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Privacy Policy for Personal Data (Notice)

This Privacy Policy (hereinafter referred to as the "Policy") applies to all personal data that the Softline Group of Companies (hereinafter referred to as "Softline") may receive from a user during the user's use of the Softline website – www.softline.ru (hereinafter referred to as the "Website"), Internet services, services, purchasing goods, participating in advertising and marketing campaigns or promotions and/or any other interaction with Softline (hereinafter referred to as "Services").

This Policy is mandatory for review and compliance by all persons granted access to process personal data at Softline and persons participating in organizing data processing processes and ensuring personal data security at Softline.

Key terms used in this Policy:

  • personal data – any information relating to an identified or identifiable natural person (data subject);
  • personal data operator (operator) – a person who independently or jointly with others organizes and/or carries out processing of personal data, and also determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data (Softline);
  • processing of personal data – any action (operation) or combination of actions (operations) with personal data performed using or without using automation tools. Processing of personal data includes, inter alia: collection; recording; systematization; accumulation; storage; clarification (updating, modification); retrieval; use; transfer (distribution, provision, access); anonymization; blocking; deletion; destruction;
  • automated processing of personal data – processing of personal data using computing equipment;
  • disclosure of personal data – actions aimed at revealing personal data to a specific person or group of persons;
  • blocking of personal data – temporary suspension of processing personal data (except cases where processing is necessary to clarify personal data);
  • destruction of personal data – actions as a result of which it becomes 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 as a result of which it becomes impossible to determine the attribution of personal data to a specific data subject without using additional information;
  • personal data information system – a combination of personal data contained in databases and information technologies and technical means ensuring their processing;
  • cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, foreign natural person or foreign legal entity.

This Policy applies to all processes of collecting, recording, systematizing, accumulating, storing, clarifying (updating, modifying), retrieving, using, transferring (providing, accessing), blocking, deleting, destroying personal data carried out using automation tools.

Softline processes personal data in compliance with the principles and rules established by the Federal Law of the Russian Federation No. 152-FZ dated June 27, 2006 "On Personal Data".

Softline does not control and is not responsible for third-party websites to which a user may navigate using links available on the Softline website. Third-party websites may have their own privacy policies and other personal data may be collected from or requested from the user.

This Policy explains how Softline processes and protects personal data and other user information.

By using the Services and providing Softline with information necessary to initiate further interaction, you consent to its use in accordance with this Policy.

For specific Services, Softline may publish additional provisions supplementing this Policy.

This Policy shall be updated in case of changes to the Russian Federation legislation on personal data.

1. User personal data collected and processed by Softline

1.1. For the purposes of this Policy, "user personal data" means:

1.1.1. Personal data that the user provides about themselves independently when registering (creating an account) on the Website or during the use of Services. Information mandatory for provision (rendering) of Services is clearly marked.

1.1.2. For unregistered Website users – persons making purchases on the website without registration, such information includes: surname, first name, patronymic, date of birth, delivery address; contact phone, company information, position, email address, country, city, region of residence, bank card information (card mask, card type and subtype, year and month of card expiry).

1.1.3. For registered Website users – persons who have successfully completed registration on the Website, such information includes: surname, first name, patronymic, contact phone, mobile phone number, delivery address, company information, position, email address, country, city, region of residence, bank card information (card mask, card type and subtype, year and month of card expiry).

1.1.4. For clients/partners – persons in contractual relationships with Softline, such information includes: surname, first name, patronymic, position in the company with company name, email address, contact phone number.

1.1.5. For job applicants – persons seeking employment, such information includes: surname, first name, patronymic, date of birth, residential address, home phone number, work phone number, mobile phone number, email address, marital status information, children information, education/certification information (study period, educational institution, faculty/specialization, degree received, form of study), certificate information, work experience and tenure information (work period, organization, organization's field of activity, position, main responsibilities), software and programming language knowledge information, foreign language knowledge information, professional qualities information, personal qualities information, city of residence, desired position information, work schedule information, expected compensation level and form information, hobbies information.

1.1.6. Other user information, collection and/or provision of which is determined by Softline for providing specific Services additionally, as clearly indicated when ordering specific Services.

1.2. User personal data provided to Softline is considered unreliable and may be blocked until Softline receives consent from the user or their legal representative for processing user personal data in any additional form designated by Softline, beyond that provided on the Website.

1.3. Softline does not make decisions based solely on automated processing of personal data that produce legal effects regarding users or otherwise affect their rights and legitimate interests.

2. Purpose of processing user personal data

2.1. Softline processes only personal data necessary for providing and improving the quality of Services.

2.2. Softline may use user personal data to achieve the following purpose: fulfillment of Softline's obligations under orders, contracts and other obligations accepted by Softline as mandatory for fulfillment before the user. Within the scope of this purpose, Softline implements a complex of actions aimed at performing the following tasks:

2.2.1. Identification of a party within the scope of providing Services.

2.2.2. Providing the user with personalized Services.

2.2.3. Improving the quality of Services and developing new ones.

2.2.4. Conducting statistical and other research based on anonymized data.

2.2.5. Providing user personal data to software rights holders, distributors or resellers for software registration in the name of the user or organization represented by the user.

2.2.6. Providing Website users with safe and convenient functionality for its use, effective display of information.

2.2.7. Effective fulfillment of orders, contracts and other obligations accepted by Softline as mandatory for fulfillment before the user.

2.2.8. Processing user questions.

2.2.9. Registering Website users for events.

2.2.10. Registering Softline clients/partners in the service desk system for subsequent technical support.

2.2.11. Collecting resumes and selecting candidates for vacant positions at Softline.

2.2.12. Performing and/or fulfilling functions, powers and duties imposed by Russian Federation legislation on Softline.

2.2.13. Collecting data for marketing purposes (for contacts using email or phone to offer services, newsletters or event registration).

3. Legal grounds for processing personal data:

  • Articles 23, 24 of the Russian Federation Constitution.
  • Article 90 of the Labor Code of the Russian Federation.
  • Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data".
  • Softline's charter and founding documents.
  • User consent to processing of personal data.
  • Softline's internal regulatory and administrative documents.

4. Transfer of user personal data to third parties

4.1. Confidentiality is maintained regarding user personal data, except for cases of processing personal data to which access by an unlimited circle of persons is provided by the user, or at their request.

4.2. Softline may transfer user personal data to third parties in the following cases:

4.2.1. The user has provided their consent for such actions, including for software registration in the user's name by software rights holders, distributors or resellers, or for product delivery.

4.2.2. Transfer is necessary to achieve the purpose, to carry out and fulfill functions, powers and duties imposed by Russian Federation legislation on Softline.

4.3. To fulfill obligations under orders, contracts and other obligations to the user, Softline may carry out cross-border transfer of personal data to territories of foreign states.

4.4. Types of data transfer and their recipients: organizations processing data on behalf of Softline (for technical, marketing support and software support), if necessary – independent third parties (auditors, lawyers, regulatory authorities) or recipients to whom data transfer is based on actions and decisions taken by the user (for example, when the user has chosen delivery to their address using a third party).

5. Measures applied to protect user personal data

5.1. To ensure compliance with the obligations provided for by the Federal Law of the Russian Federation No. 152-FZ dated June 27, 2006 "On Personal Data" and the regulatory legal acts adopted in accordance therewith, Softline has taken the following measures to protect user personal data:

5.1.1. A person responsible for organizing processing of personal data has been appointed.

5.1.2. Local acts on processing and ensuring personal data security have been issued, as well as local acts establishing procedures aimed at preventing and detecting violations of Russian Federation legislation and eliminating the consequences of such violations.

5.1.3. Legal, organizational and technical measures for ensuring personal data security have been applied.

5.1.4. Rules for access to personal data processed in personal data information systems have been established.

5.1.5. Registration and accounting of all actions performed with personal data in personal data information systems is carried out.

5.1.6. Rules for backup and recovery of information and personal data have been established.

6. User rights and obligations

6.1. Softline takes reasonable measures to maintain the accuracy and relevance of personal data held by Softline, as well as deletion of outdated and other unreliable or excessive personal data. However, the User is responsible for providing accurate information, as well as updating provided data in case of any changes.

6.2. The User may at any time change (update, supplement) the personal data provided by them or part thereof, as well as their confidentiality parameters by contacting Softline.

6.3. The User has the right at any time to withdraw consent to processing of personal data by Softline by sending a written notice to the address: 115114, Moscow, Derbenevskaya Embankment, 7, business quarter "Novospassky", bldg. 8, to PAO "Softline" marked "withdrawal of consent to processing of personal data", provided that withdrawal by the user of consent to processing of personal data results in deletion of the user's account from the Website, as well as destruction of records containing personal data in Softline's personal data processing systems, which may make it impossible to use Softline's Internet services.

6.4. The User has the right to request destruction of their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing.

6.5. The User has the right to obtain information regarding processing of their personal data by Softline, and may send a written request to the address: 115114, Moscow, Derbenevskaya Embankment, 7, business quarter "Novospassky", bldg. 8, to PAO "Softline" marked "request for information on personal data processing procedures".

6.6. Right to withdraw consent: the user has the opportunity at any time to stop subscribing to Softline's marketing communications by clicking on the corresponding link present in all Softline marketing communications, the user has the opportunity to change their cookie file settings or contact Softline in accordance with the contact information provided in Section 7 of this Policy.

6.7. To implement the provisions of paragraphs 6.2, 6.3, 6.4, 6.5 and 6.6 of this Policy, Softline may require verification of the user's identity, requesting such verification in any form not contrary to law. Softline undertakes to consider and send a response to the received request within 30 (thirty) days from the date of receipt of the appeal.

6.8. User personal data will not be stored or processed by Softline after the expiry of the period required to achieve the purposes of processing and upon completion of the data retention period. Softline will cease processing and destroy user personal data within the timeframes specified in Section 8 of this Policy upon achievement of the purposes of processing such data, unless otherwise provided by the current legislation of the Russian Federation.

6.9. If you believe that Softline's processing of your personal data does not comply with the provisions of this Policy or Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data", you have the right to challenge Softline's actions or inactions by contacting Roskomnadzor at the link: https://rkn.gov.ru/treatments/ask-question/. By following this link, you will need to select the topic of your appeal and fill in all required fields.

7. Feedback. Questions and suggestions

All suggestions or questions regarding this Policy should be reported to Softline by phone +7(495) 232-0023, by email to privacy@softline.com, or by sending a written request to the address: 115114, Moscow, Derbenevskaya Embankment, 7, business quarter "Novospassky", bldg. 8, to PAO "Softline" marked "questions and suggestions regarding the Privacy Policy".

8. Storage period for personal data

Data collected to fulfill obligations by Softline under orders, contracts, etc., to fulfill obligations for providing services to users undertaken by Softline, to provide user personal data to software rights holders, distributors or resellers for software registration in the user's name, or in the name of the organization represented by the user.

  • Storage period: Softline stores data for the entire period required to fulfill Softline's obligations under orders and services purchased by the user, but no more than 2 years from the date of the last interaction with the data, except in cases of an active contract, court proceedings or legislative requirements allowing further processing of user personal data, about which the user will be notified.

Collection of data for marketing purposes (for contacts using email or phone to offer services, newsletters or event registration).

  • Storage period: Softline stores data for the entire period required to provide information to the user in accordance with their subscription, but no more than 2 years from the date of the last interaction with the data, except in cases of an active contract, court proceedings or legislative requirements allowing further processing of user personal data, about which the user will be notified.

Collection of user data through web forms for event registration purposes.

  • Storage period: Softline stores data for the entire period required to achieve the processing purpose, but no more than 2 years from the date of the last registration.

Collection of user data through direct contact via email, phone or mail (providing personalized services).

  • Storage period: Softline stores data for the entire period required to achieve the processing purpose, but no more than 2 years from the date of the last interaction with the data, except in cases of an active contract, court proceedings or legislative requirements allowing further processing of user personal data, about which the user will be notified. Softline may continue storing user personal data if there is an obligation arising from legislative requirements, to protect the user's vital interests, or to protect the vital interests of another natural person.

Collection of data using cookies and similar technologies.

  • Storage period: for more detailed information on periods related to the use of cookies and similar technologies, please review the Cookie Usage Policy.

Data received during collection of resumes and selection of candidates for vacant positions at Softline.

  • Storage period: Softline stores data for the entire period required to achieve the processing purpose, but no more than 2 years from the date of the last interaction with the data.

A longer period of storage of personal data is established by current legislation.

The Softline Group of Companies includes legal entities, as presented at the link.

Date of adoption of this Policy: January 17, 2022.