Privacy Policy
Effective Date: November 07, 2022
1. What this Privacy Policy covers
This Privacy Policy (hereinafter, the “Policy”) covers any information about users of PortBureau.ru website (hereinafter, “Site”) that may include personal data as defined by applicable laws and regulations (hereinafter, “Personal Data”), which owner of the Site - individual entrepreneur Klinaev Oleg Nikolaevich (hereinafter, “Owner”) - may obtain when you use the Site.
2. Who processes your Personal Data
To provide you with access to the Site your Personal Data is collected and used by:
Individual entrepreneur Klinaev Oleg Nikolaevich
TIN (or INN, Taxpayer Identification Number) 231500533204
PSRNIE (or OGRNIP, Primary State Registration Number of an Individual Entrepreneur) 321237500022901
Phone +7-988-770-4878
Email Oleg.Klinaev@PortBureau.ru
Address: Russia, 353924 Novorossiysk, 21 Yuzhnaya Street, apt. 113
3. What is the purpose of this Policy
As part of the commitment to protecting your Personal Data, the Owner uses this Policy to inform you about the following:
(a) why and how your Personal Data is collected and used (also, “processed”) by the Owner when you access the Site;
(b) Owner’s role and responsibilities in this context as the legal entity deciding why and how your Personal Data is controlled and processed;
(c) what instruments you may use to limit the amount of Personal Data collected by the Owner; and
(d) what your rights are in relation to the above processing.
4. What type of Personal Data is collected by the Owner
Personal Data collected by the Owner when you access, interact with or operate the Site includes:
(i) information provided by you when you register (create) a user Account, such as your email address;
(ii) electronic data (http headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software);
(iii) date and time of accessing the Site;
(iv) information related to your activity while using the Site;
In addition, the Owner uses cookies and web beacons (including pixel tags) to collect your Personal Data and associate this Personal Data with your device and web browser (see Section 11 below).
The Owner does not actively collect any sensitive personal data (such as racial origins, political opinions, health or biometric data).
The Owner does not perform any form of profiling, which has the potential to significantly impact your rights and freedoms in accordance with applicable laws.
The Owner does not verify Personal Data provided by you unless otherwise stipulated in the Terms of Use of the Site, and does not decide its credibility or whether you have legal capacity required. However, The Owner assumes that the information you provide is true, sufficiently complete and up-to-date.
5. What are the legal basis for processing your Personal Data and its purposes
The Owner is not allowed to process your Personal Data if he does not have valid legal ground. The Owner will therefore only process your Personal Data if:
(i) the processing is necessary to perform our contractual obligations towards you including providing you with access to the Site;
(ii) the processing is necessary to comply with our legal or regulatory obligations;
(iii) it is required by applicable law, when the processing is necessary for the legitimate interests of the Owner and does not unduly affect your interests or fundamental rights and freedoms. Please note that while processing your Personal Data the Owner will always seek to maintain a balance between his legitimate interest and the protection of your privacy.
Examples of such ‘legitimate interests’ referred in (iii) immediately above are:
(a) to better understand how you interact with the Site;
(b) to enhance, maintaining accessibility, modify, personalise or otherwise improve the Site for the benefit of all users; and
(c) for specific purposes or if a consent is required under the applicable laws and regulations, the Owner may ask your permission for processing of your Personal Data on a separate legal basis. Under those jurisdictions where such a permission is required, you provide the permission by agreeing to use the Site. The Owner hereby informs you, and you hereby acknowledge, that you have no legal obligation to provide the Owner with any Personal Data when you use the Site, and that you provide it on your free will. However, you are aware that without your Personal Data your use of the Sites will be limited.
The Owner always processes your Personal Data for a specific purpose and only the Data, which is relevant to achieve that purpose. In particular, the Owner process your Personal Data for the following purposes:
(i) to provide you access to the Site;
(ii) to provide you access to your user Account;
(iii) to contact you to notify and/or inform you or request information from you in relation to the Site, or to execute our agreements with you or process your request or application;
(iv) to improve user experience on the Site;
(v) to develop new products, applications and services;
(vi) to protect your rights and the rights of the Owner; and
(vii) to collect, process and present statistical data or big data, or perform other research and/or analysis of Personal Data.
The use of information received from the Google API (Received Data) is exercised in accordance with the Google API Disclosure subject to the restrictions specified therein.
6. How the Owner protects your Personal Data
In most cases, Personal Data is processed automatically without access to it by the Owner himself.
The Owner implemented adequate technical measures to protect Personal Data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal Data.
7. Who else has access to your Personal Data and who is it shared with
The Owner may transfer Personal Data to third parties to complete the purposes listed in Section 5 above. Please note that the level of protection of Personal Data in some countries may not be identical to the level in your jurisdiction and by using the Site you consent to such transfer.
Such third parties may include:
(i) any national and/or international regulatory authorities, law enforcement organisations, federal government or local municipal authorities and other statutory or public bodies or courts where the Owner is required to do so by applicable laws or regulations at their request;
(ii) the parties if you expressed your consent to such transfer or transfer of your Personal Data is required for your use of the Site or performance of a particular agreement or contract with you;
(iii) any parties to ensure legal protection of the Owner and/or the third parties if you violate the Terms of Use of the Site (https://portbureau.ru/en/pages/terms) or this Policy, or if there is a threat of such violation.
8. Where your Personal Data is stored and processed
Your Personal Data is stored in Russia.
The Owner records, systematises, accumulates, stores, clarifies (updates, changes), extracts Personal Data using databases located on the territory of Russia.
If you are located in a jurisdiction where transfer of your Personal Data to another jurisdiction requires your consent, then by using the Site you provide the Owner with your express and unambiguous consent to such transfer, storage, and/or processing of the Data in other jurisdictions, including Russia.
9. How long your Personal Data is stored
The Owner will only keep your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.
10. Your rights
10.1 What are your rights
If it is required by applicable law, you have the right to access your Personal Data processed by the Owner under this Policy.
If you believe that any information about you we hold is incorrect or incomplete, you can login to your user Account and correct your Personal Data yourself.
If it is required by applicable law, you also have the right:
- to learn the information about you that the Owner stores;
- to request erasure of your Personal Data or certain parts of it, as well as withdraw consent to the processing of the Personal Data;
- to request the restriction for processing of your Personal Data;
- to object to the processing of your Personal Data if it is required by applicable law.
The Owner will deal with any such requests or objections as required under applicable law.
According to applicable law, you may have another rights not specifically mentioned herein.
When you use the Site, the transfer of Personal Data is carried out with your consent expressing your free will and your interest (as an agreement with you) and it is not obligatory by any law.
10.2 How can you exercise your rights
To exercise the above rights, please login to your user Account, which will provide you with option to do so, or in case of absence of special function in user account interface please contact the Owner.
If you are not satisfied with how the Owner processes your Personal Data, please let the Owner know about it. If you are not satisfied with Owner's response, you have the right to make a complaint to the competent data protection authority.
11. Why the Owner uses cookies and other similar technologies on the Site
11.1 What cookies the Owner uses and why
Cookies are small text files with service information accepted and processed by device that you use to access the Site. They contain information that is collected from your device and sent back to the Site on each subsequent visit. Their use helps your navigation through the Site and allows it remember your preferences.
The following types of cookies are used on the Site:
- strictly necessary cookies / technical cookies: these cookies are required to run the Site and may, among other, allow the Site to identify your hardware and software, including your browser type;
- statistical / analytic cookies: these cookies enable the Site to recognise users, count the number of users and collect information such as your actions on the Site, including the web pages you visit and the content you retrieve;
- performance cookies: these cookies collect information about how users interact with the Site, enabling the Owner to identify errors and test new functionalities to improve the performance of the Site;
- functionality cookies: these cookies enable the Site to provide specific functionalities in order to improve your experience on the Site, for example by storing your preferences (e.g. language);
- (third party) tracking / advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable the Site to display advertising which may be of interest to you based on collected Personal Data. These cookies are also used for statistical and research purposes.
11.2 How long are those cookies stored on your device
The Owner only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.
11.3 Who else has access to the information contained in the cookies
Personal Data collected through cookies placed on your device may be transmitted to and accessed by the Owner or the third parties referred to in Section 7 hereof. The use of Personal Data outside of the Site for advertising purposes, if any, may be subject to separate policies available on the above third parties’ websites. The Owner or those third parties might also provide you with a possibility to opt out of personalised advertising, which shall be subject to laws and regulations applicable to such products and offerings.
The first time you access the Site, your approval for the use of these cookies may be requested. If after you have approved the use of cookies you want to make another choice, you can do this by deleting the cookies stored by your browser (usually via the options in your browser’s Privacy menu – please refer to your browser’s manual or developer’s website). The popup requesting your approval may then show up again and you can make a different choice. If you do not consent to the use of cookies, certain features of the Site might become unavailable, which may affect your browsing experience. You may also set up your browser preferences to accept or decline by default all cookies or cookies from specific websites, including this Sites too.
The Owner may also use web beacons (pixel tags) in order to access the cookies previously placed on your device for the following purposes:
(i) to track your actions on the Site by accessing and interacting with the cookies stored on your device;
(ii) to collect statistical information related to operating the Site.
12. Updates to this Policy
This Policy may be subject to amendments. The Owner shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Site.
The Owner undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site (via a pop-up or web banner) prior to such changes taking effect, and you may also be notified by email.