Personal Data Processing Policy
1. Purpose and scope
1.1. This Personal Data Processing Policy (the “Policy”) sets out the position and intentions of Binnopharm Group Limited Liability Company (“Binnopharm Group LLC”) as regards processing, protection, and confidentiality of personal data, with a view to respecting and protecting the rights and freedoms of each individual and, in particular, the right to privacy, personal and family secrets, the protection of honour and good name.
1.2. The Policy applies to any and all information that Binnopharm Group LLC may obtain on visitors of the website https://www.binnopharmgroup.ru/.
1.3. The Policy shall be strictly complied with by managers and employees of all units of Binnopharm Group LLC.
1.4. Use of the website https://www.binnopharmgroup.ru/ by the User means consent to this Policy and the terms of the User’s personal data processing. If the User does not consent to the terms of the Policy, they shall stop using the website https://www.binnopharmgroup.ru/.
1.5. This Policy applies to the website https://www.binnopharmgroup.ru/, which has neither control nor responsibility for third-party websites which the User may visit via the links available on https://www.binnopharmgroup.ru/. Third-party websites may have their own policies regarding personal data processing and may collect or request other personal data from the User. 1.6. Binnopharm Group LLC does not verify personal data provided by the User.
2. Terms and definitions
2.1. Personal Data Processing means any action (operation) or set of actions (operations) performed with personal data, including collection, recording, systematisation, accumulation, storage, correction (updating, modification), extraction, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction of personal data, with or without means of automation;
2.2. Personal Data Operator (the “Operator”) means a government body, municipal authority, legal entity or individual organising Personal Data Processing. The Operator processing personal data received from the website https://www.binnopharmgroup.ru/ is Binnopharm Group LLC (INN: 9704005675, 14 Kozhevnicheskaya St., Bld. 5, floor 4, Moscow);
2.3. Personal Data means any and all information relating directly or indirectly to an identified or identifiable User of the website https://www.binnopharmgroup.ru/;
2.4. User means any visitor of the website https://www.binnopharmgroup.ru/;
2.5. Cookie means a small block of data sent by a web server and stored on the User's computer.
3. Subject matter
3.1. This Policy sets out obligations of the Operator for non-disclosure and protection of the confidentiality of the Personal Data which the User provides to the Operator at its request on the website https://www.binnopharmgroup.ru/.
3.2. Personal Data permitted for processing under this Policy is provided by the User by filling in the forms on the website https://www.binnopharmgroup.ru/ and includes the following information:
• the User's first name;
• the User's last name;
• the User's patronymic;
• e-mail address;
• phone number.
3.3. The Operator also processes technical information of the User's devices, which is automatically transmitted when visiting the website (e.g.: IP address, cookies, MAC address, data on the User's web browser and device, referrer (address of the previous page), information about the fact, date, time of visiting network addresses and websites on the Internet, errors on the website, geographical location of the User's Internet access point).
4. Purposes of personal data processing
4.1. The purposes of personal data processing include:
• contacting the User, among other things, to reply to the User’s request and provide the requested information;
• notifying the User by e-mail;
• providing comprehensive and effective advisory support to the User to troubleshoot issues related to using the website https://www.binnopharmgroup.ru/.
4.2. The anonymised User data collected by web analytics services is used to evaluate the website's performance and optimise it, to make our website easier to use and to tailor the website's content to the User's preferences. Cookies may also be used to speed up future browsing activity on our website.
5. Principles and terms of personal data processing
5.1. By security of personal data Binnopharm Group LLC understands protection and confidentiality of personal data from unauthorised or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data and takes necessary legal, organisational and technical measures to protect Personal Data.
5.2. Binnopharm Group LLC processes and protects personal data in compliance with the Constitution of the Russian Federation, Federal Law No. 152-FZ On Personal Data, regulations and guidelines of the Federal Service for Technical and Export Control of Russia and the Federal Security Service, by-laws and other federal laws of the Russian Federation that define instances and aspects of personal data processing.
5.3. The Operator processes the User's personal data only if the User fills in and/or submits them on their own via special forms on the website https://www.binnopharmgroup.ru/. By filling in the relevant forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.
5.4. When processing personal data, Binnopharm Group LLC adheres to the following principles: • regulatory compliance and fairness; • limiting personal data processing to the achievement of specific, predetermined, and lawful purposes; • preventing processing of personal data which is incompatible with the purposes of personal data collection; • preventing integration of databases that contain personal data intended for incompatible processing purposes; • personal data processing compatible with the processing purposes; • consistency of processed personal data content and scope with the stated purposes of processing.
5.5. The Operator is entitled to transfer the personal data it processes where so prescribed by the Russian law.
5.6. The Operator destroys or anonymises personal data after achieving the processing purposes or after these purposes become irrelevant.
5.8. Third-party web services used to collect information referred to in clause 3.3. do not and cannot match the information they receive with the personal data provided by the User in the respective forms on the website https://www.binnopharmgroup.ru/ and enabling identification of the User. Data received by third-party web services is stored and further processed by these services using their own hardware, and the Operator is not responsible for geographic locations of this hardware.
6. Rights and obligations of the parties
6.1. The User, whose personal data are processed by Binnopharm Group LLC, has the right to: • update, supplement the provided information on personal data in case of changes in this information; • at any time withdraw their consent to personal data processing by the Operator by sending a written notice marked “withdrawal of consent to personal data processing” to the address: 14 Kozhevnicheskaya St., Bld. 5, floor 4, Moscow, 115114, Binnopharm Group LLC.
6.2. The User whose personal data is processed by Binnopharm Group LLC has the right to receive from the Operator: • confirmation of the fact of personal data processing by Binnopharm Group LLC; • legal grounds and purposes of personal data processing; • information on the methods of personal data processing used by the Operator; • name and location of Binnopharm Group LLC; • information on parties that have access to the personal data or that the personal data may be disclosed to under an agreement or user agreement with Binnopharm Group LLC or pursuant to a federal law; • list of the processed personal data related to the individual sending such a request, and the origin thereof, unless otherwise provided by a federal law establishing a different procedure for submitting such data; • information on the processing period of the personal data, including the storage period thereof; • information on ongoing or planned cross-border transfer of personal data; • name and address of the party that processes personal data on behalf of Binnopharm Group LLC;
• other information required by Federal Law No. 152-FZ On Personal Data or other federal laws.
7. Liability of the Parties
7.1. Should Binnopharm Group LLC fail to comply with the provisions of this Policy, it shall be held liable in accordance with the applicable laws of the Russian Federation.
7.2. The User shall be fully responsible for compliance with the laws of the Russian Federation, including, but not limited to the laws relating to advertising, protection of copyright and neighbouring rights, protection of trademarks and service marks, as well as for the content and form of materials.
7.3. The User acknowledges that the responsibility for any information (including, but not limited to data files, texts, etc.), to which they may have access to as part of the Binnopharm Group LLC website (https://www.binnopharmgroup.ru/), shall be borne by the party that provides such information.
7.4. Text materials (articles and publications freely and publicly accessible at https://www.binnopharmgroup.ru/) may be distributed provided that they refer to https://www.binnopharmgroup.ru/.
7.5. Binnopharm Group LLC shall not be liable for any direct or indirect losses arising from the use or inability to use the website or individual services.
8. Information about effective requirements for personal data protection 8.1. In personal data processing, Binnopharm Group LLC assumes legal, organisational, and technical measures to maintain the confidentiality of personal data and protect it from unauthorised or accidental access, deletion, blocking, copying, disclosure, or distribution, as well as from any other wrongful acts.
As per Federal Law No. 152-FZ On Personal Data, such measures include:
• identifying threats to personal data during processing thereof in personal data systems;
• taking organisational and technical measures to protect personal data during processing thereof in personal data systems to comply with personal data protection requirements for achieving certain degrees of personal data protection established by the Government of the Russian Federation;
• assessing measures to ensure personal data security before the launch of the personal data system;
• identifying cases of unauthorised access to personal data and taking appropriate measures;
• restoring personal data modified or destroyed as a result of unauthorised access;
• setting the rules of access to personal data processed in the personal data system, registration and recording of all operations with personal data in the personal data system;
• monitoring measures to ensure personal data security and an adequate degree of protection for personal data systems;
• deploying hardware for personal data protection within the secured perimeter;
• having technical security systems in place;
• investigating violations of personal data protection requirements (incidents).
8.2. Binnopharm Group LLC has dedicated employees responsible for the security of personal data to ensure coordinated personal data protection efforts.
9. Dispute resolution
9.1. All disputes and disagreements arising between the User and Binnopharm Group LLC shall first and foremost be settled using the complaint procedure (through a written notice sent via a courier, mail or e-mail).
9.2. The recipient shall notify the claimant of the claim review results in writing or via an e-mail within 30 calendar days after the receipt thereof.
9.3. Disputes not settled by way of negotiation shall be resolved by the Moscow Arbitration Court.
9.4. The Policy and the relationship between the User and Binnopharm Group LLC shall be governed by the applicable laws of the Russian Federation.
10.1 The User may receive any clarifications on matters pertaining to the processing of their personal data by sending an inquiry to the Operator’s e-mail address email@example.com.
10.2. This document shall reflect any changes in the Personal Data Processing Policy made by the Operator. The Policy shall remain valid indefinitely until it is replaced by a new version.
10.3. The current version of the Policy is publicly available online at https://www.binnopharmgroup.ru/polozhenie-o-zashchite-personalnykh-dannykh/