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Personal Data Confidentiality Policy
WWW.ANDREICLUB.COM
 
Effective date _________________

This Personal Data Confidentiality Policy (further – «Privacy Policy», «Policy») regulates what User’s information is collected by Website Administration and how it is further processed. Website Administration reserves the right to change this Policy at any time. Website Administration will notify Users of any material changes in the conditions by posting the new Policy and changing «Effective Date» (see the above Effective Date of this Privacy Policy). It is recommended to periodically review this page to keep track of any changes. By using or navigating website www.andreiclub.com User confirms that he/she have read and agree to this Policy, as provided here. If the User does not agree to these terms, he must leave the Website, do not use and do not visit it in the future.
 
1. DEFINITIONS
 
1.1. In this Policy the following definitions are used:
1.2. «Website Administration» – Website’s employees determining the content of Personal Data, purpose of its processing, organizing or participating in Personal Data processing, commissioned to manage the Website by the name of WSA MEDIA LTD, in turn acting on the basis of license granted by the Rightsholder.
1.3. «Personal Data» – any information directly or indirectly related to certain individual person (owner of Personal Data).
1.4. «Personal Data Processing» – any activity (operation) or combination of such activities (operations), performed manually or with use of automatics, including collection, record, arrangement, accumulation, storage, confirmation (update, amendment), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data.
1.5. «Personal Data Privacy» – obligatory for any operator or any other party obtained access to Personal Data requirement not to allow its distribution without consent of Personal Data owner or other lawful grounds.
1.6. «User» – individual person who is accessing the Website via Internet and using its Services.
1.7. «Cookies» – small parts of data sent by web-server and stored on User’s computer, which is further sent by web-client or web-browsing software each time in HTTP-request in attempt to open web page of the corresponding site. Cookies technology is used for improving the quality of User’s online experience, making easier browsing through Website now and in future. Cookies could be turned off at User’s discretion.
1.8. «IP-address» – unique network address of a node in computers net, built on IP protocol.
 
2. MATTER OF POLICY
 
2.1. This Policy sets out the obligations of Website Administration (meaning Websites www.andreiclub.com and www.andrei.ru) in respect of non-disclosure and protection of confidentiality for Personal Data, which might be provided by User at the request of Website Administration for registration on the Website and/or ordering of Services.
2.2 Personal Data allowed for processing under this Policy include the following information:
- User’s name, surname, patronymic;
- User’s age;
- User’s contact phone;
- User’s e-mail;
- delivery address;
- address of residence.
2.3 Website Administration collects and analyzes Personal Data through registration forms and ordering forms at www.andreiclub.com when a User subscribes to receive goods or services. Website Administration also collects information through online surveys if the User takes part in them. When User visits Website, its Administration collects certain anonymous demographic information about users, including IP-address and browser version. Website Administration also collects information regarding the User’s activity on the www.andreiclub.com using Cookies.
2.4. Disabling Cookies may result in inability to access parts of the Website that requires authentication.
2.5. User may always choose to disable Cookies. This choice will be effective only for specific device and specific browser installation. If User prefers to switch off Cookies completely, he/she would have to disable them separately for each device and browser installation used by the User.

 
3. OBJECTIVES OF PERSONAL DATA COLLECTION AND USE
 
3.1. When using the Personal Data provided by Users, Website Administration complies with the requirements of the Russian Federation Law «On Personal Data» № 152-FZ of 27.07.2006.
3.2. Website Administration uses Personal Data to fulfill orders and / or requests of the Users, to facilitate browsing and using the Website, to provide information about the Website, about its partners and third-party companies in which User may be interested. Website Administration uses Personal Data for socio-demographic research.
3.3. Website Administartion uses the collected information to evaluate and improve the Services provided by www.andreiclub.com site.

 
4. METHODS AND TERMS OF PERSONAL DATA PROCESSING
 
4.1. User’s Personal Data processing is carried out by any lawful methods without limitation for terms, including personal data information systems using automation tools or without the use of such resources.
4.2. The User agrees that the Website Administration has the right to transfer his/her Personal Data to third parties, such as courier services, postal service organizations, telecommunications operators, solely for the purposes of fulfilment of any User’s order that could be placed via www.andreiclub.com, including the delivery of the goods or services.
4.3. The User agrees that the Website Administration has the right to disclose his/her Personal Data in the cases stipulated by law, upon receipt of the official request of law enforcement, enforcement of the judgment, in order to protect the rights of users, as well as to identify, contact or bring legal action against someone who can be suspected in causing harm or interfering with rights of the Rightsholder.
4.4. In the event of a change of Websites ownership or merger, acquisition or sale of assets to another entity, guided by Article 7 of the Russian Federation Law «On Personal Data» № 152-FZ of 27.07.2006, Website Administration will notify the Users not later than 10 days prior to the transaction, in order to allow users to delete information about themselves, if they consider it necessary..
 
5. OBLIGATIONS OF PARTIES
 
5.1. The User shall be obliged:
5.1.1. To provide information on his/her Personal Data as necessary for the purchase of premium content and / or use of the Website.
5.1.2. To update or amend the information provided on the Personal Data in the event of any changes.
5.2. Website Administration shall be obliged:
5.2.1. To use the Personal Data received only for the purposes specified in para. 3 of this Privacy Policy.
5.2.2. To maintain confidential storage of Personal Data, not to disclose, without the prior written consent of the User, and do not sell, exchange, publish, disclosure or any other possible ways transmit User’s Personal Data, with the exception of paragraphs 4.2. and 4.3. of this Privacy Policy.
5.2.3. To take precautions protecting the confidentiality of User’s Personal Data pursuant to the procedure normally used to protect this kind of information in existing business practices.
5.2.4. To block User’s Personal Data upon the appeal or request of respective User or his legal representative or authorized body for protection of the rights of Personal Data owners for the period of audit in case of inaccurate Personal Data provision or other misconduct.
 
6. PARTIES’ RESPONSIBILITY
 
6.1. In case of loss or disclosure of Personal Data Website Administration shall not bear any responsibility if such Personal Data:
6.1.2. Had become publicly available before its loss or disclosure.
6.1.3. Have been received from third party before Website Administration acquired it.
6.1.4. Have been disclosed upon User’s consent.
6.2. In case of technical malfunction restricting access to the site, Website Administration guarantees to compensate for such restriction of access with extending the access terms by ratio 1:3. For example, if access to the site was limited for 12 hours Users are given additional time of access to paid content in the amount of 36 hours.
6.3. Technical service response time shall not exceed 72 hours.
6.4. Technical service is provided in Russian or English languages only.

 
7. CONFLICTS RESOLUTION
 
7.1. An obligatory claim procedure shall be fulfilled for resolution of any disputes between the User and the Website Administration before applying to the court; that is, a written claim containing proposals on how to settle the dispute shall be brought by a party initiating such procedure to its opponent.
7.2 The recipient of the claim shall notify the claimant on its resolution of the claim within 30 calendar days from the date of receipt of the claim.
7.3. In case of failure to reach agreement under the claim procedure, the dispute between the parties shall be resolved in court in accordance with applicable Russian legislation.
7.4. The current legislation of the Russian Federation shall be applied to this Privacy Policy and the relationships between the User and Site Administration.
 
8. ADDITIONAL PROVISIONS
 
8.1. Website Administration has the right at its discretion to make changes to this Privacy Policy without the consent of the User.
8.2. Unless otherwise provided by the new version of the Privacy Policy, it shall be effective from the date of its posting on website www.andreiclub.com.
8.3. Website Administration does not collect Personal Data from individuals under the age of 18.
8.4. The current Privacy Policy is available on the Website at: www.andreiclub.com/conf-policy.
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