privacy policy

this privacy policy (the “Policy”) sets out the rules under which the Company uses and processes personal data and other personal information received from the Data Subject.

the Policy applies to all information that the Company and/or its affiliates (including all entities within the same corporate group) may obtain about a Data Subject while the Data Subject uses any services of the Website.

the Data Subject’s consent to provide personal information, given in accordance with this Policy within the framework of relations with one of the entities comprising the Company, extends to all entities comprising the Company.

by using the Website, the Data Subject unconditionally agrees to this Policy and to the terms of processing of their personal information set forth herein. if the Data Subject does not agree with these terms, they must refrain from using the Website.

the Company may amend this Policy without any special notice. the new version of the Policy enters into force from the moment it is published on the Website, unless otherwise provided by the new version of the Policy.

the Company recommends that the Data Subject regularly review this Policy for any changes and/or additions. continued use of the Website after changes and/or additions are made means the Data Subject accepts and agrees to such changes and/or additions.

definitions

the following terms are used in this Privacy Policy:

“Company” means individual entrepreneur mutovin ilya anatolyevich, who is the personal data operator, organizes and/or carries out the processing of personal data, and also determines the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.

“Personal Data”, “Personal Information” means any information relating to a directly or indirectly identified or identifiable individual (the personal data subject).

“Processing of Personal Data” means any action (operation) or set of actions (operations) performed with personal data, with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction of personal data.

“Confidentiality of Personal Data” means the mandatory requirement for the Company or any other person who has gained access to personal data to prevent disclosure without the Data Subject’s consent or other lawful basis.

“Website” means a set of web pages available on the internet under the domain mutovin.ru and/or other domains that may be used by the Company at its discretion, united by a single theme, design, and address space.

“Data Subject” means a person who has access to the Service via the internet.

“Cookies” means a small piece of data sent by a web server and stored on the Data Subject’s computer, which the web client or web browser sends back to the web server in an HTTP request each time it attempts to open a relevant web page.

“IP address” means a unique network address of a node in a computer network through which the Data Subject accesses the Website.

  1. processing of personal data


1.1. the Company processes Personal Data based on the following principles:

  • lawfulness of the purposes and methods of processing;
  • good faith;
  • alignment of the purposes of processing with the purposes determined and declared in advance when Personal Data is collected, as well as with the Company’s authority;
  • proportionality of the scope and nature of processed Personal Data and processing methods to the purposes of processing;
  • inadmissibility of combining databases containing personal data created for purposes that are incompatible with each other.


1.2. the Company collects and processes personal data in accordance with federal law dated 27.07.2006 no. 152-fz “on personal data”.

  1. the Data Subject’s personal information collected and processed by the Company


2.1. for the purposes of this Policy, the Data Subject’s “Personal Data” / “Personal Information” includes:

2.1.1. any data that the Data Subject knowingly provides, including, but not limited to, during registration, account setup on the Website, and when leaving a review on the Website, including the Data Subject’s personal details that they provide about themselves on the Website:

  • last name, first name, patronymic;
  • mobile phone number;
  • email address;
  • other information.


2.1.2. data that is automatically transmitted to the Website services during their use through software installed on the Data Subject’s device, as well as data necessary for displaying and ensuring the operation of the Website, including:

  • data about the Data Subject’s activity on the internet, in particular, pages visited, date and time of url transitions, etc.;
  • cookie information. disabling cookies may result in inability to access parts of the Website that require authorization;
  • information about the device and browser used by the Data Subject to access the internet: ip address and (if the Data Subject accesses the Website from a mobile device) the device type and its unique identifier, as well as the language and version of the browser software;
  • data on interaction with the Company’s advertising displayed outside the Website, including the number, frequency, and depth of views;
  • access status / http status code;
  • volume of transmitted data;
  • the Data Subject’s geolocation;
  • other information about the Data Subject.


2.1.3. personal data that the Data Subject provides independently and/or that is collected automatically and is required to publish a review.

2.1.4. for the purpose of publishing a review, the Company may request additional Personal Data from the Data Subject with the Data Subject’s consent.

2.2. the Company does not collect “sensitive” data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning an individual’s sex life.

2.3. information is collected both while browsing the Website and throughout the period of use of the Website services.

2.4. this Policy applies only to the Website services. the Company does not control and is not responsible for other websites (third-party websites) that the Data Subject may access via links available on the Website or through which the Data Subject authorizes on the Website. such websites may collect or request other personal information from the Data Subject and may perform other actions.

2.5. as a general rule, the Company does not verify the accuracy of personal information provided by the Data Subject and does not verify their legal capacity. however, the Company proceeds on the assumption that the Data Subject provides accurate and sufficient personal information.

  1. cookies


3.1. cookies are small text files stored on a hard drive and assigned to the Data Subject’s browser, allowing certain information to be transmitted to the location where cookies are stored. session cookies exist until the Data Subject closes their browser. persistent cookies have a longer life cycle and are not automatically deleted when the browser is closed.

3.2. cookies cannot run programs or transmit viruses to the Data Subject’s computer (device). when using the services, cookies and other tracking technologies may be used to support operation of the Website, analyze traffic, or for advertising purposes. these technologies are used either directly by the Company or by the Company’s partners, including third-party service providers and advertising platforms with which the Company cooperates.

3.3. in addition to cookies, other similar tracking technologies (pixels) are used, which may also track url addresses or software development tools.

3.4. the above technologies and cookies are used:

  • to track Data Subject behavior and obtain information about Website usage in order to improve content;
  • to identify the Data Subject on Website pages and on other websites. the information collected includes, among other things: ip address, device identification number, pages viewed, browser type, information about searches performed through the browser, operating system, internet service provider, click timestamp, whether the Data Subject responded to an advertisement, the relevant url address, features used on the page/in the application, or actions taken;
  • when technical cookies are used: to ensure proper and uninterrupted operation of the Website and to provide the Data Subject with the ability to create and manage an account;
  • to remember the Data Subject’s data (when logging in) and preferences;
  • for analytics and analysis of the effectiveness of the Website, advertising campaigns, and informational materials. for this purpose, the Company collects information about which pages the Data Subject visited and left, all actions on the Website, as well as on third-party websites where the Company’s advertising is placed;
  • to use third-party and the Company’s own cookies to display advertisements on the Company’s Website and on other websites/platforms (retargeting).


3.5. the Data Subject may delete cookies at any time by going to the security settings of their browser and selecting “delete cookies” or configure browser settings according to personal preferences. however, this may mean that the Website’s functionality will be limited.

  1. purposes of collection and processing of the Data Subject’s personal information


4.1. the Company collects and stores only those personal data that are necessary to provide access to the Website and to publish reviews.

4.2. the Company may use the Data Subject’s personal information for the following purposes:

  • identification of a party;
  • providing the Data Subject with personalized services and performance by the Company of its obligations to the Data Subject under agreements between the Company and the Data Subject;
  • contacting the Data Subject when necessary, including sending notifications, requests, and information related to use of the services;
  • determining the Data Subject’s location to ensure security and prevent fraud;
  • confirming the accuracy and completeness of personal data provided by the Data Subject;
  • sending informational and advertising messages;
  • improving service quality and usability, and developing new services;
  • targeting advertising materials;
  • conducting statistical and other research based on anonymized data;
  • providing customer and technical support to the Data Subject in case of issues related to the Website;
  • providing the Data Subject with access to partner websites or services in order to obtain or update Website services and/or publish reviews.


4.3. the Data Subject consents to receive newsletters and promotional materials from the Company, or from other persons acting on behalf of the Company, to the email address provided by the Data Subject upon authorization on the Website.

4.4. the Company may conduct statistical and other research based on anonymized information provided by the Data Subject. the Company may provide access to such research to third parties for advertising targeting purposes. by accepting this Policy, the Data Subject consents to such research and to receiving targeted advertising. the Data Subject may withdraw such consent at any time by contacting the Company using the email address indicated on the Website. the Data Subject may also, if technically possible on the Data Subject’s device or within software on the Data Subject’s device, prohibit the device or software from transmitting information through the Website that is necessary for advertising targeting.

  1. conditions for processing the Data Subject’s personal information and its transfer to third parties


5.1. the Company processes the Data Subject’s personal data using databases located within the territory of the russian federation.

5.2. personal data are processed using automated systems.

5.3. processing of the Data Subject’s personal data includes the following actions by the Company: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction.

5.4. the Data Subject’s personal data are stored on electronic media. when processing personal data to perform obligations under agreements with the Data Subject, the Company may retrieve personal data and store them on physical media. such personal data are stored for the period established by the legislation of the russian federation on education and archiving.

5.5. the confidentiality of the Data Subject’s personal information is maintained, except where the Data Subject voluntarily provides information about themselves for public access to an unlimited number of persons. when using certain services, the Data Subject agrees that a certain part of their personal information becomes publicly available.

5.6. the Company may transfer the Data Subject’s personal information to third parties in the following cases:

  • the Data Subject has explicitly consented to such actions. in this case, the Data Subject agrees that the Company may transfer personal data to third parties (partners) in order to fulfill obligations under the agreement concluded with the Data Subject;
  • the transfer is necessary within the framework of the Data Subject’s use of a specific service, use of the Website, or provision of a service to the Data Subject. confidentiality of personal information is ensured, and the Data Subject will be explicitly notified of such transfer;
  • the transfer is provided for by russian law or other applicable law within the procedure established by law;
  • the transfer occurs as part of a sale or other transfer of the business (in whole or in part), in which case all obligations to comply with this Policy with respect to the received personal information pass to the acquirer;
  • for the purpose of enabling protection of the rights and legitimate interests of the Company or third parties in cases where the Data Subject violates the Website rules.


5.7. the Data Subject’s personal data are processed no longer than required to achieve the purposes set out herein.

  1. modification of personal information by the Data Subject; Data Subject rights


6.1. the Data Subject may at any time change (update, supplement, delete) the personal information provided by them or part of it, as well as its confidentiality settings. the Data Subject understands that the Company may continue to use such information in cases permitted by russian law.

deletion of information may result in inability to use certain Website services.

6.2. by publishing information about themselves, the Data Subject may make it publicly available. the Data Subject understands that such information may be indexed by search engines and accepts the related risks of disclosure of information that may constitute personal, family, or other confidentiality.

6.3. consent to receive newsletters and promotional materials may be withdrawn by the Data Subject at any time by sending the Company a relevant notice to the email address indicated on the Website.

6.4. the Data Subject has the right to obtain from the Company information relating to the processing of their personal data, if such right is not limited under federal laws. the Data Subject may require the Company to rectify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and may take measures provided by law to protect their rights. to do so, it is sufficient to notify the Company using the email address indicated on the Website.

  1. measures to protect the Data Subject’s personal information


7.1. the Company takes necessary and sufficient organizational and technical measures to protect the Data Subject’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, dissemination, and other unlawful actions by third parties.

7.2. the Company guarantees that the information provided by the Data Subject is not combined with statistical data, is not provided to third parties, and is not disclosed, except as provided in this Policy.

7.3. the Company does not sell or transfer information about the Data Subject as a separate asset. such information may be transferred only in the event of partial or full reorganization of the Company.

7.4. the Company blocks personal data relating to the relevant Data Subject from the moment of the Data Subject’s request (or a request from their lawful representative or an authorized body for protection of personal data subject rights) for the period of verification, in case inaccurate personal data or unlawful actions are identified.

  1. amendments to the privacy policy


8.1. the Company has the right to amend this Privacy Policy. the new version of the Policy enters into force from the moment it is published on the Website, unless otherwise provided by the new version of the Policy. the current version is always available at:
https://mutovin.ru/docs/politika-konfidencialnosti_eng/

8.2. russian federation law applies to relations between the Data Subject and the Company arising in connection with application of this Privacy Policy.

  1. feedback. questions and suggestions


any suggestions and questions regarding this Policy should be sent to the Company using the email address indicated on the Website.