Privacy Policy

This Personal Data Processing Policy (hereinafter – the Policy) of Primer CSS (hereinafter – the Operator) is an official document that defines the general principles, purposes and procedure for processing personal data of users of the website (hereinafter – the Site), as well as information on the personal data protection measures implemented.

This Policy applies exclusively to the Site. The Operator does not control and is not responsible for third party websites, to which the User can access via links available on the Site. Processing of personal data of other categories of personal data subjects by the Operator is regulated by other local acts of the Operator.

This Policy shall come into effect from the moment of its approval and shall remain in force indefinitely until it is replaced by a new Policy.

Procedure and conditions of personal data processing

The basis for processing of personal data of the Website users is consent to processing of personal data. Users of the Site give their consent to the processing of their personal data in the following cases:

• when registering on the Site in the personal account;
• when filling in the feedback form.

In case the User does not agree with the terms of this Policy, the use of the Site and/or any Services available through the use of the Site shall be immediately terminated.

Personal data of the Website Users shall be processed for the following purposes:

• registration and access to a personal account on the Site;
• establishing feedback with the Site user, including sending notifications, requests and their processing, as well as processing requests and applications from the user for the purpose of further conclusion and execution of the contract;
• keeping statistics and analyzing the Website operation.

The list of personal data of users processed on the Site using means of automation for the purposes of registration and providing access to the personal account:

• surname, first name, patronymic;
• telephone number;
• e-mail address.

The list of personal data of users processed on the Website using means of automation for the purposes of establishing feedback with the user of the Website, including sending notifications, requests and their processing, as well as processing requests and applications from the user for the purposes of further conclusion and execution of the contract:

• surname, first name, patronymic;
• telephone number;
• e-mail address.

The Operator does not check the reliability of the information provided by the User and assumes that the User provides reliable and sufficient information, controls its relevance.

The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction.

Personal data shall be stored in a form that allows to identify the subject of personal data for no longer than required by the purposes of personal data processing.

The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the term of personal data processing, revocation of the consent of the Website user to the processing of his/her personal data, as well as detection of unlawful processing of personal data.

Measures to ensure the security of personal data

Security of personal data processed by the Operator is ensured by implementation of legal, organizational, technical and software measures necessary and sufficient to ensure the requirements of the legislation.

The Operator takes the following measures to ensure personal data security:

• appointment of responsible persons for organization of processing and ensuring protection of personal data;
• limiting the number of the Operator’s employees having access to personal data;
• determining the level of protection of personal data during processing in personal data information systems;
• establishment of rules for differentiating access to personal data processed in personal data information systems and ensuring registration and accounting of all actions performed with personal data;
• restricting access to the premises where the main technical means and systems of personal data information systems are located and where non-automated processing of personal data is performed;
• keeping records of machine carriers of personal data;
• organization of backup and recovery of personal data information systems and personal data modified or destroyed due to unauthorized access to them;
• establishing requirements to the complexity of passwords for access to personal data information systems;

• implementation of anti-virus control, prevention of introduction of malicious programs (virus programs) and program tabs into the corporate network;
• organization of timely updating of the software used in the information systems of personal data and information protection means;
• regular assessment of the effectiveness of measures taken to ensure personal data security;
• detecting the facts of unauthorized access to personal data and taking measures to identify the causes and eliminate possible consequences;
• control over the measures taken to ensure personal data security and security levels of personal data information systems.

Rights of site users

The Site user has the right to receive information regarding the processing of his/her personal data, including information containing:

• confirmation of the fact of personal data processing by the Operator;
• legal grounds and purposes of personal data processing;
• the purposes and methods of personal data processing applied by the Operator;
• name and location of the Operator, information about persons (except for the Operator’s employees) who have access to personal data or to whom personal data may be disclosed on the basis of a contract with the Operator or on the basis of federal law;
• personal data being processed relating to the respective personal data subject, the source of their obtaining, unless another procedure for submission of such data is provided for by the federal law;
• the terms of personal data processing, including the terms of their storage;
• the procedure for exercising by the subject of personal data the rights provided for by the Federal Law “On Personal Data”;
• information on the realized or supposed trans-border transfer of personal data;
• name or surname, first name, patronymic and address of the person processing personal data on behalf of the Operator, if the processing is or will be entrusted to such a person;
• other information provided for by the Federal Law “On Personal Data” or other federal laws.

The Website user has the right to demand from the Operator to clarify his personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his rights.

Liability

The User is fully responsible for compliance with the requirements of applicable laws, including, but not limited to, laws on advertising, copyright and related rights protection, protection of trademarks and service marks, including full responsibility for the content and form of materials, in case of quoting and other use of information obtained in connection with the use of the Site services.

Final terms

This privacy policy is effective upon posting on our website or mobile application. The Company reserves the right to modify and amend this privacy policy at its sole discretion. Changes will be effective upon posting on our website or mobile application.

If you have any questions or comments regarding our privacy policy, please contact us at the following e-mail address: [email protected].