Privacy Policy

1.General provisions.

1.1. The policy regarding the processing of personal data is a system of local regulations (hereinafter referred to as the Policy) that define the confidentiality policy of OOO Troika Cafe, which includes this Privacy Policy (hereinafter referred to as the Privacy Policy) and the "Protection Regulations" personal data of employees in LLC "Cafe Troika" (hereinafter referred to as the Regulations), which are mandatory for the application and execution of local regulatory enactments, basic documents containing general objectives , principles and norms of LLC "Cafe Troika" (hereinafter referred to as "Operator") when processing personal data (hereinafter referred to as "PD"),

1.2. The policy was developed in accordance with paragraph 2 of Part 1 of Article 18.1 of the Federal Law of 27.07.2006. № 152-FZ "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 processing and protecting PD, and is aimed at protecting the rights and freedoms of individuals whose personal data are processed by the Operator.

1.3. The policy contains information to be disclosed in accordance with Part 1 of Article 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 subject of the PoA, are governed by the Policy, the local regulatory acts of the Operator and the legislation of the Russian Federation in the field of processing PD.

1.4.1. Objectives of processing PD:

- providing the subject of PD with information about the services and products of Cafe Troika, events, special offers, availability of goods, services, provision of other information and consultations, as well as the implementation of newsletters, sending messages of an advertising nature, including for subsequent imprisonment any transactions permitted by the current legislation of the Russian Federation;

- Carrying out of marketing and other researches by the Operator; preparation and transfer by the Operator of responses to requests of subjects of the PD; carrying out by the Operator, with the participation of the subjects of PD, of activities, the provision of services, the sale of goods;

- the Operator fulfills the duties of the employer provided by law;

- the fulfillment by the Operator of the obligations arising from contractual and other civil law relations with the subjects of the PD.

1.4.2. The PD, provided to the Operator, are processed by the following persons:

- Counterparties and potential counterparties of the Operator;

- representatives who are individuals, counterparties and potential contractors of the Operator;

- employees and former employees of the Operator;

- other persons, in cases stipulated by the legislation of the Russian Federation or local regulatory acts of the Operator.

1.4.3. The list of personal data processed by the Operator is determined by the Policy, the consent of the subject of the PD and, subject to the interests of the persons listed in paragraph 1.4.2., Is governed by the administrative acts of the Operator's manager.

1.5. PDs are processed by the Operator in non-contradicting RF legislation and in their legitimate interests, if such processing does not violate the rights of the subjects of the PD

1.6. The legal grounds for processing personal data are:

- federal laws and the regulatory legal acts adopted on their basis that regulate relations related to the activities of the Operator;

- agreements concluded between the Operator and the subjects of the PoA;

- the consent of the subject of AP for the processing of PD.

1.7. The Policy applies to relations related to the processing of APs received by the Operator both before and after its approval, except for cases when, for legal, organizational or other reasons, the provisions of the Policy can not be extended to the relations for processing and protection of APs received before its approval.

2. Terms of processing of personal data and their transfer to third parties.

2.1. Processing of the PD subject of the PD is carried out within the period necessary for the purposes specified in the Policy, in any legal way, including in information systems using automation tools or without using such means.

2.2. PD can be transferred by the Operator to the authorized state authorities only on the grounds and in the order established by the legislation of the Russian Federation.

2.3. The fact of filling out and transferring to the Operator the form in which the PD is entered on the Operator's corporate site on the Internet , the subject of the PD confirms that he :

- indicates reliable information about yourself, all other information is provided by the subject of the PD at his own discretion;

- agrees that the Operator has the right to process the PD, including the transfer of these PDs to third parties, including those servicing the specified Operator's website on the Internet, to other legal entities and individuals rendering the Operator marketing and other services required by the Operator for proper and high-quality execution of their obligations under concluded contracts, as well as for the purposes of other measures in the performance of obligations provided for by the current legislation;

- in the order of Part 1 of Art. 18 of Federal Law No. 38-FZ of 03.03.2006 "On Advertising" expresses its consent to receive messages, including sms, notices of advertising nature via telecommunication networks, including through the use of telephone, facsimile, mobile radiotelephone communications;

- recognizes the legal force of e-mails /documents sent by e-mail, including by the Operator;

- solely has the right and the ability to access the email account and /or the mobile radiotelephone device with the address and /or number indicated on the form. This access is carried out by the PD subject by password, which is confidential.

2.4. The operator does not check the reliability of the received information about the subject of the AP, except for cases when such verification is necessary in order to fulfill obligations to him.

2.5. The operator has the right to transfer the PD to third parties in the following cases:

- the subject of the PD expressed his consent to such actions; the transfer is provided within the procedure established by the legislation of the Russian Federation.

2.6. When processing the PD, the Operator is guided by the current legislation of the Russian Federation on PD and local regulatory acts of the Operator.

2.7. When processing the PD, the Operator uses databases located in the territory of the Russian Federation.

3. Feedback.

3.1. Contact details of the Operator for addressing subjects of the PoA on issues related to the PoA:

- e-mail:;

- postal address: 27, Zagorodny Ave., St. Petersburg.

- Contact phone: 713-29-99

3.2. Referring to the above contact information, the subject of the AP, processed by the Operator, can obtain information concerning the processing of his PD, including:

- confirmation of the fact of the processing of the PD by the Operator;

- legal grounds and objectives for processing PD;

- methods of processing PD used by the Operator;

- the name and location of the Operator, information about the persons (with the exception of the Operator's employees) who have access to the PoA or who can be disclosed by the AP on the basis of a contract with the Operator or on the basis of a federal law;

- processed PD related to the relevant subject of the AP, the source of their receipt, unless another procedure for the submission of such data is provided for by federal law;

- the processing time for PD, including the time of their storage; the procedure for the subject of the PD to exercise the rights provided for by the Federal Law;

- information on the carried out or expected transboundary transfer of the PoA;

- name or surname, name, patronymic and address of the person performing the processing of the PD on behalf of the Operator, if the processing is entrusted or will be entrusted to such person;

- other information provided for by the Federal Law or other federal laws.

3.3. The subject of the PoA has the right to receive information regarding the processing of his PoA, except for cases when this right is limited in accordance with federal laws. The subject of the PD is entitled to require the Operator to clarify its PD, to block or destroy it in the event that PDs are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights.

3.3.1. The operator assumes that the subject of the PD agrees that, upon his written request, the notification of the destruction of the PD will be sent /served at his e-mail or residence addresses specified in the AP Processing Agreement or his representative in person or at the address of the residence .

3.3.2. Request for information or destruction of the PD must contain the number of the main document certifying the identity of the subject of the AP or its representative, information on the date of issue of the specified document and the body that issued it, information confirming the participation of the subject of the AP in relations with the Operator (contract number, conditional verbal designation and /or other information), or information that otherwise confirms the fact of the processing of the PD by the Operator, the signature of the subject of the PD or his representative. The request can be sent in the form of a corresponding notification by e-mail from the e-mail address provided by the subject of the PD to the Operator's e-mail address ( ) or by sending a written request to the Operator by registered mail with a notice of delivery with a list of attachments at the address: 27 Zagorodny Ave., St. Petersburg.

3.4. In the event that the above information, as well as the processed PD, have been provided to the subject of the PD at his request, the subject of the PoA has the right to apply again to the Operator or send a repeated request to receive the AP not earlier than 30 (thirty) days after the initial circulation or direction of the initial request.

4. Security of personal data processing.

4.1. The main task of ensuring the safety of PDs during their processing by the Operator is to prevent unauthorized access to them by third parties, to prevent deliberate program and technical and other impacts with the aim of stealing PD, destroying (destroying) or distorting them during processing.

4.2. The operator takes necessary and sufficient measures of a technical and organizational nature to ensure information security and protection of the PD from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions with them from third parties.

4.3. The operator does not process the PD, which is incompatible with the purpose of collecting them. Unless otherwise provided by federal law, upon completion of the processing of the PD by the Operator, including when achieving the objectives of their processing or the loss of the need to achieve these objectives, the PDs processed by the Operator are destroyed or depersonalized.

4.4. When processing PDs, their accuracy, sufficiency, and, if necessary, their relevance to the processing objectives are ensured. The operator takes the necessary measures to remove or refine 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 the "Troika Cafe" LLC, unless otherwise provided for by the new edition of the Policy.