ROSWOOD LLC
8 (423) 249-54-60
RU EN
ROSWOOD LLC
RU EN

Privacy Policy

1. General Provisions

1.1. This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter, the Personal Data Law) and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by ROSWOOD Limited Liability Company (ROSWOOD LLC), INN 2540166519, OGRN 1102540007437, registered address: Office 302, 35B Bestuzheva St., Vladivostok, 690003, Russian Federation, represented by General Director Valery Gennadyevich Loginov, acting pursuant to the Charter (hereinafter, the Operator).

1.2. The Operator considers respect for the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy and personal and family confidentiality, to be a fundamental objective and condition of its activities.

1.3. This Personal Data Processing Policy of the Operator (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website http://roswood.com/.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify personal data.

2.3. Website means the collection of graphic and information materials, computer programs and databases that make them available on the Internet at http://roswood.com/.

2.4. Personal data information system means a set of personal data contained in databases together with the information technologies and technical means used to process such data.

2.5. Depersonalisation of personal data means actions as a result of which it is impossible, without the use of additional information, to determine that personal data relates to a specific User or other personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data using automated means or without such means, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalisation, blocking, deletion and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with other persons, organises and/or carries out the processing of personal data and determines the purposes of personal data processing, the personal data to be processed and the actions (operations) performed on personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website http://roswood.com/.

2.9. Personal data authorised by the personal data subject for dissemination means personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorised by the personal data subject for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter, personal data authorised for dissemination).

2.10. User means any visitor to the website http://roswood.com/.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed so that the content of the personal data cannot subsequently be restored in the personal data information system and/or the physical media containing the personal data is destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

  • obtain reliable information and/or documents containing personal data from the personal data subject;
  • where the personal data subject withdraws consent to the processing of personal data or submits a request to cease processing personal data, continue processing personal data without the subject’s consent where grounds specified in the Personal Data Law apply;
  • independently determine the composition and list of measures necessary and sufficient to ensure performance of the obligations provided for by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

  • provide the personal data subject, at their request, with information concerning the processing of their personal data;
  • organise the processing of personal data in accordance with the applicable legislation of the Russian Federation;
  • respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • provide the authorised body for the protection of personal data subjects’ rights, at that body’s request, with the required information within 10 days of receiving such request;
  • publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
  • take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions involving personal data;
  • cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and circumstances provided for by the Personal Data Law;
  • perform other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

  • receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator provides such information to the personal data subject in an accessible form, and it must not contain personal data relating to other personal data subjects unless there are lawful grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • require the Operator to clarify, block or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take measures provided by law to protect their rights;
  • require prior consent as a condition for processing personal data for the purpose of promoting goods, works and services on the market;
  • withdraw consent to the processing of personal data and submit a request to cease processing personal data;
  • appeal to the authorised body for the protection of personal data subjects’ rights or to a court against unlawful acts or omissions of the Operator in processing their personal data;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with accurate information about themselves;
  • inform the Operator of any clarification (update or change) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected is not permitted.

5.3. Databases containing personal data processed for mutually incompatible purposes may not be combined.

5.4. Only personal data that meets the purposes of processing is processed.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not permitted.

5.6. When processing personal data, the accuracy and sufficiency of personal data and, where necessary, its relevance to the purposes of personal data processing are ensured. The Operator takes or ensures the taking of necessary measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that permits identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Personal data being processed is destroyed or depersonalised once the purposes of processing have been achieved or where it is no longer necessary to achieve those purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

The Operator processes personal data for the following purposes:

Purpose 1. Providing consultations regarding the Operator’s services and processing incoming enquiries from the website

Personal data:

  • surname, first name and patronymic
  • email address
  • telephone number

Legal basis: consent of the personal data subject (clause 1, part 1, Article 6 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”).

Purpose 2. Collecting website traffic statistics and analysing User behaviour

Personal data:

  • information collected by analytics tools (cookies, IP address, browser data and device location information)

Legal basis: consent of the personal data subject (clause 1, part 1, Article 6 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”).

Types of personal data processing: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), deletion and destruction of personal data.

7. Conditions for Personal Data Processing

7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

7.2. Processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice and enforcement of a judicial act or an act of another authority or official that is enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.

7.6. Personal data is processed where access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter, publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data

The security of personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to comply fully with the requirements of applicable personal data protection legislation.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorised persons from accessing personal data.

8.2. The Operator may entrust the processing of personal data to third parties on the basis of agreements entered into with them. At present, the following parties process personal data on behalf of the Operator:

  • Beget LLC (INN 7801451618) — provision of hosting for the Operator’s website;
  • Yandex LLC (INN 7736207543) — provision of the Yandex Metrica web analytics service.

Personal data is transferred to the above parties solely to the extent necessary for them to perform their assigned functions and in accordance with the requirements of the legislation of the Russian Federation on personal data.

8.3. If inaccuracies in personal data are identified, the User may update the data by sending the Operator a notice to info@roswood.com with the subject line “Personal Data Update”.

8.4. The period of personal data processing is determined by achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable legislation. The User may withdraw consent to personal data processing at any time by sending the Operator a notice by email to info@roswood.com with the subject line “Withdrawal of Consent to Personal Data Processing”.

8.5. All information collected by third-party services, including payment systems, communications services and other service providers, is stored and processed by those parties (operators) in accordance with their user agreements and privacy policies. The personal data subject is responsible for reviewing those documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Restrictions imposed by the personal data subject on transfer (except provision of access), as well as on processing or conditions of processing (except obtaining access), of personal data authorised for dissemination do not apply where personal data is processed in state, public or other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing it.

8.8. The Operator stores personal data in a form that permits identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.

8.9. Personal data processing may cease when the purposes of processing have been achieved, the personal data subject’s consent has expired, the personal data subject withdraws consent or requests that processing cease, or unlawful processing of personal data is identified.

8.10. Use of Cookies and Web Analytics Services

The website http://roswood.com/ uses cookies and the Yandex Metrica web analytics service.

Cookies are small text files stored on the User’s device when visiting the website. They make it possible to identify the User’s device and remember the User’s preferences.

Yandex Metrica collects the following information: cookies, IP address, location information, browser information, technical characteristics of the device, date and time of the visit, addresses of pages viewed, and information about the User’s actions on the website.

This information is processed by Yandex LLC (INN 7736207543, address: 16 Leo Tolstoy St., Moscow, 119021, Russian Federation) for the purposes of collecting website traffic statistics and analysing User behaviour.

The User may disable cookies in their browser settings. However, this may affect the operation of certain website functions.

By continuing to use the website http://roswood.com/, the User consents to the processing of cookies and the use of Yandex Metrica.

8.11. Procedure for Destruction of Personal Data

The Operator destroys personal data in the following cases:

  • achievement of the purposes of personal data processing;
  • withdrawal by the personal data subject of consent to personal data processing;
  • expiry of the personal data retention period established by an agreement or legislation;
  • identification of unlawful personal data processing.

Personal data is destroyed within 30 days of the relevant ground arising.

Personal data contained in information systems is destroyed by its irreversible deletion from databases.

Personal data on paper media is destroyed by mechanical shredding or burning.

9. Actions Performed by the Operator with Personal Data Received

9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalises, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without receipt and/or transfer of the information obtained via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities involving cross-border transfer of personal data, the Operator must notify the authorised body for the protection of personal data subjects’ rights of its intention to carry out cross-border transfer of personal data. Such notification is submitted separately from the notification of the intention to process personal data.

10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to whom personal data is planned to be transferred across borders.

11. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data must not disclose personal data to third parties or disseminate it without the consent of the personal data subject unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain clarification on any matters concerning the processing of their personal data by contacting the Operator by email at info@roswood.com.

12.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at http://roswood.com/en/privacy-policy-2/.