GİZLİLİK POLİTİKASI

PRIVACY POLICY

This document represents the Privacy Policy of Opti Group Limited Liability Company (OOO) (OGRN: 1207800135135) (hereinafter referred to as the Company).

This Policy applies to all personal data/personal information of the site User.

This policy has been developed, inter alia, following Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the law on personal data).

GENERAL DEFINITIONS

The Company – the owner of the site, managing a specialized electronic service on the Internet, which is the personal data processor, independently or jointly with other persons organizing and (or) carrying out the processing of 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.

The Buyer – an individual entrepreneur/legal entity that has the intention to purchase goods.

A Personal Account – a personal section of the site that the User gets access to after completing the registration and/or authorization on the site. A Personal Account is designed to store the User's personal information, view and manage the available functionality of the Service, Users' interact with each other and with the Company, and receive notifications.

The Site User (hereinafter referred to as – the User) is a Buyer and/or Supplier who has entered the User Agreement with the Company.

The Site Visitor (hereinafter referred to as – the Visitor) is an Internet user who has visited the site for a certain period and is on the site without the registration and/or authorization procedure.

The Supplier – an individual entrepreneur/legal entity engaged in the sale of goods using a remote method and offering the Client to conclude for the purchase and sale contract of goods.

A Site – an Internet resource that includes documents (web pages) combined with links and a common structure, available at http://optymarket.com (including all domain levels).

A Service – the site and the content posted on it with certain functionality, to which Users are granted access using the Company's software and hardware integrated with the site.

Personal information – any information that the User provides about himself/herself during registration or authorization, as well as in the process of further use of the Service, data that is transmitted automatically depending on the settings of the User's software in an impersonal form.

Personal data – any information related to the User's representative – an individual, which the User's representative – an individual provides about himself/herself independently during registration or authorization, as well as in the process of further use of the Service, data that is transmitted automatically depending on the software settings of the User's representative – an individual in an impersonal form.

User content – personal data and/or personal information, as well as any informational materials, including text, graphics, audio-visual, and other materials posted by the User).

Cookies – text files placed on the hard drives of the Visitor's/User's devices during the use of various sites, designed to assist in configuring the user interface following the preferences of the Visitor/User, allowing the site to remember the Visitor's/User's device, remember the preferences of the Visitor/User, select the most appropriate advertising for the Visitor/User.

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

Personal data automated processing – the processing of personal data using computer technology.

Dissemination of personal data – actions aimed at disclosing personal data to general public.

Provision of personal data – actions aimed at disclosing personal data to a certain person or a particular number of persons.

Blocking of personal data – temporary termination of personal data processing (except in cases where the processing is necessary to clarify personal data).

Destruction of personal data – actions that make it 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.

Anonymization of personal data – actions that make it impossible to determine the identity of personal data to a specific personal data subject without using additional information.

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

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

PERSONAL INFORMATION AND PERSONAL DATA

The Company has the right to set requirements for the composition of personal information/personal data of the User, which must be provided for the use of the site, as well as for user content. If certain information is not marked as mandatory by the Company, its provision or disclosure is at the User's discretion.

To access the functionality of the service, the User registers on the site using the name of the User's representative, the mobile phone number of the User's representative, and the email address. After registration, the User gets to a Personal Account.

At the same time, the User assures and guarantees that he/she has obtained consent from the User's representative – an individual for the processing of their personal data (full name, mobile phone number and/or email address) by the Company.

By providing the personal information and/or personal data specified in this section, as well as other information, documents, information following the terms of the User Agreement, the User gives informed consent to access it to the general public. This information becomes public data from the moment it is posted on the Site.

The Company does not verify the accuracy of the personal data provided and whether the User has the necessary consent to their processing in accordance with this Policy, relying on the User's assurances, as well as on the fact that the User acts in good faith, prudently and makes all necessary efforts to keep personal information and/or personal data up to date and obtain all necessary consents of personal data subjects.

The Company has the right to perform a random verification of the personal information provided by the User. The Company has the right, if desired, on the part of the Supplier, to verify the Supplier, the Company moderates information about products, User requests.

The Company processes personal information and/or personal data of the User only if they are filled in and/or sent by the User through special forms located on the site. By filling out the relevant forms and/or sending your personal information and/or personal data to the Company when creating your personal account, the User agrees to this Policy.

The Company processes non-personal information about the User in the case that it is permitted in the User's browser settings.

The User has the right at any time to independently edit the personal information and/or personal data provided by him/her during registration or authorization in his/her personal account. The User is solely responsible for reporting false information about himself/herself for untimely editing of information, as well as for possible legal consequences that may occur as a result of the User's reporting of false information/untimely editing of information.

The Company is not responsible for the use of personal information and/or personal data of the User by third parties with whom the User interacts independently within the framework of using the Service.

The Visitor/User is notified and agrees that in the process of using the Service/Company's website automatically transmits the following information about the Visitor/User: the IP address of the device, information about the location of the device, technical information about the device, information about the application or browser that uses the Service/site, information from Cookies, information about the time of use of the Service/site. The listed information is depersonalized and not used to establish the identity of the Visitor/User. The Company processes non-personal information about the Visitor/User in the case that it is permitted in the Visitor's/User's browser/application settings.

PURPOSES OF COLLECTING AND PROCESSING PERSONAL INFORMATION/PERSONAL DATA

Personal data and personal information are collected and processed by the Company for the purpose of executing the User Agreement (providing access to the functionality of the service in accordance with the selected tariff for the purpose of searching for counterparties) concluded between the Company and the User.

The User agrees that personal data and personal information are collected and processed by the Company also for:

- conclusion and execution of other contracts concluded between the User and the Company;

- identification of the User in the framework of the fulfillment of obligations under the User Agreement and other Contracts concluded with him/her. The User's personal account is associated with the User's login-password and email address and/or mobile phone number;

- fulfillment of obligations under the User Agreement and other concluded contract, including providing the User with access to the Service and technical support;

- issuing invoices and certificates;

- sending system notifications to the User, notifications about new products and services, promotions, special offers, and various events, notifications about restricted access to the personal account, service alerts, news, and offers of an advertising and marketing nature. The User can manage the receipt of news and marketing offers in the settings of the personal account;

- ensuring the security and confidentiality of personal information and/or personal data of the User. To check suspicious activities on the Site, information is collected about the IP address and browser used by the User to visit the Site.

- conducting marketing, statistical and other research based on depersonalized data to improve the quality of the provided Service . Data from Google Analytics, Yandex.Metrika, and Roistat are collected and analyzed anonymously to find out how much time Users spend on various pages of the Site, their interests and preferences.

The Company does not sell or provide personal information and/or personal data of Users to third parties for marketing purposes not provided for in this Policy and the User Agreement, without the express consent of Users. The Company may combine depersonalized data with other information received from third parties and use it to improve and personalize services, content, and advertising.

PRINCIPLES OF PROCESSING AND MEASURES FOR THE PROTECTION OF PERSONAL INFORMATION/PERSONAL DATA

The Company processes personal data following the principles established by Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”. The personal data subject has the rights established by Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".

The Company determines current threats to the security of the User's personal data during their processing and develops measures to eliminate them, carries out internal control and audit in the field of personal data protection.

Responsible persons of the Company are familiar with the Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”, this Policy and local acts of the Company on personal data security.

When carrying out cross-border transfer of personal data, the Company is guided by the requirements of Article 12 of the Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”.

Recording, systematization, accumulation, storage, clarification (updating, changing), extraction of personal data of Visitors/Users are carried out using databases located on the territory of the Russian Federation.

COOKIE USING POLICY

The Company uses:

Session cookies. Such files are used by the Company to collect information about how the Visitor/User interacts with the content on the site to create reports and improve the site, as well as to offer personalized products and content. Cookies collect information in an anonymous form.

The registration cookie. Such files are used by the Company to store and verify the authenticity of data about the User's login to the site.

Cookie activity file. Such files are used by the Company to collect information about the frequency and frequency of User visits, and to develop new functionality of the service.

The Company uses cookies to collect statistics about Visitors/Users: the number of users, the type of technology used, and the number of Users, ; about which pages of the site were viewed by Visitors/Users, how Visitors/Users got to the site, which helps the Company to constantly improve the service and contributes to the advertising and marketing activities of the Company.

The site allows third parties to upload cookies to the Visitor's/User's device. These third-party cookies are not under the control of the Company.

The Visitor/User can control the use of cookies in the Visitor's/User's browser settings.

If the Visitor/User will disable some cookies that the Company uses, and the functionality of the service may be limited.

FINAL PROVISIONS

To prevent the leakage of personal information and/or personal data, the Company advises Users to clarify the purpose of using their personal information and/or personal data before providing them to others, as well as to clarify all the essential terms of the contract with other Users, to act in good faith and reasonably; not to use Users' contact data for purposes that do not correspond to the purpose of searching for counterparties in the field of purchase and sale of goods, including for providing any commercial, marketing, and other offers; do not use the functionality of the site or the information posted on the site for purposes not provided for in this Policy and/or the User Agreement; do not process (including not collecting, extracting, recording, organizing, using, transmitting, distributing, copying, reproducing or performing any other actions) user content for purposes that do not correspond to the purposes of searching for counterparties using the functionality of the service; do not use programs to collect information on the site or otherwise interact with the site without the Company's permission; do not post, send or otherwise use information and statements that do not comply with current legislation, moral norms and business practices; do not download, store, distribute or otherwise use viruses and other malicious programs on the site.

Any implicative action, including registering on the site; and/or a User clicking a button, which shows awareness, acceptance, and adoption of the terms of service and the Privacy Policy confirm your full and unconditional consent with the terms of this Policy, the User's acceptance of this Policy and the acceptance of the terms of this Policy from now on.

When registering a User on the site, the User's representative – an individual in accordance with Article 9 of the Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” gives the Company (Opti Group LLC (OOO) OGRN: 1207800135135, St. Petersburg, Aptekarskaya nab., 20, BC “AVENUE”) decides to provide his/her personal data to the Company and gives freely, by his/her will and in his/her own interest to the Company consent to the processing of all personal data provided by the User's representative in the amount and under the conditions set out in this Policy, and allows the Company to perform actions (operations) with the personal data of the User's representative as defined in Article 3 of Federal Law No. 152-FZ dated 27.07.2006, including without limitation: collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data, cross-border data transfer, as well as performing any other actions with personal data following the current legislation. The User's representative also authorizes the exchange (reception, transfer, processing) of his/her personal data between the Company and third parties following the concluded contracts and agreements, to comply with the legal rights and interests of the User's representative. The consent of the User's representative to the processing of personal data is valid indefinitely from the date of registration of the User on the site. Revocation of this consent is carried out by sending a written application to the Company (by mail or e-mail).

A list of personal data that the User's representative agrees to process and can provide to the Company: surname, first name, patronymic, phone number, email address, IP address, and any other information provided to the Operator relating to the personal data of the User's representative.

The Company will terminate the processing of personal data/personal information in the event of withdrawal of consent to the processing of personal data of personal data subject, when the purposes of processing or in case of loss necessary to achieve these goals, as well as in other cases stipulated by the current legislation.

This Policy is an integral part of the User agreement posted and/or available on the Internet at http://optymarket.com as well as other Contracts concluded with the User.

The Company has the right to unilaterally amend the terms of this Policy. Information about changes to this Policy is communicated to the User either by posting on the site or in the User's personal account by sending a corresponding notification two weeks before the upcoming change. By continuing to use the site after the change of this Policy, the User agrees to the changes made to the Policy.

The User undertakes to visit the page on which this Policy is posted periodically http://optymarket.com.

If the User does not agree with the terms of this Policy set out in this document and the User Agreement, the User must immediately stop using the Site.

This Policy is regulated by the current legislation of the Russian Federation, comes into force for the User from the moment of its acceptance by the User, and is valid for an indefinite period.

Revised on December 11, 2020.