Privacy Policy

1. General Information

This Privacy Policy is created in accordance with the Federal Law of 27 July 2006 No. 152-FZ ‘On Personal Data’. It sets out the provisions for personal data processing and measures to protect said personal data by IMG/IT Ltd. (hereinafter, the Operator). 

1. The ultimate goal of the Operator and the primary condition for its operation is the observance of human and citizen rights and freedoms when processing personal data, including the right to personal and family privacy.
2. This Privacy Policy (hereinafter, the Policy) is applicable to any and all information that the Operator may gain access to about the users of the http://sum1.ru/en/ website. 

2. Basic Terms Used in the Policy 

1. Automated Personal Data Processing means processing of Personal Data using the necessary software;
2. Blocking of Personal Data means temporary suspension of Personal Data processing (excluding cases where processing is required to validate or update personal data);
3. Website means an entirety of graphic and information materials, as well as databases and software that assure access to these materials online at http://sum1.ru/en/;
4. Personal Data Information System means an entirety of Personal Data stored in databases, and information technologies, hardware and software that allow it to be processed;
5. Personal Data Anonymization means actions, as a result of which it is impossible to identify the owner of the Personal Data, be it a specific User or another Personal Data owner, without the help of additional information;
6. Personal Data Processing means any action (operation) or a series of actions (operations) carried out with the help of automation tools or without them on Personal Data, including collection, recording, filing, accumulation, storage, validation (updates and changes), extraction, usage, transmission (distribution, provision, access), anonymization, blocking, deletion and erasure of Personal Data;
7. Operator means a state agency, a municipal agency, a legal entity or a natural person that is responsible (independently or with other entities) for organizing and/or carrying out Personal Data processing, as well as determining the purpose of said processing, scope of Personal Data for processing and actions (operations) carried out with Personal Data;
8. Personal Data means any information directly or indirectly related to a specific or a determined User of the http://sum1.ru/en/ website;
9. User means any visitor of the http://sum1.ru/en/ website;
10. Provision of Personal Data means any action aimed at disclosing Personal Data to a specific entity or a specific group of entities;
11. Distribution of Personal Data means any action aimed at disclosing Personal Data to an indeterminate number of entities (transferring Personal Data) or at accessing Personal Data of an indeterminate number of entities, including public disclosure of Personal Data in mass media, publishing online or providing access to Personal Data in any other way;
12. Cross-border Transfer of Personal Data means transferring Personal Data onto the territory of a foreign country, to a state agency of a foreign country, a legal entity or a natural person of a foreign country;
13. Erasure of Personal Data means any actions, as a result of which, Personal Data are permanently deleted without a way to restore their contents within the Personal Data Information System and/or destroying physical Personal Data storage. 

3. The Operator has the right to process the following Personal Data of the User:

1. Full name;
2. Email address;
3. Telephone numbers;
4. The Website also collects and processes anonymous data about the Users (including ‘cookie’ files) with the help of internet statistics services (Yandex.Metrica, etc.).

The aforementioned data will hereinafter be referred to as Personal Data when mentioned in the Policy.

4. Purpose of Personal Data Processing 

1. The purpose of processing the User Personal Data is to keep the User informed via email and to provide the User access to various services, information and/or materials on the Website.
2. The Operator also has the right to forward the User information about new products and services, special offers and various events. The User always has the right to opt out of receiving such information by emailing the Operator at info@sum1.ru, titled ‘Cancel Newsletter with New Products, Services and Special Offers’.
3. Anonymous User data collected with the help of internet statistics services serves to compile information on User actions on the Website, improving the quality of the Website and its content. 

5. Legal authority for Personal Data Processing 

1. The Operator processes User Personal Data only in the case when User personally fills in and/or submits such data through dedicated forms on the http://sum1.ru/en/ website. By filling in the corresponding forms and/or by submitting Personal Data to the Operator, the User expressly agrees to the terms and conditions of this Policy.
2. The Operator processes anonymous User data in cases when this is allowed in browser settings of the User (permission to save ‘cookie’ files and using JavaScript). 

6. Framework of Personal Data Processing, including collection, storage, transferring, etc. 

Privacy of Personal Data, as processed by the Operator, is assured by way of implementing a number of legal, organizational and technical measures that are necessary to comply in full with the stipulations of the current legislation in relation to Personal Data protection. 

1. The Operator assures privacy of Personal Data and takes all the necessary measures to eliminate the possibility of access to the Personal Data by unauthorized entities.
2. User Personal Data will never, under any circumstances, be transferred to third parties, excluding cases foreseen by the stipulations of the current legislation.
3. In case of discrepancies in Personal Data, the User may update them at the User’s own discretion by sending the Operator notification to the Operator email address, info@sum1.ru, titled ‘Updating Personal Data’.
4. Personal Data Processing is established in perpetuity. The User may, at any time, revoke User’s agreement to the processing of Personal Data by sending a notification to the Operator email address, info@sum1.ru, titled ‘Revoking the Agreement to Personal Data Processing’. 

7. Cross-border Transfer of Personal Data 

1. Prior to cross-border transferring of Personal Data, the Operator has to ensure that the foreign country to which the Personal Data is to be sent observes strict regulations in terms of Personal Data protection and protects the rights of Personal Data owners.
2. Cross-border Transfer of Personal Data to foreign countries that do not meet the aforementioned requirements may only be carried out after obtaining a signed consent from the owner of Personal Data for Cross-border Transfer of Personal Data and/or in the process of executing a contract with the owner of Personal Data. 

8. Final Provisions 

1. The User may forward any additional inquiries pertaining to processing of their Personal Data to the Operator email address: info@sum1.ru.
2. This document reflects any changes made to the Privacy Policy of the Operator. The Policy is established in perpetuity until it is replaced by a newer version.
3. The latest updated version of the Policy is freely available online at http://sum1.ru/en/confident.html.