Policy on personal data processing

2.1. Automated processing of personal data - processing of personal data by means of computer equipment.

2.2. Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).

2.3. Website - a set of graphic and informational materials, as well as computer programmes and databases ensuring their availability on the Internet at the network address https://cleverpumpkin.ru/en/

2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Impersonalisation of personal data - actions, as a result of which it is impossible to determine without using additional information whether personal data belong to a particular User or other subject of personal data.

2.6. 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 (update, change), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data.

2.7. Operator - a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organising and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. Personal Data - any information relating directly or indirectly to a specific or identifiable User of https://cleverpumpkin.ru/en/.

2.9. Personal data authorised by the subject of personal data for dissemination - personal data to which access to an unlimited number of persons is granted by the subject of personal data by giving consent to the processing of personal data authorised by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data authorised for dissemination).

2.10. User - any visitor of the website https://cleverpumpkin.ru/en/.

2.11. Provision of personal data - any actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or at familiarisation of personal data to an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed.

3.1. The Operator shall have the right to:

- to receive from the subject of personal data reliable information and/or documents containing personal data;

- in case the subject of personal data withdraws consent to personal data processing, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;

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

3.2. The Operator shall:

- provide the personal data subject, upon his/her request, with information regarding the processing of his/her personal data;

- organise the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

- respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on personal data;

- report to the authorised body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request;

- publish or otherwise provide unrestricted access to this Policy on personal data processing;

- take legal, organisational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with regard to personal data;

- cease transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Personal Data Law;

- fulfil other obligations stipulated by the Personal Data Law.

4.1. Personal data subjects have the right to:

- to receive information regarding the processing of his/her personal data, except for cases stipulated by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;

- to demand from the operator to clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his rights;

- to impose a condition of prior consent when processing personal data in order to market goods, works and services;

- to withdraw consent to the processing of personal data;

- to appeal to the authorised body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of his/her personal data;

- to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

- provide the Operator with reliable data about themselves;

- notify the Operator about clarification (update, change) of their personal data.

4.3. Persons who provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter shall be held liable in accordance with the legislation of the Russian Federation.

5.1. Surname, first name, patronymic.

5.2. E-mail address.

5.3. Telephone numbers.

5.4. Company.

5.5. The website also collects and processes anonymised visitor data (including cookies) such as IP address, geolocation (if enabled), browser and device type, information about actions on the website, referrers and other technical metadata using Internet statistics services (e.g. Yandex.Metric).

5.6. The aforementioned data is hereinafter in the text of the Policy united by the general term Personal Data.

5.7. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life.

5.8. Processing of personal data authorised for dissemination from among the special categories of personal data specified in Article 10.1 of the Personal Data Law is allowed if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are complied with.

5.9. The User's consent to the processing of personal data authorised for dissemination is executed separately from other consents to the processing of his/her personal data. The conditions stipulated in particular in Article 10.1 of the Law on Personal Data shall be observed. The requirements for the content of such consent shall be established by the authority authorised to protect the rights of personal data subjects.

5.9.1. Consent to the processing of personal data authorised for dissemination is provided by the User directly to the Operator.

5.9.2. The Operator is obliged to publish information on the conditions of processing, prohibitions and conditions for processing by an unlimited number of persons of personal data authorised for dissemination within three working days from the date of receipt of the said consent of the User.

5.9.3. The transfer (dissemination, provision, access) of personal data authorised by the subject of personal data for dissemination shall be terminated at any time at the request of the subject of personal data. This request shall include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be stopped. The personal data specified in this request may be processed only by the Operator to whom it is sent.

5.9.4. Consent to the processing of personal data authorised for dissemination terminates upon receipt by the Operator of the request specified in clause 5.9.3 of this Policy on Personal Data Processing.

6.1 The processing of personal data shall be carried out on a lawful and fair basis.

6.2 The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

6.3 It is not allowed to merge databases containing personal data processed for incompatible purposes.

6.4 Only personal data that meet the purposes for which they are processed shall be processed.

6.5 The content and scope of processed personal data correspond to the stated purposes of processing. The processed personal data may not be redundant in relation to the stated purposes of their processing.

6.6 When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.

6.7 Storage of personal data is carried out in a form that allows to identify the subject of personal data, not longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or anonymised when the purposes of processing have been achieved or when it is no longer necessary to achieve these purposes, unless otherwise provided for by federal law.

7.1. Purpose of processing the User's personal data:

- Processing of requests via feedback forms on the website.
Categories and list of processed personal data: surname, first name, patronymic; e-mail address; telephone number; information collected through metric programmes; user name in Telegram; place of work (company name).

- Conclusion and execution of contracts.
Categories and list of processed personal data: surname, first name, patronymic; year of birth; month of birth; date of birth; e-mail address; address of residence; address of registration; telephone number; SNILS; TIN; personal identification document data; bank card details; current account number; personal account number.

- Sending information and advertising materials.
Categories and list of processed personal data: surname, first name, patronymic; e-mail address; telephone number; Telegram username.

- Maintaining internal statistics and analyses of the site.
Categories and list of processed personal data: information collected through metric programmes.

7.2. The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive information messages by sending a letter to the Operator to the e-mail address company@cleverpumpkin.ru with the note ‘Refusal of notifications about new products and services and special offers’.

7.3. The User's anonymised data collected through Internet statistics services serve to collect information about the User's activities on the website, to improve the quality of the website and its content.

8.1. The legal basis for the processing of personal data by the Operator is:

- Constitution of the Russian Federation;

- Federal Law dated 27.07.2006 No. 149-FZ ‘On Information, Information Technologies and Information Protection’;

- Federal Law No. 152-FZ dated 27.07.2006 ‘On Personal Data’;

- Resolution of the Government of the Russian Federation No. 1119 dated 01.11.2012 ‘On Approval of Requirements for the Protection of Personal Data when Processing in Personal Data Information Systems’;

- Resolution of the Government of the Russian Federation No. 687 dated 15.09.2008 ‘On Approval of the Regulation on Peculiarities of Personal Data Processing Performed Without the Use of Automation Means’;

- Order of the Federal Service for Technical and Export Control of Russia No. 21 dated 18.02.2013 ‘On Approval of the Composition and Content of Organisational and Technical Measures to Ensure Security of Personal Data when Processing in Personal Data Information Systems’;

- Operator's local regulatory acts. If necessary, the Operator provides the User with the above documents;

- Agreements concluded between the Operator and the User;

- Consent to the processing of personal data given under the terms of this Policy.

8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User himself/herself via special forms located on the website https://cleverpumpkin.ru/en/ or sent to the Operator via e-mail. By filling in the relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to this Policy.

8.3. The Operator processes anonymised data about the User if this is allowed in the User's browser settings (cookies and JavaScript technology enabled).

8.4. The subject of personal data independently decides on the provision of his/her personal data and gives his/her consent freely, of his/her own free will and in his/her own interest.

9.1. Processing of personal data shall be carried out with the consent of the personal data subject to the processing of his/her personal data.

9.2. The processing of personal data is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or by law, to fulfil the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.

9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially important goals, provided that the rights and freedoms of the personal data subject are not violated.

9.6. Processing of personal data to which the personal data subject or at his/her request (hereinafter referred to as publicly available personal data) has unrestricted access is carried out.

9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

The security of personal data processed by the Operator is ensured by implementing legal, organisational and technical measures necessary for full compliance with the requirements of the applicable legislation in the field of personal data protection.

10.1. The Operator shall ensure safety of personal data and take all possible measures to exclude access to personal data by unauthorised persons.

10.1.1. Processing of personal data is carried out using both automated and non-automated methods.

10.2. The User's personal data will never, under no circumstances, be transferred to third parties, except in cases related to the execution of the current legislation or if the subject of personal data has given consent to the Operator to transfer the data to a third party to fulfil obligations under a civil law contract. For example, data may be transferred to Yandex LLC (TIN 7704358519, address: 16, Lev Tolstoy St., Moscow, 119021) as part of the Yandex.Metric service. Data is not transferred outside the Russian Federation.

10.3. If any inaccuracies in the personal data are identified, the User may update them independently by sending a notice to the Operator to the Operator's e-mail address company@cleverpumpkin.ru with the note ‘Personal Data Update’.

10.4. The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another term is stipulated by the agreement or the applicable law. The term of validity of the consent is until the purposes of processing are achieved or until revocation by the subject of personal data.

The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address company@cleverpumpkin.ru, labelled ‘Withdrawal of consent to the processing of personal data’.

10.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or User is obliged to familiarise himself/herself with the said documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. The prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorised for dissemination shall not apply in cases of personal data processing in the state, public and other public interests defined by the legislation of the Russian Federation.

10.7. The Operator shall ensure confidentiality of personal data when processing personal data.

10.8. The Operator shall store personal data in a form that allows to identify the subject of personal data for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.

10.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiry of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as detection of unlawful processing of personal data.

11.1. The User has the right to withdraw consent to the processing of personal data at any time by sending a message to the e-mail address company@cleverpumpkin.ru labelled ‘withdrawal of consent to the processing of personal data’. Withdrawal of consent to the processing of personal data entails the complete deletion of all personal data of the User in the processing and storage systems, which makes it impossible to provide paid and free opportunities/use of the Site.

11.2. The Operator is obliged to stop processing the personal data within a period not exceeding ten working days from the date of receipt by the Operator of the withdrawal of consent. The said term may be extended, but not more than for five working days in case the Operator sends a motivated notice to the personal data subject indicating the reasons for extending the term for providing the requested information.

11.3. Upon achievement of the purposes of personal data processing, as well as in case of withdrawal of consent to processing by the subject of personal data, personal data shall be destroyed, unless otherwise provided for by the contract to which the subject of personal data is a party, beneficiary or guarantor. Destruction or depersonalisation of a part of personal data, if it is allowed by the material medium, may be performed in a way that excludes further processing of such personal data, while preserving the possibility of processing other data recorded on the material medium (deletion, erasure). Personal data stored in the computer memory shall be destroyed by deleting it from the computer memory. PDs placed on a flash card, CD disc or other information carrier shall be destroyed by deleting the file from the carrier and, if necessary, by disabling the flash card or CD disc. An Act shall be drawn up on the destruction of the data medium.

11.4. Confirmation of the fact of personal data processing by the Operator, legal grounds and purposes of personal data processing, as well as other information specified in part 7 of Article 14 of the Law on Personal Data shall be provided by the Operator to the personal data subject or his/her representative upon application or upon receipt of a request from the personal data subject or his/her representative.

1.5. The information provided does not include personal data relating to other data subjects, except where there are legitimate grounds for disclosing such personal data.

11.6. The request must contain:
the number of the main document certifying the identity of the personal data subject or his representative, information about the date of issue of the specified document and the issuing authority;
information confirming the personal data subject's relationship with the Operator, or information otherwise confirming the fact of personal data processing by the Operator;
the signature of the personal data subject or their representative.

11.6.1. The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.

11.6.2. If the request of the personal data subject does not contain all the necessary information in accordance with the requirements of the Personal Data Law, or if the subject does not have the right to access the requested information, a reasoned refusal shall be sent to them.

11.7. The information shall be provided to the personal data subject or their representative by the Operator within ten working days from the date of the request or receipt by the Operator of the request from the personal data subject or their representative. This period may be extended, but not by more than five working days, if the Operator sends a reasoned notification to the personal data subject indicating the reasons for the extension of the period for providing the requested information.

11.8. The right of the data subject to access their personal data may be restricted in accordance with Part 8 of Article 14 of the Personal Data Law, including if the data subject's access to their personal data violates the rights and legitimate interests of third parties.

11.9. In the event of the discovery of inaccurate personal data when the subject of personal data or his representative applies, either at their request or at the request of Roskomnadzor, the Operator shall block the personal data relating to that subject of personal data from the moment of such a request or receipt of the specified request for the period of verification, if the blocking of personal data does not violate the rights and legitimate interests of the personal data subject or third parties.

11.10. If the inaccuracy of personal data is confirmed, the Operator shall, on the basis of information provided by the personal data subject or his representative or Roskomnadzor, or other necessary documents, clarify the personal data within 7 (seven) working days from the date of submission of such information and unblock the personal data.

11.11. In the event of the detection of unlawful processing of personal data upon the request of the personal data subject or his representative or Roskomnadzor, the Operator shall block the unlawfully processed personal data relating to that personal data subject from the moment of such request or receipt of the request.

12.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), anonymises, blocks, deletes and destroys personal data.

12.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the information received via information and telecommunications networks or without such networks.

Personal data is not transferred outside the Russian Federation.

The Operator and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

15.1. The user may obtain any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator by email at company@cleverpumpkin.ru.

15.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

15.3. The current version of the Policy is freely available on the Internet at https://cleverpumpkin.ru/en/privacy/.

The website uses cookies and similar technologies necessary for the proper functioning of the website, analysis of user behaviour and provision of personalised services. Cookies can be disabled by the user in their browser settings. Consent to the use of cookies is requested on the first visit to the website.

Clever Pumpkin LLC
Taxpayer Identification Number (INN) 7814503704
Primary State Registration Number (OGRN): 1117847246615
Legal address: 197374, Saint Petersburg, Savushkina Street, 83, building 3 A
Email: company@cleverpumpkin.ru
Phone: +7 (812) 628-53-74

To withdraw previously given consent to the processing of personal data, the user may send a corresponding request to the specified email address.

In case of discrepancy, the Russian version shall prevail