Privacy policy

The policy of BLINGER LLC regarding the processing of personal data
Published date: September 01, 2021
This Privacy Policy (Agreement) forms part of the License Contract under Terms of Use of Blinger LLC (the Principal Agreement). This Agreement is an amendment to the Principal Agreement and is effective upon its incorporation to the Principal Agreement, which incorporation may be specified in the Principal Agreement or an executed amendment to the Principal Agreement. Upon its incorporation into the Principal Agreement, this Agreement will form a part of the Principal Agreement.

We periodically update this Agreement. If you have an active ProtonMail account, you will be informed of any modification by email.

The term of this Agreement shall follow the term of the Principal Agreement. Terms not defined herein shall have the meaning as set forth in the Principal Agreement.


1. DEFINITIONS

1.1. Personal data - any information related directly or indirectly to a specific or identifiable individual (citizen) - the subject of personal data. Such information, in particular, includes full name, date and place of birth, address, information about family, social, property status, information about education, profession, income, information about the state of health, as well as other information.

1.2. Operator - a state body, a municipal body, a legal entity or an individual who independently or jointly with other persons organize and (or) carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

1.3. Personal data processing - any action (operation) or a set of actions (operations) with personal data performed using automation tools or without the use of such tools. Such actions (operations) include collection, receipt, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.4. Website User (hereinafter referred to as the User) - a person who has access to the Website via the Internet and uses the Website.

1.5. Automated processing of personal data - the processing of personal data using computer technology.

1.6. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.

1.7. Distribution of personal data - actions aimed at disclosing personal data to an indefinite circle of persons or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, posting in information and telecommunications networks or providing access to personal data in any other way.

1.8. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

1.9. Destruction of personal data - actions as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.

1.10. Personal data - any information related directly or indirectly to a specific or identifiable individual (citizen) - the subject of personal data. Such information, in particular, includes full name, date and place of birth, address, information about family, social, property status, information about education, profession, income, information about the state of health, as well as other information.

1.11. Operator - a state body, a municipal body, a legal entity or an individual who independently or jointly with other persons organize and (or) carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

1.12. Personal data processing - any action (operation) or a set of actions (operations) with personal data performed using automation tools or without the use of such tools. Such actions (operations) include collection, receipt, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.13. Website User (hereinafter referred to as the User) - a person who has access to the Website via the Internet and uses the Website.

1.14. Automated processing of personal data - the processing of personal data using computer technology.

1.15. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.

1.16. Distribution of personal data - actions aimed at disclosing personal data to an indefinite circle of persons or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, posting in information and telecommunications networks or providing access to personal data in any other way.

1.17. Cross-border transfer of personal data - the transfer of personal data from the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

1.18. Destruction of personal data - actions as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.


2. PURPOSE AND SCOPE OF ACTION

2.1. This Policy of BLINGER LLC (ООО "БЛИНГЕР") regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that BLINGER LLC (ООО "БЛИНГЕР") (hereinafter referred to as the "Company", the "Operator") can receive about the User during the use of the website on the Internet at https://hugery.com (hereinafter referred to as the "Website"), about current and potential customers, contractors under civil law contracts, representatives of legal entities and individual entrepreneurs.

2.2. This Policy has been developed in accordance with the provisions of the Federal Law "On Personal Data", the Federal Law "On Information, Information Technologies and Information Protection", as well as other regulatory legal acts regulating the protection of personal data

2.3. Personal data is confidential, protected information and they are subject to all the requirements established by the Company's internal documents for the protection of confidential information.

2.4. The Policy applies to all personal data of subjects processed in the Company with the use of automation tools and without the use of such tools.

2.5. This Privacy Policy applies only to the website at https://hugery.com. BLINGER LLC (ООО "БЛИНГЕР") does not control and is not responsible for third-party websites to which the User can click on the links available on the Website.

2.6. Any subject of personal data has access to this Policy.

2.7. The use of the Website of BLINGER LLC (ООО "БЛИНГЕР") means the user's unconditional consent to this Policy and the terms of personal data processing specified therein; in case of disagreement with these terms, the user should refrain from using the Website.

2.8. The purpose of this Policy is to ensure the protection of the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets, the protection of honor and repute, the protection of information from unauthorized access and disclosure.


3. SUBJECTS AND CATEGORIES OF PERSONAL DATA

3.1. BLINGER LLC (ООО "БЛИНГЕР") processes the personal data of the following persons:
  • users of the Website of BLINGER LLC (ООО "БЛИНГЕР"); subjects with whom civil contracts have been concluded and their representatives;
  • customers, potential customers of BLINGER LLC (ООО "БЛИНГЕР");
  • representatives of legal entities and individual entrepreneurs.
3.2. These persons provide personal data independently, at their own will.

3.3. The Company does not verify the accuracy of the data provided, based on the assumption that the persons specified in clause 3.1 of this Policy provide reliable and sufficient information and maintain its relevance.

3.4. The Company processes various categories of personal data, in particular (but not limited to) the following: surname, first name, patronymic; phone number; e-mail address; postal address


4. PRINCIPLES AND PURPOSES OF PERSONAL DATA PROCESSING

4.1. Processing of personal data is carried out without a time limit in any legal way, including in personal data information systems with or without the use of automation tools.

4.2. Processing and ensuring the security of personal data is carried out in accordance with the requirements of the Constitution of the Russian Federation, Federal Law No. 152-FL "On Personal Data", by-laws, other federal laws of the Russian Federation and other regulatory legal acts defining the cases and features of personal data processing, as well as on the basis of the Company's Charter, local regulatory acts of the Company, including this Privacy Policy, contracts concluded between the Company and personal data subjects or other persons, the subject's consent to the processing of personal data.

4.3. When processing personal data, the Company adheres to the following principles: legal and fair basis; restriction of personal data processing to achieve specific, predetermined and legitimate purposes; prevention of personal data processing that is incompatible with the purposes of personal data collection; compliance of the content and volume of personal data with the purposes of their processing; processing of personal data that meet the purposes of their processing; ensuring the accuracy, sufficiency and relevance of personal data.

4.4. The Company processes the personal data of the personal data subject for the following purposes:
4.4.1. Creating a personal account on the Website, providing access to the user's personal account on the Website;
4.4.2. Identification of the personal data subject registered on the Website for concluding contracts with BLINGER LLC (ООО "БЛИНГЕР"), including by accepting the offer posted on the Website.
4.4.3. Execution of orders, contracts and other obligations assumed by BLINGER LLC (ООО "БЛИНГЕР").
4.4.4. Providing the subject of personal data with access to personalized Website resources.
4.4.5. Establishing feedback with the subject of personal data, including sending notifications, applications regarding the use of the Website, the provision of services, processing requests and applications from the User.
4.4.6. Determining the location of the personal data subject to ensure security and prevent fraud.
4.4.7. Confirmation of the accuracy and completeness of the personal data provided by the personal data subject.
4.4.8. Informing the subject of personal data about favourable offers, ongoing promotions, as well as other offers of interest to the subject of personal data.
4.4.9. Providing access to the subject of personal data to the websites or services of BLINGER LLC (ООО "БЛИНГЕР") partners in order to obtain products, updates and services.
4.4.10. Providing the subject of personal data with effective customer and technical support in case of problems related to the use of the Website.


5. TERMS OF PERSONAL DATA PROCESSING

5.1. The Company processes personal data only if at least one of the following conditions is met:
  • processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;
  • processing of personal data is necessary to achieve the purposes stipulated by law, to perform and fulfil the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
  • processing of personal data is necessary for the conclusion and (or) execution of a contract to which the subject of personal data is a party;
  • processing of personal data is necessary for the conclusion and execution of contracts with the Company's counterparties;
  • processing of personal data is necessary for the exercise of the rights and legitimate interests of the Company or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated;
  • processing of personal data is carried out, the access of an unlimited number of persons to which is provided by the subject of personal data or at his request;
  • processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
5.2. BLINGER LLC (ООО "БЛИНГЕР") has the right to entrust the processing of personal data of citizens to third parties on the basis of a contract concluded with these persons. Persons who process personal data on behalf of BLINGER LLC (ООО "БЛИНГЕР") undertake to comply with the principles and rules for processing and protecting personal data provided for by Federal Law No. 152-FL "On Personal Data". For each person, a list of actions (operations) with personal data that will be performed by a legal entity that processes personal data, the purposes of processing, the obligation of such a person to maintain confidentiality and ensure the security of personal data during their processing is determined, as well as the requirements for the protection of processed personal data are specified.

5.3. With respect to the User's personal data, their confidentiality is maintained, except in cases where the User voluntarily provides his personal data for general access to an unlimited number of persons.

5.4. In cases established by the legislation of the Russian Federation, BLINGER LLC (ООО "БЛИНГЕР") has the right to provide personal data of citizens.

5.5. The Company may transfer personal data of citizens to third parties in the following cases:
  • obtaining the appropriate consent from the subject of personal data;
  • transfer is necessary for the fulfilment of the Company's contractual obligations to Users;
  • transfer is necessary as part of the User's use of the Company's Website;
  • transfer is necessary for the conclusion of contracts by the Company with third parties and the execution of these contracts.
5.6. The Company, together with the personal data subject, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of personal data.

5.7. In case of loss or disclosure of personal data, the Company informs the subject of personal data about the loss or disclosure of personal data.

5.8. The Company destroys or depersonalizes personal data upon achieving the processing purposes or in case of loss of the need to achieve the processing purpose, unless otherwise provided for by the legislation of the Russian Federation, in case the subject of personal data withdraws consent to the processing of personal data.


6. COOKIES

6.1. For the processing of personal data, the Company may use cookies received from the equipment of the personal data subject, provided that the receipt of cookies is authorized by the subject.

6.2. Cookie is a file used to save Internet browsing settings. During the first visit to the website, this file is downloaded using the browser. The next time you visit this website from the same device, the browser can check for the presence of an associated cookie (i.e. containing the name of the website) and use the data from this cookie to send them back to the website. This allows the website to determine that the website has already been visited from this browser, and in some cases to change the displayed content.

6.3. Cookies are divided into the following categories:
  • necessary for the use of the Website and the use of its functions - these cookies collect information about the use of the Website, in particular, about the most frequently visited pages. Such data can be used to optimize the Website and simplify navigation;
  • operational - collect information about the use of the Website - these cookies are also used by the Company's partners in order to determine the fact of going to the Website from the partner's website, the fact of using the services, buying the Company's products as a result of visiting the Website. These cookies are not used to collect personal information. All information collected with their help is intended for statistical purposes and remains anonymous;
  • functional - they remember the choice made on the Website, the settings for the size and font of the text and other website parameters - these cookies allow the Website to remember the choice made by the user when viewing the website. These files can also be used to remember settings such as size and font of the text, other configurable website parameters, as well as to track recommended products and videos to avoid repetition. The information provided by such cookies does not allow identifying the user
6.4.The Company's websites may use both its own cookies and third-party analytical tools for data collection, such services and systems as: Google Analytics, Yandex.Metrica, Facebook, Vkontakte and others.

6.5. The User can change the way cookies are used, block them or delete them through the settings of the browser used. When using most browsers, the User has the ability to control the use of cookies every time the Website tries to save these files. In case of disabling or deleting cookies, some features of the website may not be available.


7. RIGHTS OF THE PERSONAL DATA SUBJECT

7.1. A citizen whose personal data is processed by the Company has the right:
7.1.1. By sending an official application by mail to the address of the Company, receive from the Company:
  • confirmation of the fact of personal data processing by the Company;
  • legal grounds and purposes of personal data processing;
  • information about the methods of personal data processing used by the Company;
  • full name and location of the Company;
  • information about persons who have access to personal data or to whom personal data may be disclosed on the basis of a contract with the Company or on the basis of the Federal Law;
  • list of processed personal data related to the citizen from whom the application was received and the source of their receipt, unless another procedure for providing such data is provided for by the Federal Law;
  • information about the terms of personal data processing, including the terms of their storage;
  • information on the procedure for the exercise by a citizen of the rights provided for by Federal Law No. 152-FL "On Personal Data";
  • information about the ongoing or proposed cross-border transfer of personal data; the name and address of the person processing personal data on behalf of the Company; other information provided for by Federal Law No. 152-FL "On Personal Data" or other Federal Laws.
7.1.2. To demand clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
7.1.3. To withdraw his consent to the processing of personal data;
7.1.4. To demand the elimination of illegal actions of BLINGER LLC (ООО "БЛИНГЕР") in relation to his personal data;
7.1.5. To protect his rights, freedoms and legitimate interests, including compensation for losses and/or compensation for moral injury in court, as well as other rights provided for by the legislation of the Russian Federation.


8. OBLIGATIONS OF THE PARTIES

8.1. The subject of personal data is obliged:
8.1.1. To provide information about personal data necessary for using the Website, registering on the Website, concluding a contract with the Company;
8.1.2. To update, supplement the provided information about personal data in case of a change in this information.

8.2. The Company is obliged:
8.2.1. To use the information received exclusively for the purposes specified in clause 4 of this Privacy Policy.
8.2.2. To ensure the storage of confidential information in secret, not to disclose without the prior written permission of the personal data subject, as well as not to sell, exchange, publish, or disclose the transferred personal data in other possible ways, except for the cases provided for in clauses 5.3, 5.4, 5.5 of this Privacy Policy.
8.2.3. To block personal data related to the relevant personal data subject from the moment of the application or request of the personal data subject or his legal representative, or the authorized body for the protection of the rights of personal data subjects for the period of verification, in case of identification of false personal data or illegal actions.
8.2.4. When processing personal data, the Company takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data. To prevent unauthorized access to personal data, the Company applies the following organizational and technical measures:
  • restriction of the number of persons who have access to personal data; familiarization of the Company's employees with the Company's local regulations on the processing and protection of personal data;
  • organization of accounting, storage and circulation of information carriers;
  • identification of possible threats to the security of personal data during their processing;
  • development of a personal data protection system based on the available information;
  • differentiation of users' access to information resources and software and hardware means of information processing;
  • using antivirus tools;
  • using, if necessary, means of inter-network shielding, intrusion detection, security analysis and cryptographic protection of information.
8.2.5. Employees of BLINGER LLC (ООО "БЛИНГЕР") who are allowed to process personal data are obliged: to know and strictly comply with the requirements of this Policy; to process personal data only within the framework of performing their official duties; not to disclose personal data obtained as a result of performing their official duties, as well as those that have become known to them by the nature of their activities, except in cases when personal data was provided for access by third parties or at the official application of the authorized state authority of the Russian Federation on the grounds established by the legislation of the Russian Federation; to prevent the actions of third parties that may lead to the disclosure (destruction, distortion) of personal data; if the fact of disclosure (illegal distribution, distortion, destruction) of personal data is revealed, to inform the direct manager about it.

8.3. In case of confirmation of the fact of personal data inaccuracy or illegality of their processing, personal data are subject to their updating by the operator, and processing should be terminated, respectively.

8.4. Employees of BLINGER LLC (ООО "БЛИНГЕР") who are allowed to process personal data are prohibited from unauthorized and unregulated copying of personal data to paper media and to any electronic media that are not intended for storing personal data.


9. LIABILITY OF THE PARTIES

9.1. The Company that has not fulfilled its obligations is liable for the losses incurred by the subject of personal data in connection with the illegal use of personal data, in accordance with the legislation of the Russian Federation.

9.2. In case of loss or disclosure of confidential information, the Company is not responsible if this confidential information:
9.2.1. Became public domain before its loss or disclosure;
9.2.2. Was received from a third party prior to its receipt by the Company;
9.2.3. It was disclosed with the consent of the personal data subject.


10. DISPUTE RESOLUTION

10.1. Before applying to the court with a claim for disputes arising in connection with the application of this Privacy Policy, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute).

10.2. The recipient of the claim within 30 calendar days from the date of the claim receipt notifies the applicant of the claim in writing about the results of the claim consideration.

10.3. If an agreement is not reached, the dispute will be submitted to the court for consideration in accordance with the current legislation of the Russian Federation.

10.4. The legislation of the Russian Federation applies to this Privacy Policy and the relations between the Subject of Personal data and the Company.


11. OTHER PROVISIONS

11.1. The Company has the right to make changes to this Privacy Policy without the consent of the Subject of Personal data.

11.2. The new Privacy Policy comes into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Privacy Policy.

11.3. The current version of the Policy as hard copy is stored at the address of the Company's location.

11.4. The current version of this Policy regarding the processing of personal data is published on the Company's websites.

11.5. All suggestions and questions regarding this Policy can be sent to BLINGER LLC (ООО "БЛИНГЕР") at the following addresses: e-mail contact@hugery.com or postal address 603155, Nizhny Novgorod region, Nizhny Novgorod, Maxim Gorky Street, building 195, hall 40, office 4
11.5.1. The application should contain the necessary and sufficient information to identify the personal data subject, the category of personal data associated with the application, the nature of the application, as well as the signature of the personal data subject or his representative.
11.5.2. The Company considers the application and sends a response to it within 30 days from the date of the specific application receipt.

This Privacy Policy is published on the website https://hugery.com.
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