This Personal Data Privacy Policy (hereinafter referred to as the Privacy Policy) is the website at https://export.macaronika.com/ an integral part (hereinafter referred to as the Site).

Site services use means the User's unconditional consent to this Policy and the personal information specified therein-processing terms; in disagreement with these terms case, the User shall refrain from using the services.

1. GENERAL PROVISIONS

1.1. For this Policy purposes, the User's personal information shall mean:

1.1.1. Personal information that the User provides about themselves when filling out feedback forms or in the using the Services process, including the User's personal data. The information mandatory for the Services provision is marked in a special way.

1.1.2. Data that is automatically transferred to the Site services in their use process of with the software help installed on the User's device, including IP address, cookie data, information about the User's browser (or other program with which help the services are accessed), the equipment and software technical characteristics used by the User, access to the services date and time, the requested pages addresses and other similar information.

1.1.3. This Privacy Policy applies only to the Site https://export.macaronika.com/.

Website https://export.macaronika.com/ does not control and is not responsible for third-party websites, to which the User can go through the links available on the Website https://export.macaronika.com/.

2. PROCESSING USERS' PERSONAL INFORMATION PURPOSES

The site collects and stores only the personal information that is necessary for the services provision or agreements and contracts with the User execution, except where the legislation provides for mandatory storage of personal information for time a period specified by law.

In a notice receipt case from the User withdrawing consent to the personal data processing, the Site stops processing the User's personal data within a period not exceeding 10 working days from the receipt date.

Consent to the personal data processing withdrawal notice should be sent to the e-mail address: export@macaronika.ru, as well as by written request to the legal address: 197348, St. Petersburg, Kolomyazhsky Avenue, 15, building 2, flat 548.

2.2. The Site processes the User's personal information for the following purposes:

2.2.1. The User identification when filling out the feedback form on the Site.

2.2.2. Providing the User with access to the Site personalised resources.

2.2.3. Establishing feedback with the User, including sending notifications, enquiries regarding the Site use, services provision, processing requests and applications from the User.

2.2.4. The User's location determination to ensure security, fraud prevention.

2.2.5. Personal data authenticity and completeness confirmation provided by the User.

2.2.6. Providing the User with effective customer and technical support in problems case related to the Website use.

3. THE PROCESSING USERS' PERSONAL INFORMATION CONDITIONS

AND IT’S TRANSFER TO THIRD PARTIES

3.1. The website stores Users' personal information in compliance with the service-specific internal regulations.

3.2. A User personal information is confidential, unless the User voluntarily divulges it for public consumption by an unlimited audience. By utilising some services, the User acknowledges that some of their personal information may be made available to the public.

3.3. The website may transfer the user personal information to third parties in the following cases:

3.3.1. The transfer is necessary for the User to use a specific service or to perform a particular agreement or contract with the User.

3.3.2. The transfer is required by the Russian or other applicable laws in accordance with the established legal procedure.

3.3.3. Should the Website be sold, the buyer will assume all responsibilities for adhering to this Policy terms and conditions regarding any personal information received.

3.4. The User's personal data shall be processed indefinitely using the following methods: data collection, recording, systematisation, accumulation, storage, clarification (updating, changing), extraction, utilization, transfer (distribution, provision, and access), depersonalisation, blocking, deletion, and destruction, including in personal data information systems with or without the automation means use. Users' personal data processing is conducted in accordance with the Federal Law dated 07/27/2006 N 152-FZ "On Personal Data".

3.5. If personal data is lost or disclosed, the Website Administration will notify the user about such loss or disclosure.

3.6. The website administration will implement required technical and organisational precautions to safeguard the user’s personal information from unauthorised access, destruction, alteration, hindering, copying, sharing, and any other illegal activities performed by third parties.

3.7. The website administration will collaborate with the users to ensure that the necessary actions are taken to avoid losses or any harmful outcomes that may arise due to the user's personal data exposure or disclosure.

4. THE PARTIES OBLIGATIONS

4.1. The user must:

4.1.1. Provide necessary personal data for using the site.

4.1.2. Update or supplement the provided personal data in any changes case.

4.2. The Site Administration is obligated to use the obtained information solely for the purposes stated in this Privacy Policy.

4.2.2. Ensure that confidential information is kept confidential and not disclosed without the User's prior written permission. Furthermore, do not sell, exchange, publish or disclose by any other means the User personal data that has been transferred, unless explicitly provided for in this Privacy Policy.

4.2.3. Block personal data related to the relevant User from the application point or request by the User, their legal representative or authorised body for the personal data subject rights protection during the verification period in the inaccurate personal data identification event or unlawful actions.

5. THE PARTIES LIABILITY

5.1. The Site Administration shall not be held liable in the loss event or confidential information disclosure if:

5.1.1. Such information the public domain had already become part before said loss or disclosure occurred.

5.1.2. Was received from the third party before its receipt by the Site Administration moment.

5.1.3. Was disclosed with the User's consent.

6. DISPUTE RESOLUTION

6.1. Prior to initiating legal proceedings relating to any disputes arising between the Website User and the Website Administration, it is compulsory to put forward a claim (a written proposal to resolve the dispute voluntarily).

6.2. Within 30 calendar days of receiving the claim, the claim recipient must inform the applicant in writing of the claim's consideration outcome.

6.3. If an agreement cannot be reached, any disputes will be referred to a court for consideration in accordance with the Russian Federation current legislation of.

6.4. The Russian Federation legislation shall apply to this Privacy Policy and to the relations between the User and the Website Administration.

7. ADDITIONAL CONDITIONS

7.1 The Website Administration has the right to make changes to this Privacy Policy without the User's consent.

7.2 The new Privacy Policy comes into force from its placement on the Site moment, unless otherwise provided by the Privacy Policy new version.

7.3 All suggestions or questions regarding this Privacy Policy should be communicated to export@macaronika.ru

7.4 The current Privacy Policy can be accessed on https://export.macaronika.com/.

--------------------------------

Information for information:

<1> According to the 07/27/2006 N 152-FZ "On Personal Data” Federal Law Article 18 part 5," operators must ensure recording, systematisation, accumulation, storage, clarification (update, change), and Russian citizens personal data extraction via databases located within Russia's borders when collecting personal data, including through the information and telecommunications network Internet. However, this requirement does not apply to cases specified in paragraphs 2, 3, 4, or 8 of Part 1 of Article 6 of the Federal Law dated 07/27/2006 N 152-FZ "On Personal Data".

General Provisions

This Personal Data Processing Policy - Personal Data (hereinafter referred to as the Policy) of IE.

Arkadiy Mihailovich Shtein TIN 780624608576 (hereinafter referred to as the Operator) defines the basic principles, objectives, procedure, and conditions of processing, scope and processed Personal Data categories, Personal Data subjects categories, responses to the subjects' requests for access to Personal Data, measures implemented to ensure Personal Data security during their processing by the Operator.

1. Processing Personal Data Purposes and Principles

1.1. The Operator shall process Personal Data for:

• ensuring adherence to the regulatory legal acts of the Russian Federation and the local regulatory acts of the Operator;
• carrying out activities as stipulated by the Operator's charter and local regulations, or to achieve socially beneficial goals, while exercising the Operator's rights and legitimate interests;
• labour relations with the Operator the employees Regulation, which includes assisting them in employment, training and promotion, ensuring safety, and monitoring their performance in fulfilling their obligations under their labour contracts quantity and quality;
• creating and maintaining a positive company image;
• handling advertising and promotional activities.

1.2. Processing Personal Data Principles

The personal data processing must adhere to certain general principles including:

• the Personal Data processing predetermined specific purposes and methods legality;
• ensuring Personal Data adequate protection;
• ensuring that the purposes for processing personal data comply with those predetermined and declared during the personal data collection;
• ensure that the personal data processing scope, nature and methods comply with the personal data processing purposes;
• ensure the personal data reliability and sufficiency for processing purposes, and avoid processing personal data that is redundant in relation to the purposes stated when collecting such data;
• ensure that personal data is stored in a format that allows for the data subject identification for no longer than is necessary for processing purposes;
• ensure the Personal Data is destroyed upon the processing objectives completion, unless Russian law establishes a specific storage period for the Personal Data.

Additionally, maintain the processed Personal Data confidentiality and security.

1.3. Legal Basis for Processing Personal Data:

• Labour Code of the Russian Federation;
• Tax Code of the Russian Federation;
• Federal Law No. 27-FZ of 04/01/1996 "On Individual (Personified) Accounting in the Compulsory Pension Insurance System";
• Federal Law of 12/06/2011 No. 402-FZ "On Accounting";
• Regulations on military registration approved by Resolution of the Government of the Russian Federation No. 719 of 11/27/2006;
• Federal Law No. 63-FZ dated 04/06/2011 "On Electronic Signature";
• Agreements concluded between the operator and the subject of personal data, consent to the processing of personal data, other federal laws and regulations.

1.4. The measures outlined in the Law Art. 18.1 and 19 that must be taken are:

• appointment of a person responsible for processing and storage of personal data;
• development and approval of local regulations governing the work with personal data (Regulations on the work with personal data, Personal Data Processing Policy, etc.);
• implementation of internal control and audit of compliance of personal data processing with the legislation of the Russian Federation;
• assessment of damage that may be caused to personal data subjects in case of violation of the legislation;
• familiarisation of the Operator's employees directly involved in personal data processing with the provisions of personal data legislation, including requirements to their protection, documents defining the Operator's policy with regard to personal data processing, local acts on personal data processing, and (or) training of the said employees;
• identification of threats to the security of personal data during their processing in personal data information systems;
• application of organisational and technical measures to ensure the security of personal data during their processing in information systems, necessary to meet the requirements for personal data protection;
• application of information protection means that have passed the conformity assessment procedure in accordance with the established procedure;
• assessment of the efficiency of the measures taken to ensure personal data security before the personal data information system is put into operation;
• accounting of personal data carriers;
• detection of the facts of unauthorised access to personal data and taking measures;
• recovery of personal data modified or destroyed due to unauthorised access to them;
• establishing rules of access to personal data processed in the information system of personal data, as well as ensuring registration and accounting of all actions performed with personal data in the information system;
• control of the measures taken to ensure the security of personal data and the level of protection of information systems and other measures in accordance with the legislation.

1.5. Trans-border transfer of Personal Data: The Operator does not perform cross-border transfer of Personal Data.

1.6. List of actions performed by the Operator with personal data The Operator performs:

• collection;
• systematisation;
• accumulation;
• storage;
• clarification (updating, modification);
• utilisation;
• transfer (provision, access);
• blocking;
• deletion, destruction of Personal Data.

1.7. Processing Personal Data methods by the Operator depending on the information system used by the Operator, Personal Data may be processed by means:

• mixed processing with transmission over the Operator's internal network with transmission over the Internet;
• automated processing without transmission over the Operator's internal network with transmission over the Internet;
• mixed processing without transmission via the Operator's internal network without transmission via the Internet.

1.8. Timeframes for Personal Data processing: Personal Data Processing by the Operator, including storage thereof, shall be carried out within the terms established by the applicable laws and local regulatory acts.

1.9. Personal Data processing procedure and conditions:

1.9.1. Personal Data Processing by the Operator is carried out with the Personal Data Subject to their Personal Data processing consent, unless otherwise provided for by the Russian Federation legislation in the Personal Data field.

1.9.2. The Operator shall not disclose or distribute the Personal Data to third parties without the Personal Data subject consent, unless otherwise provided for by the federal law.

1.10. A request to terminate the transfer (dissemination, provision, access) of the Personal Data permitted for dissemination by the Personal Data the Personal Data subject must include the surname, first name, patronymic (if any), contact information (telephone number, email address or postal address) of the Personal Data subject, the Personal Data a list whose processing is to be terminated, as well as the information resource where they are located.

1.11. Requests executed in accordance with the current legislation requirements are accepted for processing.

1.12. Final provisions: This Policy provisions shall come into force from its approval moment and shall remain in force until its cancellation.