Privacy Policy
This Personal Data Privacy Policy (hereinafter—the Policy) applies to all personal data that Softline Group (hereinafter—Softline) may receive from users when they use the Softline website at www.softline.ru (hereinafter—the Website), access web services or other services, purchase goods, participate in advertising and marketing campaigns or promotions and/or otherwise interact with Softline (hereinafter—the Services).
This Policy is mandatory for all persons allowed to process personal data at Softline and persons that organize personal data processing at Softline and ensure their security.
Basic concepts used in this Policy:
- Personal data—any information referring directly or indirectly to a particular or identified individual (personal data subject).
- Personal data operator (Operator)—an individual or an entity who, independently or in cooperation with other individuals or entities, organizes or performs personal data processing as well as determines the purposes, scope of personal data processing, and actions (operations) included in personal data processing (Softline);
- Processing of personal data—any action (operation) or a set of actions (operations) with personal data performed with or without the use of automation tools. Processing of personal data includes, but is not limited to: collection; recording; systematization; accumulation; storage; clarification (updating, alteration); retrieval; use; transfer (dissemination, provision, access); depersonalization; blocking; deletion; destruction.
- Automated personal data processing—personal data processing by computer tools;
- Dissemination of personal data—actions related to making the data available to an indefinite range of persons;
- Provision of personal data—actions related to making the data available to a definite person or a definite range of persons;
- Blocking of personal data—the temporary cessation of personal data processing (except for the cases when the processing is needed for personal data clarification);
- Destruction of personal data—actions performed on personal data contained in the respective database that prevent such data from being restored and (or) actions aimed at the physical destruction of the tangible medium of personal data;
- Personal data anonymization—actions performed on personal data that do not permit the identity of the individual concerned to be verified solely from such anonymized data;
- Personal data filing system—a database that contains personal data as well as information technologies and hardware used for data processing;
- Cross-border transfer of personal data—cross-border transfer of personal data to a foreign state agency, foreign legal entity, or individual located in a foreign state.
This Policy applies to all processes for the collection, recording, systematization, accumulation, storage, clarification (updating, alteration), retrieval, use, transfer (provision, access), blocking, deletion, and destruction of personal data performed with automation tools.
Softline processes personal data in compliance with the principles and rules established by the Federal Law of the Russian Federation No. 152-FZ "On Personal Data" d/d June 27, 2006.
Softline does not control and is not responsible for any third-party sites which the user can access through the links available on Softline's website. Third-party sites may have their own privacy policies and may collect or request other personal information from the user.
This Policy explains how Softline processes and protects users' personal data and other information.
By using the Services and providing Softline with information necessary to initiate further interaction, you consent to its use in accordance with this Policy.
For specific Services, Softline may publish additional provisions supplementing this Policy.
This Policy is shall be updated in the event of changes in the personal data law of the Russian Federation.
1. Personal data of users received and processed by Softline
1.1. For the purposes of this Policy, "personal data of users" means
1.1.1. Personal data that the user provides about themselves when registering (creating an account) on the Website or while using the Services. Information that is mandatory for the provision (performance) of the Services shall be clearly marked.
1.1.2. For non-registered Website users—individuals who make purchases on the Website without registration—such data includes first name, last name, middle name, date of birth, delivery address; contact phone number, organization details, job title, e-mail address, information about country, city, region of residence, bank card details (number, CVV, full name in Latin letters, year and month of bank card expiration).
1.1.3. For registered Website users—individuals who successfully registered on the Website, such information includes first name, last name, middle name, contact phone number, cell phone number, delivery address, fax number, organization details, job title, e-mail address, information about country, city, region of residence, bank card details (number, CVV, full name in Latin letters, year and month of bank card expiration).
1.1.4. For clients/partners—individuals in contractual relations with Softline—such information includes first name, last name, middle name, job title and place of work, e-mail address, and contact phone number.
1.1.5. For applicants seeking employment, such information includes: first name, last name, middle name, date of birth, residence address, home phone number, work phone number, cell phone number, e-mail address, information about marital status, information about children, information about education/advanced training (period of study, educational institution, faculty/specialization, diploma specialty, form of training), information about certificates, information about the work experience and record (period of work, company, company's field of activity, job title, main job duties), information about knowledge of software products and programming languages, information about knowledge of foreign languages, information about professional qualities, information about personal qualities, city of residence, information about the vacancy of interest, information about the work schedule, information about the expected level and form of remuneration, information about hobbies.
1.1.6. Other information about the user additionally collected or requested by Softline for the provision of specific services, which is explicitly stated when said Services are ordered.
1.2. The user's personal data provided by Softline are not considered reliable and may be blocked until Softline or the user's legal representative gives consent to process the user's personal data in any form additionally specified by Softline, other than the one provided on the Website.
1.3. Softline does not make decisions that give rise to legal consequences for users or otherwise affects their rights and legitimate interests solely on the basis of the automated processing of their personal data.
1.4. Softline does not delegate the processing of personal data to other entities.
2. Purpose of processing the personal data of users
2.1. Softline processes only those personal data that are required to provide the Services and improve their quality.
2.2. Softline may use the user's personal data to fulfill Softline's obligations under orders, contracts, and other obligations towards the user accepted by Softline as binding. To achieve this goal, Softline implements a set of actions to perform the following tasks:
2.2.1. Identification of the party to the Service.
2.2.2. Providing the user with personalized Services.
2.2.3. Improving the quality of Services and developing new ones.
2.2.4. Conducting statistical and other studies based on depersonalized data.
2.2.5. Providing the user's personal data to software copyright holders, distributors, or resellers for the purpose of registering the software in the name of the user or the organization whose interests are represented by the user.
2.2.6. Providing users of the Website with a safe and convenient user experience and effective display of information.
2.2.7. Effective execution of orders, contracts, and other obligations towards the user accepted by Softline as binding.
2.2.8. Handling questions from the Website users.
2.2.9. Registration of website users for events.
2.2.10. Registration of Softline customers/partners in a service desk system for further technical support.
2.2.11. Collecting CVs and selecting candidates to fill vacancies in Softline.
2.2.12. Execution and/or fulfillment of functions, powers, and duties assigned to Softline by the law of the Russian Federation.
3. Legal basis for personal data processing:
- Art. 23, 24 of the Constitution of the Russian Federation;
- Art. 90 of the Labor Code of the Russian Federation;
- Softline charter and constituent documents;
- User consent to the processing of personal data;
- Softline internal regulatory and administrative documents.
4. Transfer of the user's personal data to third parties
4.1. The user's personal data shall be kept confidential, except for the processing of personal data, access to which is granted to the general public by the user or at the user's request.
4.2. Softline reserves the right to transfer the user's personal data to third parties in the following cases:
4.2.1. The User provided their consent to such actions, including for the purpose of software registration in the user's name by software copyright holders, distributors, or resellers.
4.2.2. The transfer is necessary to achieve the purpose, implement and perform the functions, powers, and duties imposed on Softline by the law of the Russian Federation.
4.3. Softline does not transfer users' personal data across borders.
5. Measures to protect users' personal data
5.1. Softline has taken the following measures to ensure compliance with the obligations stipulated by Federal Law of the Russian Federation No. 152-FZ "On Personal Data" d/d June 27, 2006, and the regulations adopted in accordance with it to protect users' personal data:
5.1.1. A person responsible for organizing the personal data processing was appointed.
5.1.2. Local acts on personal data processing and security were issued, as well as local acts establishing procedures aimed at preventing and detecting violations of legislation of the Russian Federation and eliminating the consequences of such violations.
5.1.3. Legal, organizational, and technical measures were taken to ensure the security of personal data.
5.1.4. The rules of access to personal data processed in personal data filing systems were established.
5.1.5. All actions performed with personal data in the personal data filing systems are registered and logged.
5.1.6. Rules for personal data and information backup and recovery were established.
6. User rights and obligations
6.1. Softline takes reasonable steps to maintain the accuracy and relevance of personal data kept by Softline and to delete outdated and other inaccurate or redundant personal data. Nevertheless, the User is responsible for providing accurate information, as well as for updating the data when they are changed.
6.2. The User can at any time change (update, enrich) their personal data or a part thereof, as well as their privacy parameters by contacting Softline.
6.3. The User may withdraw their consent to Softline's processing of their personal data at any time by sending a written notice at 119270, Russian Federation, Moscow, Luzhnetskaya Naberezhnaya 2/4, bldg. 3A, office 304, to Softline Trade JSC, marked "withdrawal of consent to the personal data processing", provided that withdrawal of the User's consent to the processing of personal data leads to the deletion of the User's account from the Website, as well as the destruction of records containing personal data in Softline's personal data processing systems, which may make it impossible to use Softline Internet services.
6.4. The User has the right to receive information regarding the processing of their personal data by Softline, for which they may send a written request at 119270, Russian Federation, Moscow, Luzhnetskaya Naberezhnaya 2/4, bldg. 3A, office 304 to Softline Trade JSC marked "request for information on the personal data processing".
6.5. In order to comply with clauses 6.2 and 6.3 of this Policy, Softline may require a proof of the User's identity by requesting such proof in any form consistent with the law. Softline shall review and respond to the request within thirty (30) days since its receipt.
7. Feedback. Questions and suggestions
All suggestions or questions regarding this Policy shall be submitted to Softline by phone +7(495) 232-0023 or by e-mail at info@softline.ru.
8. Personal data storage period
The personal data storage period is limited to the period required to achieve the purpose of personal data processing specified in this Policy unless another longer period of personal data storage is established by applicable law.
i Softline Group includes the following legal entities: JSC "SoftLine Trade", 119270, Moscow, Luzhnetskaya Naberezhnaya 2/4, bldg. 3A, office 304; LLC "SK SoftLine", 119270, Moscow, Luzhnetskaya Naberezhnaya 2/4, bldg. 3A, office 302, class B; LLC "SoftLine Internet Trade" 119270, Moscow, Luzhnetskaya Naberezhnaya 2/4, bldg. 3, floor 2, room 205; LLC "Soft Logistic" 119270, Moscow, Luzhnetskaya Naberezhnaya 2/4, p. 3A, office 304; ANO DPO "SoftLine Education", 115114, Moscow, Derbenevskaya Naberezhnaya 7, bldg. 8; JSC "SoftLine International", 115114, Moscow, Derbenevskaya Naberezhnaya 7, bldg. 8; LLC "INFOSECURITY", 107140, Moscow, Rusakovskaya St. 13, floor 10, office 10-01