The Privacy Policy (hereinafter referred to as the Policy) applies to all information that Eshich and partners LLC and/or its affiliates (hereinafter referred to as the Company) may receive about the User while using any of the Company’s sites, services, programs, or products (hereinafter referred to as Services, Company Services) and during the Company’s performance of any agreements and contracts with the User. The User’s consent to the Policy, expressed by him in the context of relationships with one of the listed entities, extends to all other listed entities.

Using the Company’s Services implies the User’s unconditional consent to this Policy and the terms of processing his personal information specified herein; in case of disagreement with these conditions, the User should refrain from using the Services.

1. Personal information of Users processed by the Company
1.1. Within the framework of this Policy, “User’s personal information” is understood as:

1.1.1. Personal information that User provides about himself independently during registration (creating an account) or in the process of using the Services, including the User’s personal data. Information necessary for the provision of Services is marked in a special way. Other information is provided by the User at his discretion.

1.1.2. Data that are automatically transferred to the Company’s Services in the process of its use through the software installed on the User’s device, including IP address, cookie data, information about the User’s browser (or another program which access to the Services is carried out), technical characteristics of hardware and software used by the User, the date and time of access to the Services, addresses of the requested pages, and other similar information.

1.1.3. Other information about the User, the processing of which is provided for by the terms of use of individual Company Services.

1.2. This Policy applies only to information processed during the use of the Company’s Services. The Company does not control and is not responsible for the processing of information by third-party sites to which the User can follow the links available on the Company’s sites.

1.3. The Company does not verify the accuracy of the personal information provided by the User and does not have the ability to assess his legal capacity.

2. Purposes of processing personal information of Users

2.1. The Company collects and stores only that personal information that is necessary for the provision of Services or the execution of agreements and contracts with the User, except cases when legislation provides for mandatory storage of personal information for a period specified by law.
2.2. The User’s personal information is processed by the Company for the following purposes:

2.2.1. Identification of the party within the Services, agreements, and contracts with the Company;

2.2.2. Providing the User with personalized Services and execution of agreements and contracts;

2.2.3. Communication with the User, including sending notifications, requests and information regarding the use of Services, execution of agreements and contracts, as well as processing requests and applications from the User;

2.2.4. Improving the quality of Services, ease of use, development of new Services;

2.2.5. Targeting of advertising materials;

2.2.6. Conducting statistical and other studies based on anonymized data.

3. Conditions for processing personal information of Users and its transfer to third parties

3.1. The Company stores the User’s personal information in accordance with the internal regulations of specific services.

3.2. The confidentiality of the User’s personal information is maintained, except in cases where the User voluntarily provides information about himself for general access to an unlimited number of people.

3.3. The Company has the right to transfer the User’s personal information to the third parties in the following cases:

3.3.1. The User has expressed consent to such actions;

3.3.2. As a result of processing the User’s personal information by anonymizing it, anonymized statistical data were obtained, which are transferred to a third party for conducting research, performing work or providing services on behalf of the Company.

3.4. When processing the personal data of Users, the Company is guided by the Federal Law of the Russian Federation “On Personal Data”.

4. Change and deletion of personal information. Mandatory data storage

4.1. The User can at any time change (update, supplement) the personal information provided by him or part of it by sending a written request to the address info@eshich.ru.

4.2. The User can at any time delete the personal information provided by him by sending a written request to the address info@eshich.ru.

4.3. The rights provided for in paragraphs 4.1. and 4.2. of this Policy may be limited in accordance with legal requirements. In particular, such restrictions may require the Company to keep the information modified or deleted by the User for the period prescribed by law, and to transfer such information to a government body in accordance with the legally established procedure.

5. Processing of personal information using cookies and counters

5.1. Cookies sent by the Company’s equipment to the User’s equipment and from the User’s equipment to the Company may be used by the Company to provide the User with personalized Services, to target advertising displayed to the User, for statistical and research purposes, as well as to improve the Company’s Services.

5.2. The User is aware that the hardware and software used by him to visit sites on the internet may have a function to prohibit operations with cookies (for any sites or for certain sites), as well as to delete previously received cookies.

5.3. The Company has the right to determine that the provision of a certain Service is possible only if the reception and receipt of cookies are allowed by the User.

5.4. The structure of the cookie, its content and technical parameters are determined by the Company and can be changed without prior notice to the User.

5.5. Counters placed by the Company in the Services can be used to analyze the User’s cookies, to collect and process statistical information about the use of Services, as well as to ensure the functionality of the Services as a whole or their individual functions in particular. The technical parameters of the counters are determined by the Company and can be changed without prior notice to the User.

6. Measures used to protect the User’s personal information

6.1. The Company takes necessary and sufficient organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties.

7. Change of the Privacy Policy. Applicable law

7.1. The Company has the right to make changes to this Privacy Policy. When changes are made, the date of the latest update is indicated in the current version. The new version of the Policy comes into force from the moment of its placement, unless otherwise provided by the new version of the Policy. The current version is always available on the page at https://eshich.ru/en/privacy-policy/

7.2. This Policy and the relationship between the User and the Company arising in connection with the application of the Privacy Policy is subject to the law of the Russian Federation.

8. Feedback. Questions and suggestions

8.1. All suggestions or questions about this Policy can be sent by the User to info@eshich.ru, or to the address: Moscow, Business Park Ordzhonikidze 11, Eshich and partners LLC.

Publication date: 09.06.2023