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Privacy Policy

regarding the processing of personal data

This is an unofficial translation provided for convenience. The legally binding version is the Russian original; in case of any discrepancy the Russian text prevails.

This personal data processing policy (hereinafter — the Policy) has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for the Processing of Personal Data and the measures to ensure the security of Personal Data taken by the limited liability company “SEKUNDANT” (Sekundant LLC) (PSRN 1237700546050, TIN 7751263581, KPP 771401001), registered address: 125167, г. Москва, ВН.ТЕР.Г. Муниципальный Округ Хорошевский, пр-кт Ленинградский, д. 37/5, кв. 213Д, on the website on the Internet at the network address s-shooting.ru.

Terms and definitions

  1. Automated Processing of Personal Data — the Processing of Personal Data by means of computer technology.
  2. Blocking of Personal Data — the temporary suspension of the Processing of Personal Data (except where the Processing is necessary in order to clarify the Personal Data).
  3. Personal Data Information System — a set of Personal Data contained in databases together with the information technologies and technical means that ensure their Processing.
  4. Depersonalisation of Personal Data — actions as a result of which it becomes impossible, without the use of additional information, to determine that the Personal Data belong to a particular User or other personal data subject.
  5. Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without the use of automation means with Personal Data, including collection, recording, systematisation, accumulation, storage, clarification (updating, alteration), extraction, use, transfer (Dissemination, Provision, access), Depersonalisation, Blocking, deletion, Destruction of Personal Data.
  6. Operator — the limited liability company “SEKUNDANT” (Sekundant LLC) (PSRN 1237700546050, TIN 7751263581, KPP 771401001), registered address: 125167, г. Москва, ВН.ТЕР.Г. Муниципальный Округ Хорошевский, пр-кт Ленинградский, д. 37/5, кв. 213Д, which organises and carries out the Processing of Personal Data, and also determines the purposes of the Processing of Personal Data, the composition of the Personal Data subject to Processing, and the actions (operations) performed with the Personal Data.
  7. Personal Data — any information relating directly or indirectly to a determined or determinable User of the Website.
  8. Personal Data permitted by the User for Dissemination — Personal Data to which access by an unlimited number of persons has been granted by the User by giving consent to the Processing of Personal Data permitted by the User for Dissemination in the manner provided for by the Personal Data Law.
  9. User — a personal data subject, any visitor of the Website who provides the Operator with his or her Personal Data.
  10. Provision of Personal Data — actions aimed at disclosing Personal Data to a particular person or a particular group of persons.
  11. Dissemination of Personal Data — any actions aimed at disclosing Personal Data to an indefinite group of persons (transfer of Personal Data) or at making Personal Data known to an unlimited number of persons, including the publication of Personal Data in the mass media, the placement of Personal Data in information and telecommunication networks or the provision of access to Personal Data in any other way.
  12. Website — the Operator’s web resource located on the Internet at the address s-shooting.ru and in the “SEKUNDANT” mobile application, through which goods are sold by distance selling.
  13. Cross-border Transfer of Personal Data — the transfer of Personal Data to the territory of a foreign state to a foreign state authority, a foreign natural person or a foreign legal entity.
  14. Destruction of Personal Data — any actions as a result of which Personal Data are destroyed irrevocably, with the impossibility of further restoration of the content of the Personal Data in the Personal Data Information System and / or the material carriers of the Personal Data are destroyed.
  15. Cookies — small text files saved by the User’s Internet browser on a personal computer and / or tablet personal computer, telephone or other device used by the User to visit the Website.

1. General provisions

1.1. The Operator sets as its most important goal and as a condition of carrying out its activities the observance of human and civil rights and freedoms when Processing his or her Personal Data, including the protection of the rights to inviolability of private life and to personal and family privacy.

1.2. This Policy of the Operator regarding the Processing of Personal Data applies to all information that the Operator may obtain about Users of the Website.

1.3. Use of the services of the Website means the User’s unconditional consent to this Policy and to the conditions for the Processing of his or her Personal Data set out herein.

2. Purposes of processing and scope of the personal data processed

2.1. Registration on the Website:

2.2. Identification on the Website:

2.3. Establishing and maintaining communication between the User and the Operator:

2.4. Sending advertising messages, targeting of advertising materials:

2.5. Improving the quality of service to Users and upgrading the Website:

2.6. Use, including visiting the relevant mobile applications, as well as other services in accordance with the functionality provided:

2.7. Placing orders (for goods and services) and their subsequent delivery (return) within / outside the Russian Federation:

2.8. Organising and holding promotions, contests and events, including the subsequent award of prizes and payment of remuneration to the winners:

3. Principles of personal data processing

3.1. The Processing of Personal Data is carried out on a lawful and fair basis.

3.2. The Processing of Personal Data is limited to the achievement of the specific purposes set out in section 3 of this Policy. The Processing of Personal Data incompatible with the purposes set out in section 3 of this Policy is not permitted.

3.3. It is not permitted to merge databases containing Personal Data the Processing of which is carried out for purposes incompatible with each other.

3.4. Only Personal Data that correspond to the purposes set out in section 3 of this Policy are subject to Processing.

3.5. The content and scope of the Personal Data processed correspond to the purposes set out in section 3 of this Policy. Redundancy of the Personal Data processed in relation to the declared purposes of their Processing is not permitted.

3.6. When Processing Personal Data, the accuracy of the Personal Data, their sufficiency and, where necessary, their relevance to the purposes set out in section 3 of this Policy are ensured. The Operator takes the necessary measures and / or ensures that they are taken to delete or clarify incomplete or inaccurate data.

3.7. Personal Data are stored in a form that allows the personal data subject to be identified no longer than required by the purposes set out in section 3 of this Policy, unless the storage period for the Personal Data is established by the Personal Data Law or by a contract to which the personal data subject is a party, beneficiary or guarantor. The Personal Data processed are destroyed or depersonalised upon achievement of the purposes set out in section 3 of this Policy, or in the event that the need to achieve those purposes is lost, unless otherwise provided by the Personal Data Law.

4. Main rights and obligations of the Operator and Users

4.1. The Operator has the right:

4.1.1. To receive from the User accurate information and / or documents containing Personal Data;

4.1.2. If the User withdraws consent to the Processing of Personal Data, as well as sends a request demanding that the Processing of Personal Data be terminated, the Operator has the right to continue the Processing of Personal Data without the User’s consent where the grounds set out in the Personal Data Law are present;

4.1.3. To determine independently the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided for by the Personal Data Law and by the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

4.2. The Operator is obliged:

4.2.1. To provide the User, at his or her request, with information concerning the Processing of his or her Personal Data;

4.2.2. To organise the Processing of Personal Data in the manner established by the current legislation of the Russian Federation;

4.2.3. To respond to appeals and requests from Users and their legal representatives in accordance with the requirements of the Personal Data Law;

4.2.4. To report to the authorised body for the protection of the rights of Users, at the request of that body, the necessary information within 10 (Ten) days from the date of receipt of such request;

4.2.5. To publish or otherwise provide unrestricted access to this Policy regarding the Processing of Personal Data;

4.2.6. To take legal, organisational and technical measures to protect Personal Data against unlawful or accidental access to them, Destruction, alteration, Blocking, copying, Provision, Dissemination of Personal Data, as well as against other unlawful actions in respect of Personal Data;

4.2.7. To terminate the transfer (Dissemination, Provision, access) of Personal Data, to terminate the Processing and to destroy the Personal Data in the manner and in the cases provided for by the Personal Data Law.

4.3. Users have the right:

4.3.1. To receive information concerning the Processing of their Personal Data, except in the cases provided for by federal laws. The information is provided to the User by the Operator in an accessible form and must not contain Personal Data relating to other Users, except where there are lawful grounds for disclosing such Personal Data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

4.3.2. To demand that the Operator clarify their Personal Data, block or destroy them if the Personal Data are incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the purposes set out in section 3 of this Policy, and also to take the measures provided for by law to protect their rights;

4.3.3. To put forward a condition of prior consent to the Processing of Personal Data for the purposes of promoting goods, works and services on the market;

4.3.4. To withdraw consent to the Processing of Personal Data, as well as to send a demand for termination of the Processing of Personal Data, by sending the Operator a notification to the Operator’s email address info@s-shooting.ru marked “Withdrawal of consent to the processing of personal data”;

4.3.5. To appeal to the authorised body for the protection of the rights of Users or through the courts against unlawful actions or omissions of the Operator in the Processing of their Personal Data.

4.4. Users are obliged:

4.4.1. To provide the Operator with accurate data about themselves;

4.4.2. To inform the Operator of the clarification (updating, alteration) of their Personal Data, by sending the Operator a notification to the Operator’s email address info@s-shooting.ru marked “Updating of personal data”.

4.5. Users who have provided the Operator with inaccurate information about themselves, or information about another User without the latter’s consent, bear responsibility in accordance with the legislation of the Russian Federation.

5. Processing of personal data, security and confidentiality

The security and confidentiality of the Personal Data processed by the Operator is ensured through the implementation of the legal, organisational and technical measures necessary for the full compliance with the requirements of the current legislation in the field of personal data protection.

5.1. The Operator ensures the safekeeping and confidentiality of Personal Data and takes all possible measures preventing access to personal data by unauthorised persons.

5.2. The User’s Personal Data will never, under any circumstances, be transferred to third parties, except in cases connected with compliance with the current legislation or where the User has given the Operator consent to transfer the data to a third party.

5.3. The period of the Processing of Personal Data is determined by the achievement of the purposes set out in section 3 of this Policy, unless a different period is provided for by a contract or by the current legislation of the Russian Federation.

5.4. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their user agreements and privacy policies. The Operator bears no responsibility for the actions of third parties, including the service providers referred to in this clause.

5.5. Prohibitions established by the User on the transfer (other than the provision of access), as well as on the Processing or the conditions of Processing (other than obtaining access) of Personal Data permitted for Dissemination, do not apply in cases of Processing of Personal Data in state, public and other public interests defined by the legislation of the Russian Federation.

5.6. When Processing Personal Data, the Operator ensures the confidentiality of personal data.

5.7. The Operator stores Personal Data in a form that allows the User to be identified no longer than required by the purposes set out in section 3 of this Policy, unless the storage period for the Personal Data is established by federal law or by a contract to which the User is a party, beneficiary or guarantor.

5.8. Grounds for termination of the Processing of Personal Data may be the achievement of the purposes set out in section 3 of this Policy, the expiry of the User’s consent, the withdrawal of consent by the User or a demand for termination of the Processing of Personal Data, as well as the detection of unlawful Processing of Personal Data.

6. Cross-border transfer of personal data

6.1. Before commencing activities involving the Cross-border Transfer of Personal Data, the Operator is obliged to notify the authorised body for the protection of the rights of Users of its intention to carry out the Cross-border Transfer of Personal Data (such notification is sent separately from the notification of the intention to process personal data).

6.2. The Operator is obliged to notify Users of the carrying out of activities involving the Cross-border Transfer of Personal Data by making amendments to this policy.

6.3. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, the foreign natural persons and the foreign legal entities to which the cross-border transfer of personal data is planned.

7. Dispute resolution

7.1. Before applying to a court with a claim in disputes arising out of the relations between the User and the Operator, it is mandatory to submit a claim letter (a written proposal for the voluntary settlement of the dispute).

7.2. Within 14 (Fourteen) calendar days from the date of receipt of the claim letter, the recipient of the claim letter shall notify the claimant in writing of the results of its consideration.

7.3. If no agreement is reached, the dispute shall be referred for consideration to the Arbitrazh (commercial) court at the location of the Operator.

8. Use of cookies and web analytics services

8.1. The Website uses cookies and web analytics services to collect depersonalised statistical data on traffic and on the behaviour of Users for the purpose of improving the operation of the Website and the quality of service.

8.2. The Operator uses the Yandex.Metrica service (Yandex LLC), including the Webvisor technology, to analyse the actions of Users on the Website. Webvisor may record the User’s actions on the pages of the Website (cursor movements, clicks, scrolling, form filling). Form fields containing Personal Data (name, telephone number, email address, message text) are excluded from Webvisor recording and are not transmitted to the service — their content is masked.

8.3. The Website may use the Google Analytics service (Google LLC) to collect depersonalised visit statistics.

8.4. The said services collect data by means of cookies and similar technologies: depersonalised IP address, information about the device and browser, referral source, pages viewed and actions performed on the Website. The Processing of these data is carried out on the terms of the respective services: Yandex Privacy Policy — yandex.ru/legal/confidential; Google Privacy Policy — policies.google.com/privacy.

8.5. The User has the right to refuse the Processing of cookies and web analytics data by changing the settings of his or her browser (disabling cookies) or by using special blocking tools. Disabling cookies may affect the operation of certain functions of the Website.

8.6. By continuing to use the Website without changing the browser settings, the User expresses consent to the Processing of cookies and to the collection of depersonalised analytics data to the extent and for the purposes set out in this section.

9. Final provisions

9.1. The User may obtain any clarifications on questions of interest concerning the Processing of his or her Personal Data by contacting the Operator by email at info@s-shooting.ru.

9.2. Any amendments to this Policy made by the Operator will be reflected in this Policy. The Policy is valid indefinitely until replaced by a new version.

9.3. The current version of the Policy is freely available on the Internet at s-shooting.ru/en/privacy-policy.

9.4. The current legislation of the Russian Federation applies to this Policy and to the relations between the User and the Operator.