PRIVACY POLICY

This privacy policy (hereinafter referred to as the "Policy") was developed by the ITGEMS Limited Liability Company (TIN 9718104348, address: 125319, Moscow, CHERNYAKHOVSKOGO STR., 16, OFFICE 1307) and determines the procedure for processing information about physical and / or a legal entity (hereinafter referred to as the "User"), which ITGEMS LLC may receive as a result of the use of the itgems.org website by such a person on the Internet (hereinafter referred to as the "Site"), as well as in other cases provided for by this Policy.

1. GENERAL PROVISIONS

1.1. This Policy has been developed in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data". The terms used in the Policy have the same meaning in which they are used in the provisions of the said Federal Law.

1.2. Use of the Site means the unconditional consent of the User with this Policy and the conditions for processing his personal data specified therein; in case of disagreement with these conditions, the User must refrain from using the Site.

1.3. The provisions of the Policy apply to the following information about the User:

1.3.1. Information that the User provides about himself independently in the process of using the Site (including when registering (creating a personal account) on the Site) or the processing of which is due to the fulfillment of ITGEMS LLC obligations arising from the conclusion of agreements with the User in the process of using the Site ... In cases where the provision by the User of information about himself is necessary, this is specially negotiated with the provision of the User with the opportunity to explicitly express consent to the processing of information in an appropriate way using the functionality of the Site.

1.3.2. Data that is automatically processed by the software of the Site in the course of its use, including the IP address, cookie data, information about the User's browser (or other program through which the Site is accessed), technical characteristics of the hardware and software used By the User, the date and time of access to the Site, the addresses of the requested pages and other similar information.

1.3.3. Data directly authorized by the User for distribution (disclosure of personal data to an indefinite circle of persons).

1.4. This Policy applies only to the Site. ITGEMS LLC does not control and is not responsible for third-party sites to which the User can click on the links available on the Site.

2. PURPOSE OF PROCESSING PERSONAL DATA OF USERS

2.1. ITGEMS LLC collects and stores only that information about the User that is necessary to provide the services of the Site or to fulfill obligations to the User that arose in connection with the conclusion of any contracts by the parties in the process of using the Site.

2.2. ITGEMS LLC processes information about the User for the following purposes:

- identification of the User registered on the Site in order to provide an opportunity to order services (work) provided (performed) by ITGEMS LLC.

- providing the User with access to the personalized resources of the Site;

- fulfillment of contractual obligations of ITGEMS LLC to the User;

- establishing feedback with the User, including sending notifications, requests regarding the use of the Site, the provision of services, processing requests and applications from the User;

- determining the location of the User to ensure security and prevent fraud;

- confirmation of the accuracy and completeness of the information provided by the User;

- notifications of the Site User about marketing events and promotions carried out by ITGEMS LLC;

- providing the User with effective customer and technical support in the event of problems related to the use of the Site;

- conducting statistical and other studies based on anonymized data;

- carrying out advertising activities with the consent of the User.

3. TERMS OF PROCESSING OF USERS 'PERSONAL DATA AND THEIR TRANSFER TO THIRD PARTIES

3.1. The processing of the User's personal data includes the following actions: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction.

3.2. In cases where the provision of information about the User (personal data) is necessary in order to use the services of the Site and / or the performance of ITGEMS LLC of its obligations, the User agrees to the processing of the information provided by him by putting a mark in the appropriate electronic form of the Site, if another way of obtaining the consent of the User is not provided for by law, this Policy or the agreement concluded by the parties.

3.3. The site uses cookies to improve the usability, in particular to customize the content of the site in accordance with the personal preferences of the User, to collect statistics. The user accepts or refuses the condition on the use of cookies by the Site at the time of entering the Site. By accepting the relevant condition and not blocking cookies in the browser, the User agrees to their use and storage in the memory of the device with which he accesses the Site. At the same time, the user acknowledges that blocking cookies may negatively affect the functionality of the Site. The user has the right at any time to independently change the browser settings in such a way as to resume, block or restrict the storage of cookies.

3.4. Consent to the processing of personal data allowed by the User for distribution (disclosure to an indefinite circle of persons) is drawn up separately from other User's consents to the processing of his personal data. With the help of the software of the Site, the User is given the opportunity to determine the list of personal data for each category of personal data specified in the corresponding consent, allowed by the User for distribution. The transfer (distribution, provision, access) of personal data authorized by the User for distribution is terminated at any time at the request of the User.

3.5. To protect personal data, ensure their proper use and prevent unauthorized or accidental access to them, ITGEMS LLC applies technical and administrative measures. The information provided by the Users is stored on servers with limited access located on the territory of the Russian Federation.

3.6. ITGEMS LLC has the right to provide access to information about the User to third parties in the following cases:

- The user has clearly and unambiguously expressed his consent to the dissemination of personal data;

- access is required for the purpose of using a certain service of the Site by the User or for the performance of ITGEMS LLC obligations to the User established by the contract;

- in cases stipulated by applicable law and within the framework of the procedure established by such legislation;

- in case of transfer of rights to the Site to a third party. In this case, the purchaser of the Site passes all obligations to comply with the terms of this Policy in relation to the information about the Users received by him.

3.7. The processing of the User's personal data is carried out in accordance with the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" for an unlimited period of time in any legal way, including in personal data information systems using automation tools or without using such tools.

3.8. In case of loss or disclosure of personal data, ITGEMS LLC informs the User about the loss or disclosure of such information.

3.9. The Site Administration takes the necessary organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

3.10. The Site Administration together with the User takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

4. OBLIGATIONS OF THE PARTIES

4.1. The user undertakes:

4.1.1. Provide reliable personal data in the amount necessary for using the Site and for the fulfillment of the obligations assumed by ITGEMS LLC in the performance of contracts concluded with the User in the process of using the Site.

4.1.2. Update, supplement the information provided in case of its change.

4.2. LLC "ITGEMS" undertakes:

4.2.1. Use the information received from the User solely for the purposes specified in this Privacy Policy.

4.2.2. Ensure that information about the User is kept secret, not disclosed without the prior written permission of the User, and also not to sell, exchange, publish or disclose in other possible ways the transferred personal data of the User, except as provided for in this Policy.

4.2.3. Take all possible measures to protect personal data.

4.2.4. Block personal data related to the relevant User from the moment the User or his legal representative or the authorized body for the protection of the rights of personal data subjects apply or request for the verification period in case of revealing inaccurate personal data or illegal actions.

5. RESPONSIBILITY OF THE PARTIES

5.1. ITGEMS LLC bears responsibility for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation of the Russian Federation.

5.2. ITGEMS LLC is not responsible for the loss or disclosure of personal data if this information:

- became widely known before its loss or disclosure;

- was received from third parties prior to its receipt by ITGEMS LLC;

- was disclosed with the consent of the User, given explicitly and unambiguously.

6. FINAL PROVISIONS

6.1. Disputes and disagreements between the Parties that may arise in the process of applying this Policy will be resolved through negotiations. If it is impossible to resolve disputes and disagreements through negotiations, such disputes and disagreements are subject to resolution in court in accordance with the legislation of the Russian Federation.

6.2. ITGEMS LLC has the right to make changes to this Policy without the consent and notification of the User. Changes come into force from the moment the new edition of the privacy policy is posted on the Site.

6.3. The legislation of the Russian Federation applies to this Privacy Policy and the relationship between the User and ITGEMS LLC.

6.4. All suggestions or questions about this Privacy Policy are sent to the technical support service of ITGEMS LLC at the e-mail address indicated on the Website.

Date of posting of the current edition of the Privacy Policy on the Website: October 01, 2021