This Personal Data Privacy Policy (hereinafter referred to as the " Privacy Policy") shall apply to all information which the website PRANA: Predictive Analytics and Remote Monitoring System, located at the domain name prana-system.com, may receive from the User while using the website.

1. TERMS AND DEFINITIONS

1.1. In this Privacy Policy, the following terms are used:

1.1.1. "Website Administration" shall mean employees authorized to manage the website, acting on behalf of JSC ROTEC, who organize and/or perform personal data processing, and determine the purposes of personal data processing, the composition of personal data that are subject to processing, and actions (operations) carried out with personal data.

1.1.2. "Personal Data" shall mean any information related directly or indirectly to an identified or identifiable individual (a personal data subject).

1.1.3. "Personal Data Processing" shall mean any action (operation) or a combination of actions (operations) carried out with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, and destruction of personal data.

1.1.4. "Personal Data Privacy" shall mean the requirement compulsory for compliance by the Operator or other person who has received access to personal data not to allow their distribution without the consent of the personal data subject or other legitimate ground.

1.1.5. "Website User" (hereinafter, the "User") shall mean a person having access to the Website through the Internet and using the Website.

1.1.6. "Cookies" shall mean a small piece of data sent by a web server and stored on a user's computer that a web customer or a web browser sends each time to a web server in an HTTP inquiry upon the attempt to open a page of a respective Website.

1.1.7. "IP address" shall mean a unique network address of a node in a computer network built pursuant to an IP protocol.

2. GENERAL PROVISIONS

2.1. Use of the Website by the User shall signify consent with this Privacy Policy and the terms of processing of the User's personal data.

2.2. In the event of a disagreement with the terms of the Privacy Policy, the User shall cease using the Website.

2.3. This Privacy Policy shall apply only to the Website of PRANA: Predictive Analytics and Remote Monitoring System. The Website does not control and shall not bear the liability for websites of third parties to which the User may go using the links that are available on the Website.

2.4. The Website Administration does not verify personal data provided by the Website User.

3. SUBJECT OF THE PRIVACY POLICY

3.1. This Privacy Policy sets obligations of the Website Administration related to non-disclosure and ensuring the mode of confidentiality protection of personal data that the User provides at the request of the Website Administration while registering on the Website or placing an order for purchase of Goods.

3.2. Personal data permitted for processing within this Privacy Policy shall be provided by the user by filling in various forms at the Website of PRANA: Predictive Analytics and Remote Monitoring System, including the following information:

3.2.1. surname, first name and patronymic (middle name) of the User;

3.2.2. contact telephone number of the User;

3.2.3. e-mail;

3.2.4. address of the Goods' delivery;

3.2.5. place of residence of the User.

3.3. The Website collects certain statistical information that is automatically transferred in the course of reviewing advertising units and visiting pages:

IP address of the User;
information from cookies;
browser type;
date, time and number of visits;
website address from which the User transferred to the Company's Website;
information on location;
information on pages visited, review of advertising banners;
information provided by your browser (device type, type and version of browser, operating system, etc.)

3.3.1. Disabling cookies may result in the impossibility of accessing parts of the Website requiring authorization.

3.3.2. The Website collects statistics about IP addresses of its visitors. This information is used for detecting and solving technical problems, and for exercising control over the legitimacy of payments.

3.4. Any other personal information not stipulated above (a history of purchases, browsers used, operating systems, etc.) shall be subject to safe-keeping and non-disclosure, except for cases stipulated in Clauses 5.2. and 5.3. of this Privacy Policy.

4. PURPOSES OF COLLECTION OF PERSONAL INFORMATION OF THE USER

4.1. The Website Administration may use personal data of the User for the following purposes:

4.1.1. Identifying the User registered on the Website for execution of an order and/or conclusion of an Agreement of Remote Purchase and Sale of Goods with PRANA: Predictive Analytics and Remote Monitoring System.

4.1.2. Providing the User with access to personalized resources of the Website.

4.1.3. Establishing feedback with the User, including delivery of notices, requests related to the use of the Website, provision of services, processing of requests and applications from the User.

4.1.4. Determining the location of the User for ensuring security, preventing fraud.

4.1.5. Verifying reliability and completeness of personal data provided by the User.

4.1.6. Creating a user account for purchases, if the User gave consent for this.

4.1.7. Notifying the Website User of the status of an Order.

4.1.8. Processing and receiving payments, confirming a tax or tax benefits, disputing a payment, determining the right to the receipt of a credit line by the User.

4.1.9. Providing the User with efficient customer and technical support in the event of occurrence of problems related to the use of the Website.

4.1.10. With the consent of the User, providing the User with updates of products, special offers, information on prices, newsletters and other information on behalf of the Website or partners of the Website.

4.1.11. Performing advertisement activity with the consent of the User.

4.1.12. Providing the User with access to websites or services of partners for the purpose of receiving products, updates and services.

5. METHODS AND PERIODS OF PERSONAL INFORMATION PROCESSING

5.1. Processing of personal data of the User shall be performed for an unlimited period of time by any legitimate methods, including processing in personal data information systems with or without the use of automation tools.

5.2. The User agrees that the Website Administration has the right to transfer personal data to third parties, including courier services, post offices, telecom carriers, solely for the purpose of completing an order of the User executed on the Website PRANA: Predictive Analytics and Remote Monitoring System, including delivery of Goods.

5.3. Personal data of the User may be transferred to authorized government bodies of the Russian Federation solely on the grounds and pursuant to the procedure established by the laws of the Russian Federation.

5.4. In the event of the loss or disclosure of personal data, the Website Administration shall inform the User of such.

5.5. The Website Administration shall take the necessary organizational and technical measures for protection of personal information of the User from unauthorized or accidental access, change, blocking, copying, distribution, and other wrongful acts of third parties.

5.6. The Website Administration jointly with the User shall take all necessary measures for prevention of losses or other negative consequences caused by loss or disclosure of personal data of the User.

6. OBLIGATIONS OF THE PARTIES

6.1. The User shall:

6.1.1. Provide information on personal data necessary for the use of the Website.

6.1.2. Update, add information about personal data provided in the event of a change of that information.

6.2. The Website Administration shall:

6.2.1. Use information received solely for the purposes specified in Clause 4 of this Privacy Policy.

6.2.2. Keep the confidential information secret, not disclose it without the prior written consent of the User, and not sell, exchange, publish or otherwise disclose personal data of the User transferred, except as provided for in Clauses 5.2. and 5.3. of this Privacy Policy.

6.2.3. Take preventive measures to protect the confidentiality of personal data of the User pursuant to the standard procedure used for protection of information of that type in current business practice.

6.2.4. Block personal data related to a respective User since the time of an application or a request of the User or his/her legitimate representative or an authorized body for protection of rights of personal data subjects for a verification period, in the event of detection of unreliable personal data or wrongful acts.

7. LIABILITY OF THE PARTIES

7.1. If the Website Administration fails to fulfill its obligations, it shall bear liability for losses incurred by the User due to wrongful use of personal data pursuant to the laws of the Russian Federation, except for cases stipulated by Clauses 5.2., 5.3. and 7.2. of this Privacy Policy.

7.2. In the event of loss or disclosure of Confidential Information, the Website Administration shall not bear liability if that confidential information:

7.2.1. Became publicly available before its loss or disclosure.

7.2.2. Was received from a third party before its receipt by the Website Administration.

7.2.3. Was disclosed with the consent of the User.

8. DISPUTE RESOLUTION

8.1. Before applying to a court with respect to disputes arising from relations between the Website User and the Website Administration, presenting a claim (a written offer about voluntary resolution of a dispute) is compulsory.

8.2. A claim recipient within thirty (30) calendar days since the receipt of a claim shall notify the claimant of the results of consideration of the claim.

8.3. If an agreement is not reached, the dispute shall be submitted to a judicial body pursuant to the applicable laws of the Russian Federation.

8.4. This Privacy Policy and relations between the User and the Website Administration are governed by the applicable laws of the Russian Federation.

9. ADDITIONAL TERMS

9.1. The Website Administration shall have the right to amend this Privacy Policy without the consent of the User.

9.2. A new Privacy Policy shall take effect upon its placement on the Website, unless otherwise stipulated by the new version of the Privacy Policy.

9.3. Any proposals or questions with respect to this Privacy Policy shall be communicated through a feedback form.

9.4. The effective Privacy Policy is posted at prana-system.com/en/privacy_policy/