Privacy
policy
1. General provisions.
1.1. The policy on personal data processing is a system of local regulations (hereinafter — the Policy) defining the privacy policy of LLC "Cafe "Troika", which includes this Policy on personal data processing (hereinafter — the Privacy Policy) and the "Regulation on the protection of personal data of employees at LLC "Cafe "Troika" (hereinafter — the Regulation), which are mandatory for application and execution as local regulations, fundamental documents containing the general goals, principles and norms of LLC "Cafe "Troika" (hereinafter — the Operator) when processing personal data (hereinafter — PD).
1.2. The Policy has been developed in accordance with clause 2, part 1, art. 18.1 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — the Federal Law "On Personal Data"), in order to implement the requirements of the legislation of the Russian Federation in the field of PD processing and protection, and is aimed at protecting the rights and freedoms of individuals whose personal data is processed by the Operator.
1.3. The Policy contains information subject to disclosure in accordance with part 1, art. 14 of the Federal Law "On Personal Data"; the documents are publicly available.
1.4. Relations related to the processing and protection of PD provided by the PD subject are governed by the Policy, local regulations of the Operator and the legislation of the Russian Federation in the field of PD processing.
1.4.1. Purposes of PD processing:
- providing the PD subject with information about the services and products of LLC "Cafe "Troika", ongoing events, special offers, availability of goods and services, providing other information and consultations, as well as carrying out newsletter distribution, sending advertising messages, including for the subsequent conclusion of any transactions permitted by the current legislation of the Russian Federation;
- conducting marketing and other research by the Operator; preparing and sending responses to requests from PD subjects by the Operator; holding events, providing services, selling goods by the Operator with the participation of PD subjects;
- performance by the Operator of the employer's duties provided for by law;
- performance by the Operator of obligations arising from contractual and other civil law relations with PD subjects.
1.4.2. The PD provided to the Operator is processed from the following persons:
- counterparties and potential counterparties of the Operator;
- representatives who are individuals, of counterparties and potential counterparties of the Operator;
- employees and former employees of the Operator;
- other persons, in cases provided for by the legislation of the Russian Federation or local regulations of the Operator.
1.4.3. The list of personal data processed by the Operator is determined by the Policy, the consent of the PD subject and, taking into account the interests of the persons listed in clause 1.4.2, is regulated by the administrative acts of the head of the Operator.
1.5. PD is processed by the Operator for purposes that do not contradict the legislation of the Russian Federation and in its legitimate interests, if such processing does not violate the rights of PD subjects.
1.6. The legal grounds for processing personal data are:
- federal laws and regulatory legal acts adopted on their basis, regulating relations related to the activities of the Operator;
- contracts concluded between the Operator and PD subjects;
- consent of the PD subject to PD processing.
1.7. The Policy applies to relations related to the processing of PD received by the Operator both before and after its approval, except in cases where, for legal, organizational and other reasons, the provisions of the Policy cannot be extended to relations on the processing and protection of PD received before its approval.
2. Conditions of personal data processing and its transfer to third parties.
2.1. Processing of the PD of the PD subject is carried out within the period necessary for the purposes specified in the Policy, in any lawful manner, including in information systems using automation tools or without using such tools.
2.2. PD may be transferred by the Operator to authorized state authorities only on the grounds and in the manner established by the legislation of the Russian Federation.
2.3. By filling out and submitting to the Operator the form into which PD is entered on the Operator's corporate website on the Internet www.troikaspb.ru, the PD subject confirms that they:
- provide accurate information about themselves, all other information is provided by the PD subject at their own discretion;
- agree that the Operator has the right to process PD, including transferring this PD to third parties, including those servicing the specified Operator's website on the Internet, other legal entities and individuals providing the Operator with marketing and other services necessary for the Operator to properly and efficiently fulfill its obligations under concluded contracts, as well as for the purposes of other activities in fulfilling obligations stipulated by the current legislation;
- in accordance with part 1, art. 18 of Federal Law No. 38-FZ of 13.03.2006 "On Advertising", expresses their consent to receive messages, including SMS notifications, of an advertising nature via telecommunication networks, including through the use of telephone, facsimile, mobile radiotelephone communications;
- recognize the legal force of electronic letters / documents sent by e-mail, including by the Operator;
- solely possess the right and ability to access the e-mail account and / or mobile radiotelephone communication device with the address and / or number specified in the form. This access is carried out by the PD subject using a password, which is confidential.
2.4. The Operator does not verify the accuracy of the information received about the PD subject, except in cases where such verification is necessary in order to fulfill obligations to them.
2.5. The Operator has the right to transfer PD to third parties in the following cases:
- the PD subject has expressed their consent to such actions; the transfer is provided for within the framework of the procedure established by the legislation of the Russian Federation.
2.6. When processing PD, the Operator is guided by the current legislation of the Russian Federation on PD and local regulations of the Operator.
2.7. When processing PD, the Operator uses databases located on the territory of the Russian Federation.
3. Feedback.
3.1. Contact details of the Operator for PD subjects to apply on issues related to PD:
- email address: company@troikaspb.ru ;
- postal address: St. Petersburg, Zagorodny pr., 27.
- contact phone: 713-29-99
3.2. By contacting the contact details listed above, the PD subject whose PD is processed by the Operator can obtain information regarding the processing of their PD, including containing:
- confirmation of the fact of PD processing by the Operator;
- legal grounds and purposes of PD processing;
- methods of PD processing used by the Operator;
- name and location of the Operator, information about persons (except for employees of the Operator) who have access to PD or to whom PD may be disclosed on the basis of an agreement with the Operator or on the basis of federal law;
- processed PD relating to the relevant PD subject, the source of their receipt, unless a different procedure for providing such data is provided for by federal law;
- terms of PD processing, including terms of their storage; the procedure for exercising the rights provided for by federal law by the PD subject;
- information about the completed or intended cross-border transfer of PD;
- the name or surname, first name, patronymic and address of the person processing PD on behalf of the Operator, if the processing is or will be entrusted to such person;
- other information provided for by federal law or other federal laws.
3.3. The PD subject has the right to receive information regarding the processing of their PD, except in cases where this right is limited in accordance with federal laws. The PD subject has the right to demand that the Operator clarify their PD, block or destroy it if the PD is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights.
3.3.1. The Operator proceeds from the fact that the PD subject agrees that, at their written request, a notification on the destruction of PD will be sent / delivered to their email addresses or place of residence specified in the Consent to PD processing, or to their representative in person or at the address of residence.
3.3.2. A request for obtaining information or destruction of PD must contain the number of the main document proving the identity of the PD subject or their representative, information about the date of issue of the specified document and the authority that issued it, information confirming the participation of the PD subject in relations with the Operator (contract number, date of conclusion of the contract, conditional verbal designation and / or other information), or information otherwise confirming the fact of PD processing by the Operator, the signature of the PD subject or their representative. The request may be sent in the form of an appropriate notification by email from the email address provided by the PD subject to the Operator's email address (company@troikaspb.ru) or by sending a written appeal to the Operator by registered mail with a return receipt and an inventory of the attachment to the address: St. Petersburg, Zagorodny pr., 27.
3.4. If the above information, as well as the processed PD, were provided for review to the PD subject at their request, the PD subject has the right to re-apply to the Operator or send a repeated request for PD no earlier than 30 (thirty) days after the initial application or sending the initial request.
4. Security of personal data processing.
4.1. The main task of ensuring the security of PD during their processing by the Operator is to prevent unauthorized access to them by third parties, prevent intentional software, hardware and other impacts for the purpose of theft of PD, destruction (destruction) or distortion of them during processing.
4.2. The Operator takes the necessary and sufficient technical and organizational measures to ensure information security and protect PD from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions with them by third parties.
4.3. The Operator does not process PD incompatible with the purposes of their collection. Unless otherwise provided by federal law, upon completion of PD processing by the Operator, including upon achieving the purposes of their processing or loss of the need to achieve these purposes, the PD processed by the Operator is destroyed or depersonalized.
4.4. When processing PD, their accuracy, sufficiency, and, if necessary, relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures to delete or clarify incomplete or inaccurate PD.
5. Final provisions.
5.1. The Operator has the right to make changes to the Policy. The new version of the Policy comes into force from the moment it is posted on the website of LLC "Cafe "Troika", unless otherwise provided by the new version of the Policy.