1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law of 07.27.2006. No. 152-ФЗ
“On Personal Data” and determines the procedure for processing personal data and measures to ensure the security of personal data of 9 PAND LLC (hereinafter referred to as the Operator).

1. The Operator sets as his most important target and condition for the implementation of his activities the observance of the rights and freedoms of individual and citizen when processing his personal data, including protecting the rights to privacy, personal and family secrets.

2. This Operator 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://9pandas.ru.

2. The main concepts used in the Policy

1. Automated processing of personal data - processing of personal data using computer technology;

2. Блокирование персональных данных – временное прекращение обработки персональных данных (за исключением случаев, если обработка необходима для уточнения персональных данных) ;

3. Blocking of personal data - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data) ;

4. Website - a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://9pandas.ru;

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

6. Anonymization of personal data - actions, as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other personal data subject;

7. Processing personal data - any action (operation) or 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), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction of personal data;

8. Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;

9. Personal data - any information relating directly or indirectly to a specific or determined User of the website https://9pandas.ru;

10. User - any visitor to the website https://9pandas.ru;

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

12. Dissemination of personal data - any action aimed at disclosing personal data to an undefined circle of people (transfer of personal data) or familiarizing oneself with personal data of an unlimited circle of people, including disclosing personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way;

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

14. Destruction of personal data - any actions as a result of which personal data is permanently destroyed with the inability to further restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.

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

1. Full Name;

2. Email address;

3. Phone numbers;

4. The site collects and processes anonymous data about visitors as well (including cookies), using Internet statistics services (Yandex Metric, Google Analytics and others).

5. The above data are further incorporated in the text of the Policy by the general concept of Personal Data.

4. Purpose of processing personal data

1. The purpose of processing the User’s personal data is to inform the User by sending emails; filling out an online application for feedback.

2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The user can always refuse to receive informational messages by sending an e-mail to the Operator at the email address policy@9pandas.ru, using a mark: «Refusal to notify of new products and services and special offers».

3. Anonymized user data collected using the Internet statistics services is used to collect information about the actions of users on the site, improve the quality of the site and its content.

5. Legal basis for the processing of personal data

1. The Operator processes the User’s personal data only if it is filled and / or sent by the User independently through special forms located on the site https://9pandas.ru. By filling out the appropriate forms and / or sending your personal data to the Operator, the User acknowledges his acceptance with this Policy.

2. The Operator processes anonymized data about the User if it is allowed in the settings of the User’s browser (the storage of cookies and the use of JavaScript technology are enabled).

3. Anonymized user data collected using the Internet statistics services is used to collect information about the actions of users on the site, improve the quality of the site and its content.

6. The procedure for the collection, storage, transfer and other types of processing of personal data

The security of 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 the current legislation in the field of personal data protection.

1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

2. When a User visits the Site, the Site sends one or more cookies to the user's computer or other device. Cookies are small text files that are usually stored on the User's computer until the end of the session, i.e. until the end of work in the browser, but in some cases beyond as well.

Cookies are used:

• To simplify the use of the Site by the User.

• For analysis for advertising purposes. The Site uses third-party services to track attendance statistics, receive information about conversions on advertising campaigns, and others.

Using these services and tools, the Site does not collect data about specific Users, but uses only general statistics on the traffic and effectiveness of the Site and on the effectiveness of advertising campaigns.

The following is a list of additional third party services that are used on the Site, as well as links to the privacy policies of these services. Google Analytics is Google’s free web analytics service that allows website owners to learn how users interact with their pages. Information is collected in it anonymously.

Google Analytics uses its own cookies to track the actions of Visitors on the site. They allow you to find out if the User visited the web resource earlier, from what resource did he come on the Site and how much time he spent on it. The site uses the Google Analytics remarketing feature. Remarketing in Google Analytics allows you to return users who have previously visited the site using ads specifically designed for them on other sites.

Remarketing uses a third-party cookie from DoubleClick. Using it, the Display Network provides remarketing for products such as AdWords. The user can disable the use of cookies by Google, by visiting the cookie disable page.

To change and disable the use of Google Analytics, the User can also use:

• Google Ads Preferences Manager;

• Google Analytics Blocker.

A description of Google’s advertising services and documentation regarding their use can be found at //www.google.ru/intl/ru/services/, Google’s privacy policy is published at //www.google.ru/intl/ru/policies/terms/regional.html.

Other tools for tracking statistics of attendance and integration into social networks that are used or may be used on the Site:

• Yandex services;

• +1 button;

• Facebook social plugin;

• VK social plugin;

• Twitter widget.

You can block all of the tools above, including Google tools, by installing a Ghostery plug-in (extension) for the browser. The agreement is valid indefinitely from the moment of data submission and may be revoked by You by submitting an application to the Site Administration indicating the data specified in Article 14 of the Law “On Personal Data”.

1. The User’s personal data will never, under any circumstances, be transferred to third parties, with the exception of cases related to the implementation of applicable law.

2. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address policy@9pandas.ru , using the mark: «Updating personal data».

3. The processing time for personal data is unlimited. The User can withdraw his acceptance to the processing of personal data at any time by sending a notification to the Operator’s email address policy@9pandas.ru using the mark «Revocation of acceptance of the processing of personal data».

7. Cross-border transfer of personal data

1. Before starting the cross-border transfer of personal data, the Operator must make sure that the foreign state in whose territory it is supposed to transfer personal data provides reliable protection of the rights of the subjects of personal data.

2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written acceptance of the personal data subject of the cross-border transfer of his personal data and / or the execution of the contract to which the personal data subject is a party.

8. Final provisions

1. The user can get any clarification on questions of interest regarding the processing of his personal data by contacting the Operator via e-mail policy@9pandas.ru.

2. This document will reflect any changes in the policy of processing personal data by the Operator. The policy is valid indefinitely until it is replaced with a new version.

3. The current version of the Policy is freely available on the Internet at https://9pandas.ru/policy.