WEBSITE

USE AGREEMENT

(USER AGREEMENT)



This Agreement (hereinafter referred to as the Agreement) is a public offer of SanPorto LLC (OGRN 1217700255410, TIN 9703036141) (hereinafter referred to as the Administration) in accordance with Art. 437 of the Civil Code of the Russian Federation, is addressed to any capable person who filled out the feedback form on any page of the Website on the Internet at the address: www.sanporto.net (hereinafter referred to as the Website).

  1. Subject of the Agreement
1.1 The Administration provides the User with access to the materials on the Website and to the Administration's mailing list. The User gets the right to get familiarized with the Website materials and the Administration's mailing list in accordance with the Agreement.

1.2. The Agreement is free of charge, the Administration provides the User with information in order to provoke the User's interest to order the services of the Administration, its partners, cooperation or participation in events arranged by them.

2. Agreement Procedures

2.1. The User of the Website consciously and voluntarily fills out an application (feedback form) on the Website and submits it to the Administration through the user interface of the Website (button in the feedback form) to contact the Administration for the purposes specified in cl. 2.4 of the Agreement.

2.2. By submitting the application, the User accedes to the Agreement, provides its consent to processing of his/her personal data by the Administration in accordance with the personal data processing policy (offer acceptance).

2.3. Upon the application receipt, the Administration processes it.

2.4. Upon the application receipt, the Website Administration is entitled to contact the User through the communication channels specified by him/her (e-mail address, phone number) for purposes that do not contradict the legislation of the Russian Federation, in particular, but not limited to:

2.4.1. To provide the User with the information related to the Administration's activity area, the services provided, the goods offered and to announce the activities of the Administration and its partners.

2.4.2. To inform on the procedure for taking up the Administration's vacant positions and on the results of the job application form review.

2.5. The User is not entitled to send the application to the Administration for the purpose of offering his/her goods or services.

2.6. The User can unsubscribe at any time by sending a notification to the Administration.

3. Liability of the Parties

3.1. The Administration is not responsible for the presence of errors and/or computer viruses or extraneous code snippets on the Website.

3.2. The Administration does not bear any responsibility for any damage, lost profit or any indirect losses incurred by the User when submitting the application, including in the event of a malfunction of the User's other software.

3.3. The User agrees that the Administration does not bear any responsibility and has no obligations in connection with the advertising that may be placed on the Website.

3.4. The User's personal data shall be processed in accordance with the current legislation of the Russian Federation and with the personal data processing policy placed on the Website and obligatorily presented to the User prior to submitting the application on the Website.

3.5. Neither Party shall be liable for full or partial failure to fulfill any of its obligations if the failure is the result of such circumstances as flood, fire, earthquake, other natural disasters, war or military actions and other force majeure circumstances arising from the conclusion of the Agreement and being beyond the control of the Parties.

3.6. Disputes between the Parties related to the execution of the Agreement shall be resolved by the mediation procedure or negotiation. The pre-trial dispute settlement procedure is mandatory. Claims shall be sent to e-mail addresses.

3.7. The party that received a claim or an invitation to the mediation procedure is obliged to respond to it within 20 (twenty) days.

3.8. In the event that the dispute is not settled within the pre-trial process, the dispute is subject to consideration in the Moscow Arbitration Court or in a court of general jurisdiction in accordance with the civil procedure law of the Russian Federation.

4. Final Provisions

4.1. The legislation of the Russian Federation applies to all unsettled issues of legal relations arising from the Agreement.

4.2. The User is obliged to familiarize himself/herself with the Agreement and the personal data processing policy before submitting the application.

4.3. The Administration shall be entitled at any time to unilaterally amend the terms of the Agreement and related documentation without notifying the Customer. Such amendments come into force since the publication of a new document revision on the Website.

4.4. The Administration shall be entitled to unilaterally refuse to fulfill the terms of the Agreement, if the User violates the legislation of the Russian Federation or the terms of the Agreement.

4.5. If any provision of this Agreement is found by the court to be invalid or unenforceable does not entail the invalidity of other provisions of the Agreement.

4.6. The current valid revision of the Agreement is located at the URL: http://www.sanporto.net



PERSONAL DATA PROCESSING POLICY



  1. General Clauses
1.1. This document (hereinafter referred to as the Policy) defines the goals and general principles of processing of personal data, as well as the measures taken to protect personal data of SanPorto LLC (hereinafter referred to as the Operator, the Company). The Policy is a publicly available document of the Company, with any individual being able to get familiarized with it.

1.2. Since its approval, the Policy is valid indefinitely unless amended.

1.3. The terms and concepts used in the Policy are applied in accordance with their meanings defined in Federal Law No. 152-FZ dated 027.07.2006 "On Personal Data" (hereinafter referred to as the Federal Law "On Personal Data").

1.4. The Policy applies to all actions taken by the Company related to the personal data processing.

1.5. The Company does not control other websites that can be accessed from the Company's website.

1.6. The personal data subject has the right: to withdraw his/her consent to personal data processing; to receive information on the processing of his/her personal data; to require the Company to clarify his/her personal data; to block or delete it, if the personal data is incomplete, outdated, inaccurate, illegally obtained or not required for the stated purpose of the processing, as well as to take measures prescribed by law in order to protect his/her rights.

  1. Purposes of Data Processing
    1. 2.1. The processing of personal data is carried out for the following purposes:
  • fulfillment of the Company's obligations under the concluded civil contracts;
  • compliance with the current legislation of the Russian Federation.
  1. Legal Basis for Personal Data Processing
3.1. The processing of personal data is carried out by the Company on a legal and fair basis, with the legal grounds for such a processing being as follows:

  • Constitution of the Russian Federation;
  • Civil Code of the Russian Federation;
  • Tax Code of the Russian Federation;
  • civil contracts with personal data subjects;
  • consent of personal data subjects to the processing of personal data;
  • other mandatory legal acts affecting activities of the Company.
  1. The Amount and Categories of Processed Personal Data and Categories of Personal Data Subjects
4.1. The content and amount of the processed personal data are determined based on the processing purposes.

4.2. The basic categories of personal data subjects whose data is processed by the Company include as follows:

4.2.1. Individuals that are the Company's counterparties under contracts.

4.2.2. Representatives/employees of the Company's counterparties under contracts.

4.3. For the category of personal data subjects specified in cl. 4.2.1., the following data can be processed: surname, name, patronymic, registration address at place of residence and actual address of residence, telephone number, e-mail address, URL of the profile page in social networks, TIN, OGRNIP. For the category of personal data subjects specified in cl. 4.2.2., the following data can be processed: surname, name, patronymic, telephone number, e-mail address, URL of the profile page in social networks.

  1. Procedure and Terms of Personal Data Processing
5.1. The processing of personal data by the Company is non-automated.

5.2. Actions with personal data include as follows: collection, recording, systematization, accumulation, storage, clarification (update and modification), extraction, use, transfer (distribution, provision and access), depersonalization, blocking, deletion and destruction of personal data.

5.3. The Company does not transfer personal data to third parties without the consent of the personal data subject, unless otherwise provided by law.

5.4. When processing, the accuracy of personal data, their sufficiency and relevance in relation to the purposes of personal data processing are ensured. Should inaccurate or incomplete personal data be found, it shall be clarified and updated.

5.5. The processing and storage of personal data are carried out for no longer than the period required to accomplish the purpose of personal data processing, unless there are legal bases for further processing. The processed personal data is subject to destruction under the following conditions:

  • achievement of the purposes of personal data processing;
  • ascertainment of the fact that personal data is obtained illegally or is not required for the stated purpose of processing;
  • impossibility of ensuring the legitimacy of the personal data processing;
  • withdrawal of consent to personal data processing by the personal data subject, if the personal data storage is no longer required for the purposes of personal data processing;
  • withdrawal of consent to personal data processing by the personal data subject for contacts with potential consumers, when promoting goods and services.
5.6. The Company shall take the necessary legal, technical and organizational measures to ensure the security of personal data to protect them from unauthorized (inter alia, accidental) access, destruction, modification, blocking of access and other unauthorized actions.

5.7. In cases not explicitly provided by the current legislation or contract, processing is carried out upon obtaining the consent of the personal data subject. The consent can be expressed in the form of taking actions, accepting the terms of the offer agreement, placing due marks, filling out forms, or in any other way that complies with the law.

  1. Updating, Rectification and Destruction of Personal Data, Responding to Requests for Access to Personal Data from Subjects
6.1. The personal data subject has the right to send requests for information about processing of his/her personal data by the Company to the e-mail address specified in cl. 7.4. of the Policy. The request shall be sent in an arbitrary form allowing to identify the sender and containing an e-mail address for sending a response and carrying on correspondence.

6.2. The personal data subject has the right to withdraw the consent to personal data processing by sending a request to the Company as stipulated in cl. 6.1.

6.3. The personal data subject has the right to demand from the Company to clarify his/her personal data, block or destroy it, if the personal data is incomplete, outdated, inaccurate, illegally obtained or not required for the stated purpose of processing, by sending a request to the Company as stipulated in cl. 6.1. of this Policy.

6.4. The Company shall provide information on the processing of personal data of the relevant subject upon his/her request within 30 days from the receipt of such a request at the Company's e-mail address.

6.5. In case of any discrepancy between the processed personal data and the reality, it shall be updated by the Company within 7 days since the personal data subject's confirmation of irrelevance and inconsistency of the personal data with the reality.

6.6. If it is established that the processing of personal data is illegal, the processing of such personal data shall be terminated within a period not exceeding 7 days.

6.7. The Company shall immediately stop processing personal data at the request of the personal data subject, if this processing was carried out in order to promote the Company's services.

6.8. The Company shall block the processing of personal data for the period of checking at the request of the personal data subject or an authorized body.

6.9. Upon achievement of the processing purposes, as well as in the event that the subject withdraws the consent to the processing, personal data is subject to destruction, unless:

  • otherwise provided by the contract, the party to which, i.e. the beneficiary or the guarantor of which is the data subject;
  • the Company is not entitled to carry out processing without the consent of the personal data subject on the grounds provided by the Law "On Personal Data" or other federal laws;
  • otherwise provided for another agreement between the Company and the personal data subject.
6.10. If the personal data subject believes that the Company is processing his/her personal data in violation of the requirements of the Federal Law "On Personal Data" or otherwise violates his/her rights and freedoms, the personal data subject has the right to appeal against the action or inaction of the Company to the authorized body for protection of the rights of personal data subjects (The Federal Service for Supervision of Communications, Information Technology and Mass Media - Roskomnadzor) or in court.

  1. Final Clauses
7.1. The rights and duties of the Company are stipulated by the current legislation and agreements concluded by the Company.

7.2. Persons found guilty of violating the regulations on personal data processing and protection shall bear disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws, local acts and agreements of the Company.

7.3. Other rights and duties of the Company are determined by the legislation of the Russian Federation related to personal data.

7.4. The Policy is developed and put into effect by the head of the Company. Suggestions, comments, as well as all requests from the personal data subjects shall be sent to info@sanporto.net. The Policy is updated, when needed. The permanent URL of the Policy is http://www.sanporto.net

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