The Privacy Policy (hereinafter referred to as the Policy) applies to information that Vserossiyskoe Otkrytoe Aktsionernoe Obshchestvo «TSST» (Public Joint Stock Company "CST") and/or its affiliated entities, including all entities that are part of the same group as ZALA (hereinafter referred to as ZALA), may receive about the User during the User's use of ZALA's website (https://zala.aero), services, programs, products, or proprietary technologies (hereinafter referred to as Services) and in the course of ZALA fulfilling any agreements and contracts with the User.
The User's consent to the Policy, expressed by him within the framework of his relationship with one of the listed persons, extends to all other listed persons.
This Policy explains how ZALA processes and protects Users' personal data.
ZALA reserves the right to publish additional or amended provisions of the Policy. For specific Services, ZALA may also publish additional provisions which supplement and/or amend this Policy.
By using the Services and providing ZALA with the information necessary to initiate further interaction, in accordance with Part 3 of Article 6 of Federal Law No. 152-FZ of 27.07.2006 «On Personal Data», Part 1 of Article 18 of Federal Law No. 38-FZ of 13.03.2006 «On Advertising», the User:
- expresses consent to the processing of personal data with or without the use of automation, including collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data and other use of provided and/or received information in accordance with this Policy;
- confirms that ZALA consents to the possible transfer of its personal data to third parties, including for the purpose of providing advertising messages.
- ZALA's personal data that it receives and processes
1.1 For the purposes of this Policy, "user's personal data/personal information" shall mean:
1.1.1 Personal data (surname, first name and patronymic, e-mail address, postal address, contact phone number and any information relating directly or indirectly to a certain individual), which the User provides about himself/herself, including when registering (creating an account) on the Website or in the process of using the Services. The information mandatory for provision (rendering) of the Services is explicitly labelled. Other information is provided by the user at his/her discretion.
1.1.2. Anonymised data automatically obtained by ZALA while the user is on any page of the Website, using the software installed on the user's device: IP address, cookie information, information about
the user's browser (or other programme with the help of which the Site services are accessed), access time, address of the requested page and other similar information.
1.2. ZALA does not verify the accuracy of personal data provided by the User and is unable to assess their legal capacity. However, ZALA operates on the assumption that the user provides accurate and sufficient personal information and keeps this information up to date. ZALA does not control or accept responsibility for third-party websites that the user may access via links available on ZALA's websites. Third-party websites may have their own privacy policies and may collect or request different personal data from the user.
- Purposes of processing users' personal data
2.1. ZALA processes only the personal data that is necessary for the provision and improvement of the quality of its services.
2.2. ZALA may use the user's personal data for the following purposes:
2.2.1 Identification of the party within the framework of the Service provision.
2.2.2 Providing the User with timely and personalised Services and offers (including advertising).
2.2.3 Improving the quality of the Services and developing new ones.
2.2.4 Feedback from the User to provide information at the User's request.
2.2.5. Carrying out statistical and other research on the basis of anonymised data.
2.2.6. The performance and/or execution of functions, powers and duties vested in ZALA by the legislation of the Russian Federation. - Transfer of user's personal data to third parties
3.1 The User's personal data shall be kept confidential, except in cases of processing personal data to which the User has granted access to an unlimited number of persons or at the User's request.
3.2. ZALA reserves the right to transfer the User's personal data to third parties in the following cases:
3.2.1. the User has given his/her consent to such actions.
3.2.2. The transfer is necessary to achieve the objectives, carry out and perform the functions, powers and duties assigned to ZALA by this policy and the legislation of the Russian Federation.
3.3.3 The transfer is provided for by Russian or other applicable law under the procedure established by law. - Measures applied for the protection of users' personal data
ZALA takes necessary and sufficient organisational and technical measures to protect the user's personal data from unauthorised or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions with personal data by third parties. Personal data is stored until ZALA ceases its activities or until the Purposes are achieved.
processing of personal data of users. The maximum period of storage of personal data is 75 years from the date of its receipt from the User.
- Rights and obligations of the User
5.1. ZALA takes reasonable and practicable steps to maintain the accuracy and currency of personal data held by ZALA, and to remove outdated or otherwise inaccurate or excessive personal data; however, the User is responsible for providing accurate information and for updating provided data in the event of any changes.
5.2. The User may at any time change (update, supplement) the personal information provided by them or part thereof, as well as its privacy settings by contacting ZALA.
5.2.1. The User has the right to withdraw consent for the processing of ZALA personal data at any time by sending a written notification marked «withdrawal of consent for the processing of personal data» to the following address: 426063 Russian Federation, Udmurt Republic, Izhevsk, Vorovskogo St., 130, LLC «CST». The User's withdrawal of consent for the processing of personal data will entail the deletion of the user's account from the Site, as well as the destruction of records containing personal data in ZALA's personal data processing systems, which may make it impossible to use ZALA's Services.
5.3. The User has the right to receive information concerning the processing of their personal data in ZALA, for which purpose they may send a written request marked «request for information on personal data processing procedures» to the following address: 426063, Russian Federation, Udmurt Republic, Izhevsk, Vorovskogo St., 130, CST LLC.
5.4. To fulfil the provisions in clauses 5.2 and 5.3 of this Policy, ZALA may require User identity verification by requesting such confirmation in any legally permissible form. - Feedback. Questions and suggestions
The User may send all suggestions or questions regarding this Policy to the address: 130 Vorovskogo St., Izhevsk, Izhevsk, 426063 RF, Udmurt Republic, CST Ltd.
