clauses. 5.2. and 5.3. of this Privacy Policy.

 

4. PURPOSE OF COLLECTING PERSONAL USER INFORMATION

4.1. The User’s personal data may be used by the Site Administration for the following purposes:

4.1.1. Establishing feedback with the User, including sending notifications, requests regarding the use of the count-orlov.com website, providing services, processing requests and applications from the User.

4.1.2. Determining the location of the User to ensure security, prevent fraud.

4.1.3. Confirmation of the accuracy and completeness of personal data provided by the User.

4.1.4. Notifications of the User of the count-orlov.com site about the status of the application.

4.1.5. Providing the User with his consent, service updates, special offers, price information, newsletters and other information on behalf of Count Orlov LLC.

4.1.6. Implementation of advertising activities with the consent of the User.

5. METHODS AND TERMS OF PROCESSING OF PERSONAL INFORMATION

5.1. The processing of the User’s personal data is carried out without any time limit, in any legal way, including in personal data information systems using automation tools or without using such tools.

5.2. The User agrees that the Site Administration has the right to transfer personal data to third parties, in particular, telecommunication operators, solely for the purpose of fulfilling the User’s order placed on the Site.

5.3. The User’s personal data can be transferred to the authorized government bodies of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.

5.4. In case of loss or disclosure of personal data, the Site Administration informs the User about the loss or disclosure of personal data.

5.5. The site administration takes the necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

5.6. The site administration, together with the User, takes all the necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

6. OBLIGATIONS OF THE PARTIES

6.1. The user is obliged:

6.1.1. Provide information about personal data necessary to use the Site.

6.1.2. Update, supplement the provided information about personal data in case of changes in this information.

6.2. The site administration is obliged:

6.2.1. Use the information received solely for the purposes specified in clause 4 of this Privacy Policy.

6.2.2. Ensure the storage of confidential information in secret, do not disclose without the prior written permission of the User, and also do not sell, exchange, publish, or disclose in other possible ways the transferred personal data of the User, with the exception of cl. 5.2. and 5.3. of this Privacy Policy.

6.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure usually used to protect this kind of information in existing business transactions.

6.2.4. Block personal data related to the relevant User from the moment of application or request of the User or his legal representative or the authorized body for the protection of the rights of subjects of personal data for the period of verification, in case of revealing inaccurate personal data or illegal actions.

7. RESPONSIBILITY OF THE PARTIES

7.1. The site administration, which has not fulfilled 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, with the exception of cases provided for in cl. 5.2., 5.3. and 7.2. of this Privacy Policy.

7.2. In case of loss or disclosure of Confidential Information, the Site Administration is not responsible if this confidential information:

7.2.1. Became public domain before its loss or disclosure.

7.2.2. Was received from a third party before it was received by the Site Administration.

7.2.3. Was disclosed with the consent of the User.

8. DISPUTE RESOLUTION

8.1. Before going to court with a claim for disputes arising from the relationship between the Site User and the Site Administration, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute).

8.2. The recipient of the claim within 30 calendar days from the date of receipt of the claim shall notify the applicant of the claim in writing about the results of the consideration of the claim.

8.3. If an agreement is not reached, the dispute will be referred to a judicial authority in accordance with the current legislation of the Russian Federation.

8.4. The current legislation of the Russian Federation applies to this Privacy Policy and the relationship between the User and the Site Administration.

9. ADDITIONAL TERMS

9.1. The site administration has the right to make changes to this Privacy Policy without the consent of the User.

9.2. The new Privacy Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new edition of the Privacy Policy.

9.3. Any suggestions or questions about this Privacy Policy should be reported to indicate a section of the Site.

9.4. The current Privacy Policy is posted on the page at: https://count-orlov.com/privacy-and-information-collection-policy/