Personal Data Processing Policy
1. General provisions
1.1 This Policy regarding the processing of personal data (hereinafter referred to as the "Policy") has been prepared in accordance with paragraph 2 h. 1 art. 18.1 of the Federal Law of the Russian Federation "On Personal Data" No. 152-FZ dated July 27, 2006 (hereinafter referred to as the "Law") and defines the position of the online platform "Buy Local" (hereinafter referred to as the "Marketplace")in the field of processing and protection of personal data (hereinafter – personal data), with respect to the observance of rights and freedoms, describes the features of the collection, storage, use and transfer of personal data, the requirements for their protection, as well as information about the rights of persons to whom the relevant personal data relate.
1.2 Personal data refers to any information relating directly or indirectly to a specific or identifiable individual (citizen), legal entity (IE, LLC...) (hereinafter – User).
1.3 Personal data processing means any action (operation) or a set of actions (operations) with personal data performed using automation tools and/or without the use of such tools. Such actions (operations) include, in particular: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.4 Personal data security means the protection of personal data from unlawful and/or unauthorized access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data.
1.7 This Policy applies to personal data received both before and after the entry into force of this Policy.
2. Legal grounds and purposes of Personal Data Processing Marketplace
2.1 Marketplace processes and ensures the security of personal data for the implementation of the functions, powers and duties assigned to the Marketplace by the legislation of Russia, including, but not limited to, in accordance with the Constitution of the Russian Federation, federal laws, in particular Federal Law No. 152-FZ of July 27, 2006 "On Personal Data", by-laws, other federal laws of the Russian Federation, guidelines and methodological documents of the FSTEC of Russia and the FSB of Russia, as well as the Civil Code of the Russian Federation, the Tax Code of the Russian Federation, the Law of the Russian Federation No. 2300-1 of February 7, 1992 "On Consumer Rights Protection", Federal Law No. 402-FZ of December 6, 2011 defining the cases and features of the processing of these personal data. "On Accounting", as well as by the operators of personal data, the charter and local acts of the Marketplace.
2.2 The Marketplace is the operator of personal data in accordance with the Law.
2.3 The processing of personal data may be carried out by the Marketplace in the following cases and on the following legal grounds:
- the processing of personal data is carried out only with the consent of the subject of personal data, expressed in any form that allows you to confirm the fact of obtaining consent, including by the methods specified in clause 1.6. this Policy;
- to achieve the goals provided for by an international agreement of the Russian Federation or by law, to perform and fulfill the functions, powers and duties assigned by the legislation of the Russian Federation to the operator of personal data;
- to fulfill the contract of sale of Goods, or another contract between the seller and the user of the Site, who is an individual who has the necessary amount of legal capacity and has the intention to place or place an Order for Goods through the Site, (hereinafter referred to as – "Buyer"), concluded using a Website to which the personal data subject is a party or beneficiary or guarantor, including in the case of the operator exercising its right to assign rights (claims) under such an agreement, as well as to conclude an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor;
- to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided, that the rights and freedoms of the subject of personal data are not violated;
- for statistical or other marketing and research purposes, subject to mandatory depersonalization of personal data.
2.4. The subjects of personal data processed through the Website and the employees of the Contact Center are, among others, the users of the Website, buyers and recipients of Goods (if the buyer specified another person as the recipient of the Goods); any other individuals who apply to the Marketplace with applications / appeals.
2.5 The Marketplace processes personal data, including the following persons:
2.5.1 Buyers (Users) for the purposes of:
- conclusion and execution of contracts, one of the parties to which is the User, in accordance with the Terms of the order and delivery of the Site, including the contract of retail sale of Goods, including a contract for the provision of paid services concluded remotely on the Website;
- provision of information about Goods, Promotions and special offers;
- informing about the status of the Order;
- assistance in settling claims between the Buyer and the Seller;
- fulfilling the Seller's orders in terms of collecting and transferring funds to him in payment for the Goods;
- fulfilling the orders of Sellers and Buyers in connection with the return of Goods;
- posting reviews of Goods and (or) Sellers by Users and Buyers;
- analysis of the quality of the service provided by the Marketplace and improvement of the quality of customer service of the Marketplace;
- identification Users and Buyers in Promotions, ensuring the procedure for accrual, accounting, use of bonus points of loyalty programs of Users and Buyers;
- fulfillment of Marketplace obligations to conduct Promotions;
- in any other cases directly provided for by applicable law.
2.5.2 Recipients of Goods purchased by Buyers for the purpose of delivery of such Goods;
2.5.4 All Users of the Site in order to analyze and improve the quality of service to Users and Buyers.
2.5.5 Employees of the Marketplace in order to implement employment agreements in accordance with the Legislation of the Russian Federation.
2.5.6 Counterparties of the Marketplace, the processing of whose personal data is carried out as part of the implementation of contractual relations between the parties.
3. Categories of personal data processed by Marketplace
3.1 The Marketplace processes the following categories of personal data of Users, recipients
Product: information received during registration and ordering (last name, first name, patronymic,
phone number, email address, cookie), information received during interaction with Customers
(gender, age of the Buyer, passport data, payment means data), in connection with the placement or
execution of the Buyer's Orders (information about the method of delivery of the Goods, the method and status of payment
Of the Goods, and if the final recipient of the Goods differs from the Buyer, also the surname, first name, patronymic, delivery
address and phone number of the consignee), about the claims of the Buyer (transmitted by the Buyer
via the Website, Contact Center or otherwise), reviews of the Goods and
(or) Sellers posted by the Buyer.
3.3 The personal data specified in the paragraphs of this Section above may be obtained
Marketplace in one of the following ways:
- provided by the subjects of personal data by filling out the appropriate forms on the Website,
by sending correspondence or e-mails to e-mail addresses
- received from third parties in the cases provided for in this Section. In particular, the personal data of Buyers can be obtained by the Marketplace directly from Sellers or other counterparties of the Marketplace in connection with the execution of the Seller's orders and (or) the execution of other actions provided for by the current legislation.
4. Principles and conditions of Personal Data processing
4.1 When processing personal data, the Marketplace adheres to the following principles:
- personal data processing is carried out on a legal basis;
- personal data is not disclosed to third parties and is not distributed without the consent of the subject of
personal data, except in cases provided for by the legislation of Russia;
- determination of specific legitimate purposes before the start of processing (including collection) of personal
- combining databases, including databases containing personal data, processing
which is carried out for purposes incompatible with each other, is not allowed;
- the processing of personal data is limited to the achievement of specific, predetermined and
- the processed personal data is subject to destruction or depersonalization upon withdrawal of consent
on their processing by the subject of personal data, to achieve the purposes of processing or in case of loss
the need to achieve these goals, unless otherwise provided by federal law;
- the content and volume of personal data processed correspond to the stated goals
processing. The processed personal data is not redundant in relation to the stated
purposes of processing;
- when processing personal data, the accuracy of personal data and their
sufficiency, if necessary, and relevance of personal data in relation to the
stated purposes of their processing;
- personal data is stored in a form that allows you to determine the subject of
personal data for no longer than the purposes of personal data processing require, if the term
the storage of personal data is not established by federal law, an agreement to which a party,
the beneficiary or guarantor of which is the subject of personal data.
The Marketplace does not perform voice input and verification of personal data using
unsecured data transmission channels. Transfer of data by personal data subjects to employees
The Contact center is voluntary and implies that the data received will be
used in accordance with this Policy.
4.4 The Marketplace has the right to entrust the processing of personal data to third parties with the consent of the subject personal data expressed by providing consent, on the basis of a contract concluded with such third parties, in the following cases:
4.5 to process requests from Buyers and (or) Users, third parties through voice and non-voice communication channels, including email, online chat, mobile device applications and (or) social networks;
4.6 in order to deliver the Goods to Buyers and Recipients;
4.8 Persons who process personal data on the basis of an agreement concluded with the Marketplace (operator's instructions), including Sellers and delivery services, undertake to comply with the principles and rules for processing and protecting personal data provided for by applicable law. For each third party, the contract defines a list of actions (operations) with personal data that will be performed by a third party processing personal data, processing purposes, establishes the obligation of such a person to respect confidentiality and to ensure the security of personal data during their processing, the requirements for the protection of processed personal data are specified in accordance with current legislation.
4.9 The Marketplace has the right to transfer personal data to third parties with the consent of the personal data subject in the following cases :
4.9.1 To Sellers and delivery services for the purposes of fulfilling the Buyer's Order, including, in
case of receiving a request for the return of Goods purchased on the Website, for the purpose of consideration
requirements and the return and the refund in the cases specified in the Rules of the order and
in other sections of the Site, including, subject to obtaining the Marketplace claims of infringement
intellectual or other rights of third parties in order to resolve claims received in the case
further statements, opinions, claims, complaints, messages, or documents addressed to
The seller, in other cases and purposes, as described in the Rules of ordering;
4.9.2 in order to protect the rights and legitimate interests of the Marketplace or third parties in
cases when the subject of personal data violates any conditions of user documents
The Website and (or) this Policy;
4.9.3 by a court decision that has entered into force or in cases established by the current
4.10 In order to comply with the requirements of the current legislation of Russia and its contractual obligations, the Marketplace processes personal data both with and without the use of automation tools. The totality of processing operations includes collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data.
4.11 The Marketplace does not make decisions that generate legal consequences with respect to the subject of personal data or otherwise affect his rights and legitimate interests, based solely on automated processing of personal data.
4.12 The Marketplace does not verify and, as a rule, does not have the opportunity to verify the relevance and
reliability of the information provided by the subjects of personal data obtained through
The site. The Marketplace assumes that the subjects of personal data, acting reasonably and
in good faith, provide reliable and sufficient personal data and keep them up to
5. Rights of personal data subjects
5.1 The subject of personal data, whose personal data is processed by the Marketplace, has the
5.1.1 Change (update, supplement) the personal data provided by them at any time
by logging into the Personal Account in cases where the functionality of the Site allows it;
5.1.2 Delete the personal data provided by them by sending a written
notice to the Marketplace indicating the personal data to be deleted;
5.1.3 Receive from the Marketplace:
- confirmation of the fact of personal data processing and information about the availability of personal data
related to the relevant personal data subject;
- information about the legal grounds and purposes of personal data processing;
- information about the methods of processing personal data used by the Marketplace;
- information about the name and location of the Marketplace;
- information about persons (with the exception of Marketplace employees) who have access to personal
data or to whom personal data may be disclosed on the basis of a contract with the Marketplace
or based on federal law;
- processed personal data related to the subject of personal data and information
about the source of their receipt, unless another procedure for the provision of such personal data does not
provided by the legislation;
- information about the terms of processing of personal data, including the terms of their storage;
- information on the procedure for the exercise by the subject of personal data of the rights provided for
legislation on personal data;
- name and address of persons processing personal data on behalf of
- other information provided by Law;
5.1.4 Require the Marketplace to clarify its personal data, block or
destroy them if the personal data is incomplete, outdated, inaccurate,
illegally obtained or is not necessary for the stated purpose of processing;
5.1.5 Withdraw your consent to the processing of personal data at any time by sending an
electronic message with an electronic signature to the email address: email@example.com, or by
sending a written notification to the Marketplace address after receiving such a message.
the personal data of the personal data subject will be terminated and his personal data will be
deleted, except in cases when processing can be continued in accordance with the
legislation of the Russian Federation. In this case, the direction of such a message about the withdrawal of consent
The User and (or) the Buyer should also be considered a notification of unilateral refusal to
execute the relevant Order and entails the impossibility of its execution;
5.1.6 Demand the elimination of illegal actions of the Marketplace in relation to its personal
5.1.7 Take measures provided for by law to protect their rights and legitimate interests,
including compensation for damages and (or) compensation for moral damage in court.
5.2 The rights provided for in the subparagraphs of this Section above may be restricted in
in accordance with the requirements of the legislation of Russia and (or) in cases where the Marketplace
processes personal data on other legal grounds than the consent of the subject of
6. Responsibilities of the Marketplace
In accordance with the requirements of the Law , the Marketplace is obliged to:
6.2 At the request of the subject of personal data to clarify, block or delete the processed personal data, if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing within a period not exceeding seven working days from the date the subject of personal data or his representative provides information confirming these facts;
6.3 Keep a log of personal data subjects' requests, which should record the requests of personal data subjects to receive personal data, as well as the facts of providing personal data on these requests;
6.4 Notify the subject of personal data about the processing of personal data if the personal data was not received from the subject of personal data. The following cases are an exception:
- the subject of personal data has been notified about the processing of his personal data by the Marketplace
- personal data was received by the Marketplace in connection with the execution of a contract to which
either the beneficiary or the guarantor is the subject of personal data or on
based on the requirements of the current legislation;
- personal data is made publicly available by the subject of personal data or obtained from a
publicly available source;
- The Marketplace processes depersonalized personal data for statistical or
for other research purposes, if the rights and legitimate interests of the
personal data subject are not violated;
- providing the subject of personal data with the information contained in the processing notification
personal data, violates the rights and legitimate interests of third parties;
6.6 If the subject of personal data withdraws consent to the processing of their personal data terminate the processing of personal data and destroy personal data within a period not exceeding thirty days from the date of receipt of the specified recall, unless otherwise provided by the agreement between the Marketplace and the subject of personal data. The Marketplace is obliged to notify the subject of personal data about the destruction of personal data;
6.7 In case of receipt of the personal data subject's request to terminate processing
personal data obtained for the purpose of promoting goods, works, services on the market, immediately
stop processing personal data;
7. Personal data protection
7.1 The Marketplace takes the necessary legal measures when processing personal data,
organizational and technical measures to protect personal data from unlawful and (or)
unauthorized access to them, destruction, modification, blocking, copying,
provision, dissemination of personal data, as well as from other unlawful actions with
respect to personal data.
7.2 Such measures in accordance with, in particular, include:
- appointment of the person responsible for the organization of personal data processing, and the person,
responsible for ensuring data security;
- development and approval of local acts on the processing and protection of personal
- application of legal, organizational and technical measures to ensure security
- control over the measures taken to ensure the security of personal data and the level of
security of personal data information systems;
- assessment of the harm that may be caused to personal data subjects in the event of a violation
requirements of the legislation on personal data, the ratio of the specified harm and accepted
Marketplace of measures aimed at ensuring the fulfillment of obligations stipulated by the
legislation on personal data;
- compliance with conditions that exclude unauthorized access to material media
personal data and ensuring the safety of personal data;
- familiarization of the Marketplace employees who directly process personal data
data, with the provisions of the Russian legislation on personal data, including the requirements for the
protection of personal data, local acts on the processing and protection of personal data,
and training of employees of the Marketplace
8. Terms of processing (storage) of Personal Data
8.1 The terms of processing (storage) of personal data are determined based on the purposes of processing
personal data, in accordance with the validity period of contracts with personal data subjects, the
requirements of current legislation:
- personal data of registered Users is stored for the entire validity period
- personal data of the unregistered User and the recipient of the Goods (if as
the recipient of the Goods is indicated by another person) are stored for three years from the date of execution of the Order
such a User;
- personal data of other persons applying to the Marketplace with statements about the alleged
violation of their rights, during the entire period of processing and consideration of the relevant claims and
within three years from the date of completion of processing and (or) consideration of the claim, if
the legislation does not provide for a different limitation period for the relevant disputes.
9. Procedure for obtaining clarifications on Personal Data processing9.1 Personal data subjects whose personal data is processed by the Marketplace can receive clarifications on the processing of their personal data by contacting personally Marketplace or by sending a corresponding written request to the address of the location Marketplace.
10. Automatically collected information
10.1 The Marketplace may collect and process the following information, including information that
is not personal data:
- information about the interests of Users on the Site based on the entered search queries
users of the Site about the goods being sold and offered for sale in order to provide
up-to-date information to Users when using the Site, as well as generalization and analysis of
information about which sections of the Site and products are in the greatest demand among Users
- information about the interests of the Contact Center Users based on the received requests
Users of the Contact Center in order to provide up-to-date information to Users when
using the Contact Center, as well as generalization and analysis of information about what opportunities
Contact Centers are in the greatest demand among Contact Center Users;
- information that forms the Seller's system rating: user reviews of the Seller,
information about the execution of Orders, other information;
10.2 The Marketplace processes and stores search queries of Site Users in
order to summarize and create client statistics on the use of Site sections.
10.3 The Marketplace automatically receives some types of information received in the process
User interactions with the Site, e-mail correspondence, etc. We are talking about
technologies and services, such as web protocols, cookies, Web tags, as well as third-party applications and
At the same time, Web tags, Cookies and other monitoring technologies do not allow you to
automatically receive personal data. If the User of the Site at his discretion
provides his personal data, for example, when filling out a feedback form or when
sending an email, then only then the processes of automatic collection of detailed
information for the convenience of using websites and (or) to improve interaction with
10.4 If the Marketplace can reasonably correlate the information specified in this Section with
the Account of a particular User, such information may be processed together with Personal Data
Data and other personal information of such User.
11. Policy Changes; Other provisions
11.1 The Marketplace may periodically make changes to this Policy, including to
reflect changes in the scope of services provided by the Marketplace or changes in the functionality of the Site, as
well as changes in legislation. The new version of the above-mentioned provisions and confidentiality
comes into force from the moment of its publication, unless it specifies a different date for its entry into