User Agreement and Privacy Policy of EuroSpace

1. General provisions

1.1. This Agreement establishes the procedure for accessing information materials posted on the Internet that constitute the information resource https://переводмосква.рф (hereinafter referred to as the “Site”) and defines the rights and obligations of persons accessing the Site via the Internet (hereinafter referred to as “Users”).

1.2. The owner of the Site, exercising in full the rights to administer the Site, is Individual entrepreneur Anna Arkadyevna Frolova.

1.3. All relations between the Site Owner and Site Users are governed by the current legislation of the Russian Federation and this Agreement.

1.4. The Site Owner may amend this Agreement at any time. The current version of the Agreement is available online at https://переводмосква.рф/privacy/.

2. Rights of the Site Owner

2.1. The Site Owner holds all exclusive rights to use the Site and, at their discretion, may at any time change the content of the Site, remove and add any materials, permit or restrict access to the Site, and exercise any other rights belonging to them in relation to the Site.

2.2. The Site Owner administers the Site to publish information about the company, its activities, and other information that, in the Site Owner’s opinion, may be useful to Site Users.

3. Site Users

3.1. A Site User is any person accessing the Site via the Internet.

3.2. The rights and obligations of a Site User arise when that person first accesses any of the Site’s materials.

3.3. Site Users are granted free access to the information materials posted on the Site, except for materials whose access must be restricted under the legislation of the Russian Federation. Site Users must refrain from any actions that could damage the Site’s information content, software, or hardware.

4. Legal Status of Information Posted on the Site

4.1. Copyright in the information materials (including, but not limited to, images, photographs, texts, logos, the design of individual Site sections, and the Site as a whole) posted on the Site belongs to the Site Owner and other rights holders whose consent was obtained to post the materials on the Site. Other persons may not use the materials posted on the Site in any way, copy them in whole or in part, distribute, modify, or reproduce them without the prior permission of the Site Owner and/or other rights holders. All rights to information materials, including images (photographs), posted on the Site are protected in accordance with national and international law (Chapter 70 of the Civil Code of the Russian Federation, the Universal Copyright Convention, the Berne Convention for the Protection of Literary and Artistic Works, and other regulations governing copyright protection). When using any information materials and images (photographs) from the Site on the Internet, it is mandatory to indicate the source of the materials—the Site—and include an active hyperlink to the Site in the form of https://переводмосква.рф.

4.2. Site Users may freely review information materials available on the Site in the public domain. Access to materials located on the Site is provided free of charge.

4.3. The Site may contain information about the services of the Site Owner, as well as information directly about the seller or person providing services, etc.

5. Liability of the Parties

5.1. The Site Owner shall not be liable for losses incurred by Site Users due to technical failures of hardware or software, or for losses resulting from actions of Site Users. The Site Owner bears no financial or legal liability for losses incurred by Site Users or third parties as a result of Site Users’ use of any information materials and recommendations posted on the Site. By using the Site’s materials, you agree that you bear all financial and legal risks yourself.

5.2. The Site Owner shall not be liable and shall have no direct or indirect obligations to the User in connection with any losses incurred in relation to the Site’s content, copyright registration and information about such registration, products or services available on the Site or obtained through external websites or other contacts entered into by the User using information or links posted on the Site.

5.3. A Site User’s violation of the terms of this Agreement may constitute grounds for the temporary or complete denial of the User’s access to the Site, as decided by the Site Owner. A Site User’s infringement of the Site Owner’s copyrights constitutes grounds for holding the Site User liable as provided by law (Articles 1252, 1301 of the Civil Code of the Russian Federation, Article 146 of the Criminal Code of the Russian Federation, Article 7.12 of the Code of Administrative Offenses of the Russian Federation, and other provisions of Russian law).

6. Personal Data Processing Policy

6.1. General provisions

This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 27.07.2006-FZ dated 152- “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Individual entrepreneur Anna Arkadyevna Frolova (hereinafter referred to as the “Operator”).

6.1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens when processing their personal data, including protecting the rights to privacy and personal and family secrets, to be its most important objective and condition of operation.

6.1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the website https://переводмосква.рф.

6.2. Key Terms Used in the Policy

6.2.1. Automated processing of personal data means the processing of personal data using computer technology.

6.2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where processing is necessary to clarify the personal data.

6.2.3. Website means a collection of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://переводмосква.рф.

6.2.4. Personal data information system means a set of personal data contained in databases, and information technologies and technical means ensuring their processing.

6.2.5. Anonymization of personal data means actions that make it impossible to determine, without using additional information, the identity of the personal data to a specific User or other personal data subject.

6.2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

6.2.7. Operator means a state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or processes personal data, and determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed on personal data.

6.2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://переводмосква.рф.

6.2.9. Personal data permitted by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by consenting to the processing of personal data permitted by the personal data subject for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for distribution”).

6.2.10. User means any visitor to the website https://переводмосква.рф.

6.2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

6.2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transferring personal data) or making personal data available to an unlimited number of persons, including publishing personal data in mass media, posting it on information and telecommunications networks, or providing access to personal data in any other manner.

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

6.2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed, making it impossible to further restore its contents in the personal data information system, and/or the physical media containing the personal data are destroyed.

6.3. Key Rights and Obligations of the Operator

6.3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the personal data subject;
• if the personal data subject withdraws consent to the processing of personal data, continue processing personal data without the subject’s consent where grounds specified in the Personal Data Law exist;
• independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

6.3.2. The Operator is obliged to:

• provide the personal data subject, at their request, with information concerning the processing of their personal data;
• organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the authorized body for protecting the rights of personal data subjects, at its request, with the necessary information within 30 days from the date of receipt of such request;
• publish this Personal Data Processing Policy or otherwise ensure unlimited access to it;
• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions involving personal data;
• cease the transfer (distribution, provision, access) and processing of personal data and destroy personal data in the manner and cases provided for by the Personal Data Law;
• perform other obligations stipulated by the Personal Data Law.

6.4. Key Rights and Obligations of Personal Data Subjects

6.4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and procedure for obtaining it are established by the Personal Data Law;
• require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and take measures provided by law to protect their rights;
• make prior consent a condition for processing personal data for the purpose of promoting goods, works, and services on the market;
• to withdraw consent to the processing of personal data;
• to appeal, before the authorized body responsible for protecting the rights of personal data subjects or through the courts, against unlawful actions or inaction by the Operator in processing their personal data;
• to exercise other rights provided for by the laws of the Russian Federation.

6.4.2. Personal data subjects are required to:

• provide the Operator with accurate information about themselves;
• notify the Operator of any clarification (update or change) of their personal data.

6.4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, shall be liable in accordance with the laws of the Russian Federation.

6.5. The Operator may process the following personal data of the User

6.5.1. Last name, first name, patronymic.

6.5.2. Email address and postal address for order delivery.

6.5.3. Telephone numbers and payment details.

6.5.4. Year, month, and date of birth.

6.5.5. The website also collects and processes anonymized visitor data (including cookie files) using web analytics services (Yandex Metrica, Google Analytics, and others).

6.5.6. The above data are hereinafter collectively referred to in this Policy as Personal Data.

6.5.7. The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.

6.5.8. Processing personal data permitted for dissemination from among the special categories of personal data specified in Part 1 Article 10 of the Personal Data Law is permitted provided that the prohibitions and conditions set forth in Article 10.1 of the Personal Data Law are observed.

6.5.9. The User’s consent to the processing of personal data permitted for dissemination is оформed separately from other consents to the processing of their personal data. The conditions provided for, in particular, by Article 10.1 of the Personal Data Law shall be observed. Requirements for the content of such consent are established by the authorized body responsible for protecting the rights of personal data subjects.

6.5.9.1 The User provides the Operator directly with consent to the processing of personal data permitted for dissemination.

6.5.9.2 The Operator must, no later than three business days after receiving the User’s consent, publish information about the processing conditions and about any prohibitions and conditions on the processing of personal data permitted for dissemination by an unlimited number of persons.

6.5.9.3 The transfer (dissemination, provision, or access) of personal data permitted for dissemination by the personal data subject must be terminated at any time at the request of the personal data subject. This request must include the personal data subject’s last name, first name, and patronymic (if applicable), contact information (telephone number, email address, or postal address), as well as a list of the personal data whose processing must be terminated. The personal data specified in this request may be processed only by the Operator to whom the request was sent.

6.5.9.4 Consent to the processing of personal data permitted for dissemination ceases to be effective when the Operator receives the request specified in Clause 6.5.9.3 of this Personal Data Processing Policy.

6.6. Principles of personal data processing

6.6.1. Personal data are processed lawfully and fairly.

6.6.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Personal data may not be processed in a manner incompatible with the purposes for which they were collected.

6.6.3. Databases containing personal data may not be combined if the data are processed for purposes that are incompatible with one another.

6.6.4. Only personal data that meet the purposes of their processing may be processed.

6.6.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.

6.6.6. When processing personal data, their accuracy and sufficiency, and, where necessary, their relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that measures are taken to delete or clarify incomplete or inaccurate data.

6.6.7. Personal data are stored in a form that makes it possible to identify the personal data subject, and no longer than required by the purposes of processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. The personal data processed are destroyed or anonymized once the purposes of processing have been achieved or when the need to achieve those purposes no longer exists, unless otherwise provided by federal law.

6.7. Purposes of personal data processing

6.7.1. Purpose of processing the User’s personal data:

• informing the User by sending emails;
• entering into, performing, and terminating civil-law contracts;
• providing the User with access to the services, information, and/or materials contained on the website https://переводмосква.рф.

6.7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may unsubscribe from informational messages at any time by sending the Operator an email info@perevod-ekb.ru with the subject line “Unsubscribe from notifications about new products, services, and special offers.”

6.7.3. Anonymized User data collected through web analytics services are used to gather information about Users’ actions on the website and to improve the quality of the website and its content.

6.8. Legal grounds for processing personal data

6.8.1. The legal grounds for the Operator’s processing of personal data are:

• contracts concluded between the Operator and the personal data subject;
• federal laws and other regulatory legal acts governing the protection of personal data;
• Users’ consents to the processing of their personal data and to the processing of personal data permitted for dissemination.

6.8.2. The Operator processes the User’s personal data only if the User enters and/or submits it independently through special forms located on the website https://переводмосква.рф or sends it to the Operator by email. By completing the relevant forms and/or sending their personal data to the Operator, the User expresses consent to this Policy.

6.8.3. The Operator processes anonymized User data if this is permitted by the User’s browser settings (cookie storage and JavaScript enabled).

6.8.4. The personal data subject independently decides whether to provide their personal data and gives consent freely, of their own accord, and in their own interest.

6.9. Conditions for processing personal data

6.9.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.

6.9.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.

6.9.3. Personal data processing is necessary for the administration of justice, the enforcement of a judicial act, or the enforcement of an act issued by another body or official that is subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.

6.9.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

6.9.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.

6.9.6. Personal data are processed when access to them has been provided by the personal data subject to an unlimited number of persons or at their request (hereinafter, publicly available personal data).

6.9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.

6.10. Procedure for collecting, storing, transferring, and otherwise processing personal data

The security of the personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable personal data protection legislation.

6.10.1. The Operator ensures the preservation of personal data and takes all possible measures to prevent unauthorized persons from accessing them.

6.10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where required to comply with applicable law or where the personal data subject has consented to the Operator transferring the data to a third party to fulfill obligations under a civil-law contract.

6.10.3. If inaccuracies are found in the personal data, the User may update them independently by sending a notification to the Operator’s email address info@perevod-ekb.ru with the subject line “Personal Data Update.”

6.10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by email to the Operator’s email address info@perevod-ekb.ru with the subject line “Withdrawal of Consent to the Processing of Personal Data.”

6.10.5. All information collected by third-party services, including payment systems, communications providers, and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and promptly review these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

6.10.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply when personal data are processed in state, public, or other public interests defined by the legislation of the Russian Federation.

6.10.7. When processing personal data, the Operator ensures their confidentiality.

6.10.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject, and no longer than required by the purposes of processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.

6.10.9. Processing of personal data may be terminated when the purposes of processing have been achieved, the personal data subject’s consent expires or is withdrawn, or unlawful processing of personal data is discovered.

6.11. List of actions performed by the Operator with the personal data received

6.11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates or changes), retrieves, uses, transfers (disseminates, provides, or grants access to), anonymizes, blocks, deletes, and destroys personal data.

6.11.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained via information and telecommunications networks.

6.12. Cross-border transfer of personal data

6.12.1. Before initiating a cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data are to be transferred provides reliable protection of the rights of personal data subjects.

6.12.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements may be carried out only if the personal data subject has provided written consent to the cross-border transfer of their personal data and/or if necessary to perform a contract to which the personal data subject is a party.

6.13. Confidentiality of personal data

The Operator and other persons who have access to personal data must not disclose them to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.

6.14. Final provisions

6.14.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator by email info@perevod-ekb.ru.

6.14.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.