SITE USERS` PERSONAL DATA PROTECTION AND PROCESSING POLICY (PRIVACY POLICY)

1.    General provisions

1.1.    This document defines the policy of the Limited liability company "VPI expo" (hereinafter referred to as "Administration") in relation to the processing of personal data of the Site users- https://www.tellproperty.com  (further also – the "Policy", the "Agreement").
1.2.    The user must be fully acquainted with this Policy prior to using the Site. Using the Site and filling in any forms on the Site means that the User fully and unconditionally accepts this Policy in accordance with article 438 of the Civil code of the Russian Federation.
1.3.    This document is publicly available and is subject to posting on the official website https://www.tellproperty.com
1.4.    Local regulations and other documents regulating the processing of personal data of the Site Users are developed taking into account the provisions of the Policy.
1.5.    The Administration has the right to make changes to this Policy, for reasons related to business practices or regulatory changes, without prior notice to the User and / or obtaining approval from him. When making changes, the Policy header specifies the date when the revision was last updated. The new version of the Policy takes effect from the moment it is posted on the Site, unless otherwise provided for in the new version of the Policy. In this regard, we recommend that you read the Policy when you visit the site again.
1.6.    The Administration has the right, at its discretion, to notify the User of the addition and / or modification of this Agreement in a way that the Administration deems most acceptable. Using the Site, the materials and services offered on it at any time means that the User unconditionally accepts all the terms of this Agreement. If the User does not agree with the current version of this Agreement in whole or in part, they must immediately request the Administration to delete their account and stop using the Site until their account is deleted.
1.7.    By accepting this Agreement by using the Site and filling in any forms posted on it, the User confirms their consent to the processing by the Administration of their personal data provided during registration, as well as voluntarily posted by the User on their personal page in the personal account (if available).
1.8.    The Administration acts as the operator of Personal data, in accordance with the Federal law dated 27.07.2006 N 152-FZ "On personal data", General Data Protection Regulation, GDPR (European Union) 2016/679).
1.9.    This Policy applies to terms and definitions used in accordance with the legislation of the Russian Federation and the usual rules of interpretation of the relevant terms established on the Internet, in particular:
a.    The Users (also referred to as Personal data subjects) are all persons using the official website of the Administration;
b.    The Official site of the Administration (the Site) is the site located at: https://www.tellproperty.com
c.    The Personal data mean any information that can be used to identify your personality and may include, without limitation, the name, photo, email address, postal or other physical address, credit or debit card number, job title, mobile phone number, and other personally identifiable information.
d.    The Operator is the state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and (or) performs the personal data processing, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
e.    The Personal data processing means any action (operation) or a set of actions (operations) with personal data performed using automation tools or without their use. The Personal data processing includes, among other things: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
1.10.    The users` personal data processing is carried out in connection with the conclusion of a Service agreement with the User or the company represented by the User.

2.    Purposes of personal data collection and processing

2.1.    The Administration collects and / or processes the Personal data when the User orders (registers) and receives the services provided by the Administration on the Site, including under separate agreements, as well as when using or otherwise interacting with the Administration's products posted on the Site.
2.2.    The Administration collects and / or processes the Personal data in order to be able to fully use the Site, provide the User with the services offered by the Administration on the Site, participate in research and marketing activities conducted by the Administration.
2.3.    The Administration collects and stores only the personal information that is necessary for the provision of the Site's services or the execution of agreements and contracts with the User, except in cases where the law provides for mandatory storage of personal information for a period determined by law, including for the purpose of:
- User identification;
- providing the User with personalized services;
- communication with the User, including sending notifications, requests and information related to the use of the Site, the provision of services, as well as processing requests and applications from the User;
- conducting statistical and other research based on depersonalized data;
- conducting marketing campaigns for the Users, including for the purpose of distributing offers to participate in the promotion and receiving prizes/rewards provided for by the promotion;
- distribution of advertising and information materials over telecommunication networks, including through the use of telephone, Internet, mobile radiotelephone communications, or through direct contacts;
- targeting mailing lists, advertising materials, and other information brought to the attention of the Users.
3.    Volume of the Personal data processed
3.1.    Within this Policy, the User's Personal information includes:
- personal information that the User provides about themselves on the Site or as part of the execution of an agreement concluded with the Administration, such as: name, photo, email address, phone number, place of work;
- data that is automatically transmitted to the Administration during the use of the Site with the software installed on the User's device, including: IP address, cookie information, information about the User's browser (or other program that allows access to the Site's services), access time, the address of the requested page, as well as other data, including those provided by the User after registration, during the use of the Site.
3.2.    The Administration, for its part, synchronizes the search history, settings and favorites in the User's personal account or the company that the User represents.
4.    Procedure and conditions for processing personal data
4.1.    The Administration has the right to:
- perform any actions (operations) or a set of actions (operations) performed using automation tools or without using automation tools with the Site User's personal data (personal data processing), including collection, recording, copying, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access) to third parties, as well as in cases directly provided for by the current legislation of the Russian Federation, in compliance with the requirements of information confidentiality, depersonalization, blocking, deletion or destruction of personal data. The User confirms that by giving such consent to the processing of their personal data, they act of their own will and in their own interest.
- use cookies and similar technologies (including: pixel tags, web beacons, transparent GIF files, JavaScript and local data storage, etc.) to collect personal identification information or the information that may become personal identification information in combination with other information, in compliance with all necessary legal requirements regarding the privacy of Users' personal data, by identifying users, counting their number and monitoring which pages of the Site they visit, to guarantee maximum user convenience by providing personalized information, remembering their marketing and product preferences, and helping them get the right information (including for accessing secure areas of the Site or using a virtual shopping cart), analyzing User actions on the Site, in order to improve and optimize the Site, including making it easier for visitors to find the necessary information on the Site;
- provide advertising, messages and content, including by sending SMS advertising notifications (messages), advertising notifications and messages, via e-mail on the Internet, using the services and databases of both the Site itself and the services of third-party (external) sites and resources on the Internet;
- communicate directly with the User, including via telephone.
4.2.    The Administration has the right to use the information provided by the User, including personal data, in order to ensure compliance with the requirements of current legislation (including in order to prevent and/or suppress illegal and/or unlawful actions of the Users). Disclosure of the information provided by the User may be made only for the purpose of fulfilling the agreement concluded with the User, in accordance with current legislation, at the request of the court, law enforcement agencies, as well as in other cases stipulated by law.
4.3.    The personal data are processed from the moment the User fills out the appropriate form for providing services on the Site, or provides personal data in another form, and until the termination of relations between the Administration and the User as a result of deleting their account, or revocation of consent to the personal data processing by the person who provided such data in another form.
4.4.    The Administration has the right to transfer the User's personal data to third parties in the following cases:
- transfer (including cross-border) is necessary for the User to receive a certain service of the Site (the Administration's performance of the agreement to provide the User with the services ordered by the User on the Site). Cross-border transfer of user information (including personal data of Users) can be carried out to the foreign states that are parties to the Council of Europe Convention on the protection of individuals in the automated processing of personal data, as well as other foreign states that provide adequate protection of the rights of personal data subjects. In accordance with article 12 of the Federal law "On personal data", the Administration does not carry out cross-border transfer of personal data if such transfer is prohibited or restricted in order to protect the foundations of the constitutional system of the Russian Federation, morality, health, rights and legitimate interests of citizens, to ensure national defense and state security. When performing cross-border transfer of personal data of users, the Administration complies with the applicable legislation of the Russian Federation and the foreign country to which the personal data is transferred. Prior to the start of cross-border transfer of personal data, the Administration makes sure that the receiving foreign state is in the process of ensuring adequate protection of the rights of the subject of the transferred personal data;
- the transfer is provided for by Russian or other applicable law in accordance with the procedure established by law;
- the transfer takes place as part of the sale or other transfer of the Site (in whole or in part), while the buyer assumes all obligations to comply with the terms of this Policy in relation to the personal information received by them.
By accepting the terms of this Policy, the User agrees to transfer their data to third parties in the above cases. The User's separate consent to this transfer is not required.
In other cases, the Administration has the right to transfer the User's personal data to third parties if the User has expressed their consent, in writing or in any other form that does not contradict the law, to such actions.
4.5.    The Administration does not sell or lease Personal data to third parties for marketing purposes without first obtaining permission from the Users.
4.6.    Access to personal data of the Users is possible within the Administration and its employees.
4.7.    The Administration will make every reasonable effort to ensure that:
- confidential information about Users is collected by the Administration only in the minimum necessary amount;
- confidential information is used exclusively for the purposes stated when it was collected;
- confidential information does not fall into third hands, except as stipulated in this Agreement, the laws of the Russian Federation or the applicable laws of a foreign country.
4.8.    The Administration stores Personal data and ensures their protection from unauthorized access and distribution in accordance with the internal rules and regulations. The User's Personal data is kept confidential, except in cases when the technology of the Site or the settings of the software used by the User provide for an open exchange of information with other users of the Site or with any Internet users.
4.9.    The User's personal information is kept confidential, except for cases when the User voluntarily provides information about himself for General access to an unlimited number of persons.
4.10.    The Administration ensures confidentiality and security of personal data when processing them in accordance with legal requirements. The administration applies appropriate standards of technological and operational security to protect the information provided by visitors to our website from unauthorized access, disclosure, distortion or destruction
4.11.    The Personal data is stored on the Site until the User stops using the Site. If data are deleted from the Site at the initiative of one of the parties, the User's personal data are stored in the Administration's databases for no more than six months, in accordance with the legislation of the Russian Federation.
4.12.    Upon expiration of the above-mentioned period of storage of the User's personal data, the User's personal data are destroyed. The destruction of personal data is carried out by erasing the information using certified software with guaranteed destruction (in accordance with the specified characteristics for the installed software with guaranteed destruction)
4.13.    The User's Personal data is stored by the Administrator exclusively on electronic media and processed using automated systems, except in cases when non-automated processing of personal data is necessary due to the fulfillment of the requirements of the Russian Federation legislation.
4.14.    The data collected about Users in Russia is securely stored on servers located in Russia. The data collected about Users in other countries is stored on the servers of Google, which is known for its attitude to security, and this data are decentralized.
5.    User rights
5.1    The User can at any time change (update, supplement) the personal information provided by them or part of it, as well as the parameters of its confidentiality, by making a change in the Order or notifying the Site Administration by sending a corresponding email to the email address: support@vpiexpo.ru.
5.2    The User may at any time revoke the consent given for personal data processing subject to a written notice in advance through the communication channels listed on the Website, not less than 90 days prior to the date of termination of the processing and use of personal details provided by them.
6.    Final provisions

6.1.    The Site may contain links to websites and other information resources of third parties on the Internet, placed solely for the convenience of Users. The Administration does not declare its approval and does not give any estimates of third-party sites or information contained on these sites, as well as possible results of their use, as well as does not check the accuracy and relevance of the given information. The User is solely responsible for the use of third-party sites.
6.2.    This Policy applies only to the Site's services. The Administration does not control and is not responsible for third-party sites / services to which the User can click on links available from the Site's services, including the information about the User processed by third parties.
6.3.    The User is solely responsible for the security (resistance to selection) of the selected means for accessing the account, and also independently ensures their confidentiality. The User is solely responsible for all actions (as well as their consequences) within or using the Site services under the User's account, including cases when the User voluntarily transfers data for access to the User's account to third parties on any terms (including under contracts or agreements). In this case, all actions within or using the Site's services under the User's account are considered to be performed by the User themselves.
6.4.    The persons who process personal data must comply with the requirements of the Administration's regulatory documents in terms of ensuring the confidentiality and security of personal data.
6.5.    The Site is not intended or specifically targeted for use by persons under the age of 18. The Policy does not provide for the intentional collection or storage of personal information of persons under the age of 18 without obtaining permission from their authorized legal representative. If you are a parent or guardian, or other legal representative of a child, and you find out that your children have provided us with personal information, please contact the Administration. If the Administration receives information about the fact of collecting personal information from a child under the age of 18 without confirming the consent of his legal representative, the Administration undertakes to take measures to delete this information from its servers.
6.6.    If the materials provided by the User contain data, including images, of third parties, including minors, the User guarantees that they have obtained the necessary permissions and consents to use them in accordance with the terms of this Policy.

Administration details:
«VPI expo» LLC
OGRN 5157746168993, ITN 7702395176
Address: 127047, Russia, Moscow, 1st Shemylovsky lane 16
e-mail: info@vpiexpo.ru