Approved

By the Order of LLC “Concordia”

№8 dated 02.05.2023

POLICY OF LLC “Concordia” REGARDING THE PROCESSING OF PERSONAL DATA ON THE WEBSITE

This Policy of LLC “Concordia” (hereinafter referred to as the Operator) regarding the processing of personal data (hereinafter referred to as the Policy) is an integral part of the public offer – the User Agreement, posted on the website in the information and telecommunication network Internet at the address: https://concordiyaelectro.rf (hereinafter referred to as the Website).

The use of the Website’s services signifies the unconditional consent of the user: a person visiting the Website on the Internet (hereinafter referred to as the User) to this Policy and the terms of personal data processing specified in it; in case of disagreement with these terms, the User must refrain from using the services and leave the Website.

1. General Provisions

1.1. For the purposes of this Policy, the User’s personal data is understood as:

1.1.1. Personal information – any information relating directly or indirectly to an identified or identifiable individual that the User provides about themselves independently during registration (creation of an account) or while using the Website’s services. Information required for service provision is specially marked.

1.1.2. Data automatically transmitted to the Website's services in the process of their use via the software installed on the User’s device, including IP address, cookie data, User’s browser information (or other software used to access the services), technical specifications of the User’s hardware and software, date and time of service access, addresses of requested pages, and other similar information.

1.2. Processing of personal data means any action (operation) or a set of actions (operations) performed with personal data, using automation tools or without such tools.

1.3. This Privacy Policy applies only to the Website. The Website Operator does not control and is not responsible for third-party websites, which the User may access through links available on the Website.

2. Purposes of Collecting and Processing Users’ Personal Data

2.1. The Website Operator collects and stores only the personal information necessary to provide services or fulfill agreements and contracts with the User, except in cases where legislation requires mandatory storage of personal information for a specified period.

In case the User notifies the Website of the withdrawal of consent to personal data processing, the Website ceases processing the User’s personal data within a period not exceeding 10 business days from receipt, unless otherwise specified by applicable regulations.

A notification of withdrawal of consent to process personal data should be sent to the email address: This email address is being protected from spambots. You need JavaScript enabled to view it., posted as a corresponding withdrawal on the Website, or submitted in writing to the legal address: 141800, Moscow Region, Dmitrov City, Professional Street, Building 1a, Apartment 406.

2.2. The Website processes User’s personal data for the following purposes:

2.2.1. Identifying the User registered on the Website for selling goods to them.

2.2.2. Providing the User access to personalized resources on the Website, including searching for goods for purchase.

2.2.3. Establishing feedback with the User, including sending notifications, requests regarding Website use, service provision, and processing requests and applications from the User.

2.2.4. Determining the User’s location to ensure security and prevent fraud.

2.2.5. Verifying the accuracy and completeness of personal data provided by the User.

2.2.6. Creating an account for a personal User Account if the User agrees to create one.

2.2.7. Notifying the User about new goods, promotions, and other advertising information.

2.2.8. Providing the User with effective client and technical support in case of issues related to Website use.

2.2.9. Conducting advertising activities with the User’s consent.

2.2.10. Selling goods and providing other services to the User.

3. Legal Grounds for Personal Data Processing

3.1. The Operator processes personal data based on and in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006 (hereinafter referred to as the Personal Data Law), other federal laws, regulations adopted under these laws, the Operator’s foundational and local regulations, the User’s consent to process their personal data, as well as in cases specified by the laws of the Russian Federation without such consent.

4. Scope and Categories of Processed Personal Data, Categories of Personal Data Subjects

4.1. The Operator may process personal data of the following categories of Users:

4.1.1. Clients and contractors of the Operator (individuals) for the purpose of conducting business activities in accordance with the Operator’s charter:

• Last name, first name, patronymic;
• Date and place of birth;
• Passport details;
• Residential registration address;
• Contact details;
• Job title;
• Taxpayer identification number;
• Bank account number;
• Other personal data provided by clients and contractors necessary for contract conclusion and execution.

...

4.1.2. Representatives (employees) of the Operator’s clients and contractors (legal entities) for the purpose of conducting business activities in accordance with the Operator’s charter:

• Last name, first name, patronymic;
• Passport details;
• Contact details;
• Job title;
• Other personal data provided by representatives (employees) of clients and contractors necessary for contract conclusion and execution.

5. Procedure and Conditions for Processing Users’ Personal Data and Its Transfer to Third Parties

5.1. The Operator stores Users’ personal data in accordance with the internal regulations of specific services.

5.2. Users’ personal data is kept confidential, except in cases of voluntary provision of information by the User for general access to an unlimited number of persons. By using certain services, the User agrees that a certain part of their personal information becomes publicly available.

5.3. The Website may transfer the User’s personal information to third parties in the following cases:

5.3.1. The User has expressed their consent to such actions.

5.3.2. The transfer is necessary for the User to use a specific service or to fulfill a specific agreement or contract with the User.

5.3.4. The transfer is provided for by Russian or other applicable legislation within the established legal procedure.

5.3.5. In the event of the sale of the Website, all obligations to comply with the terms of this Policy concerning the received personal information are transferred to the purchaser.

5.4. Processing of the User’s personal data is carried out without time limitation in the following ways: collection, recording, systematization, accumulation, storage, updating (modification), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data, including in personal data information systems using automation tools or without such tools. The processing of Users’ personal data is carried out in accordance with the Personal Data Law.

5.5. In case of loss or disclosure of personal data, the Operator informs the User of the loss or disclosure of personal data.

5.6. The Website Operator takes necessary organizational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions by third parties.

5.7. The Website Operator, 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.

6. Obligations of the Parties

6.1. The User is obliged to:

6.1.1. Provide information about personal data necessary for using the Website.

6.1.2. Update and supplement the provided personal data information in case of changes.

6.2. The Operator is obliged to:

6.2.1. Use the received information solely for the purposes specified in this Policy.

6.2.2. Ensure the confidentiality of confidential information, not disclose it without the prior written consent of the User, and not sell, exchange, publish, or disclose the User’s transmitted personal data by other possible means, except as provided for in this Policy.

6.2.3. Take necessary legal, organizational, and technical measures to protect the User’s personal data from unauthorized or unlawful access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions.

6.2.4. Block personal data related to the relevant User from the moment of the User’s request or inquiry or their legal representative or authorized body for the protection of the rights of personal data subjects during the verification period in case of detecting inaccurate personal data or unlawful actions.

6.2.5. Respond to inquiries and requests from Users in accordance with the requirements of the Personal Data Law.

7. Updating, Correcting, Deleting, and Destroying Personal Data; Responses to Subject Requests for Access to Personal Data

7.1. In case of confirmation of the inaccuracy of personal data or unlawful processing, the personal data must be updated by the Operator, and its processing must be terminated.

7.2. Upon achieving the purposes of processing personal data or in case the User withdraws consent for its processing, personal data must be destroyed unless:

• Otherwise provided for by an agreement in which the User is a party, beneficiary, or guarantor;
• The Operator is not entitled to process the data without the User's consent as stipulated by the Personal Data Law or other federal laws;
• Otherwise provided for by other agreements between the Operator and the User.

7.3. The Operator is obliged to provide the User with information about the processing of their personal data upon their request.

7.4. The request must include:

• The primary identification document number, information on the date of its issuance, and the issuing authority;
• Information confirming the User’s participation in relations with the Operator (contract number, contract date, verbal designation, or other information), or other information confirming the fact of processing personal data by the Operator;
• The User's signature.

8. Liability of the Parties

8.1. The Operator, failing to fulfill its obligations, is liable for losses incurred by the User due to the unlawful use of personal data in accordance with Russian Federation legislation.

8.2. In case of loss or disclosure of confidential information, the Operator is not liable if this confidential information:

8.2.1. Became public domain before its loss or disclosure.

8.2.2. Was received from a third party prior to its receipt by the Website Operator.

8.2.3. Was disclosed with the User’s consent.

9. Dispute Resolution

9.1. Before going to court with a claim on disputes arising from relations between the Website User and the Website Operator, it is mandatory to submit a claim (a written proposal for voluntary dispute resolution).

9.2. The recipient of the claim must notify the claimant in writing of the results of the claim review within 30 calendar days from the date of its receipt.

9.3. If no agreement is reached, the dispute will be referred to the court (arbitration court) at the Operator’s location in accordance with the current legislation of the Russian Federation.

9.4. This Privacy Policy and relations between the User and the Website Operator are governed by the current legislation of the Russian Federation.

10. Additional Conditions

10.1. The Website Operator may amend this Policy without the User's consent.

10.2. The new Policy comes into force from the moment it is posted on the Website unless otherwise provided by the new edition of the Policy.

10.3. All suggestions or questions regarding this Privacy Policy should be reported to the email address: This email address is being protected from spambots. You need JavaScript enabled to view it. or submitted as feedback on the Website.

10.4. This Privacy Policy is an integral part of the Public Offer – User Agreement, posted on the Website.