Confidentiality Policy

  1. General Provisions

    1.1. This Confidentiality Policy (hereinafter referred to as the Policy) was approved by the Joint-Stock Company Management Company of the Russian Direct Investment Fund (hereinafter referred to as the Operating Organization) in accordance with Federal Law No. 152-FZ dated July 27th, 2006 "On Personal Data" to establish the procedures for processing users’ personal data on the website www.sputnikvaccine.com (hereinafter referred to as Users and the Website, respectively).

    1.2. Using some sections on the Website, and some of its services, involves the Users providing personal information to the Operating Organization. In this case, using the Website and its services is only possible when the User first becomes familiar with this Policy, and expresses consent with the terms outlined in the Policy. A User that has provided the Operating Organization with personal data is considered to have expressed consent to having that personal data processed in the manner prescribed in the Policy. Using the Website means that the User provides unconditional consent to this Policy and the conditions governing how personal information is processed that are specified therein; in case any disagreement with these conditions arises, the User must refrain from using the Website.

    1.3. The Operating Organization does not control, and is not responsible for, third-party websites where it is possible for the User to go via the links available on the Website. The relationship between the User and any third parties to ensure confidentiality for personal data provided by the User to those third parties is regulated between the User and these third parties independently.

  2. List specifying the personal data processed by the Operating Organization

    2.1. By providing the Operating Organization with personal data, the User agrees to have the Operating Organization process any and all personal data from the User that the User enters using the registration form on the Website, or otherwise transfers to the Operating Organization, as well as any and all personal data on the User that the Operating Organization independently gains access to owing to how the User uses the Website, including, but not limited to:

    2.1.1. personal information that the User provides on his/her own when using the Website, including the User's personal data. Information that is mandatory to enable using the Website is marked in a distinct manner. Other information is provided by the User at his/her discretion.

    2.1.2 email address

    2.1.3. data that is automatically transmitted to the services offered by the Website through the use of the software installed on the User's device, including IP addresses, data from cookies, information about the User's browser (or other programs through which the services are accessed), the technical characteristics for the equipment and software used by the User, the date and time services are accessed, the addresses of requested web pages, and other similar information.

  3. Principles and objectives of processing personal data. Sources of personal data

    3.1. The Website collects and stores only that personal information which is necessary to provide services or fulfill agreements and contracts with the User, except for cases when legislation calls for the mandatory storage of personal information for a certain period of time as required by law.

    3.2. The Operating Organization processes the personal data that is necessary for it to perform its activities, provided that the rights of the subject of personal data are not violated, and that it is for purposes that do not contradict Russian Federation legislation.

    3.3. Personal data is processed:

    3.3.1. to identify the subject of personal data

    3.3.2. to communicate with the subject of personal data, including for the purposes of sending notifications, requests, and other information, and to process requests and queries submitted by the subjects of personal data

    3.3.3. to conduct statistical, marketing, and other types of research

    3.3.4. to give feedback to the User

    3.3.5. for marketing purposes.

  4. Conditions for processing users’ personal information and transmitting it to third parties 

    4.1. The Website stores Users’ personal information in accordance with the internal regulations that apply to specific services.

    4.2. As far as a User's personal information is concerned, it is kept confidential, except in those cases when the User voluntarily provides information about himself/herself that becomes publicly available to an unlimited number of persons.

    4.3. The Website has the right to transmit a User's personal information to third parties in the following cases:

    4.3.1. The User expressed consent to taking this action.

    4.3.2. Transmitting the information is necessary for the User to use a specific service, or to fulfill a specific agreement or contract that has been entered into with the User.

    4.3.3. Transmitting the information is stipulated by Russian or other applicable legislation in the context of a procedure that has been established by law.

    4.3.4. If the Website is sold, then the purchasing organization takes on all the obligations to comply with the terms of this Policy in respect to the personal information that it receives.

    4.4. Processing a User's personal data is accomplished without any time limits in any lawful manner, including the use of personal data information systems that either incorporate automation tools or do not use those kinds of tools. Users’ personal data is processed in accordance with Federal Law No. 152-FZ dated July 27th, 2006 "On Personal Data".

    4.5. If personal data becomes lost or disclosed, the Website administration informs the User about this loss or disclosure in regard to that personal data.

    4.6. The Website administration adopts the necessary organizational and technical measures to protect Users’ personal information from people gaining unauthorized or accidental access, and from it being destroyed, modified, blocked, copied, distributed, or subject to unlawful action taken by third parties.

    4.7. The Website administration, together with the User, takes all the necessary measures to prevent losses from being incurred, or other negative consequences from arising, that could be caused by the loss or disclosure of that User's personal data.

  5. Obligations of the parties

    5.1. The User is obligated:

    5.1.1. To provide information related to personal data that is necessary to use the Website.

    5.1.2. To update and supplement the information provided related to personal data if there are any changes in that information.

    5.2. The Website administration is obligated:

    5.2.1. To use the information that it receives solely for the purposes specified in this Confidentiality Policy.

    5.2.2. To ensure that confidential information is kept secret, and not disclosed without prior written permission granted by the User, and also not to sell, exchange, publish, or disclose in any other possible manner the personal data transmitted by the User, except as provided for in this Confidentiality Policy.

    5.2.3. To take precautionary measures that protect the confidentiality of the User's personal data in accordance with the procedures usually used to protect this kind of information in current business practices.

    5.2.4. To block personal data related to the relevant User from the time that the User, or the User’s legal representative, or a competent authority that regulates the protection of the rights enjoyed by the subjects of personal data, submits a request or inquiry related to a verification period in case it comes to light that inaccurate personal data exists, or unlawful actions have been taken.

  6. The procedure to revoke consent to process personal data

    6.1. The user has the right at any time to revoke consent given to process personal data. To revoke consent given to process personal data, the User sends written notification about revoking consent to the Operating Organization at the email address [email protected] From the time this notification is received, the Operating Organization stops processing the User's personal data, except in cases where legislation allows processing personal data without the consent of the subject of that personal data. Terminating the processing of a User's personal data may lead to the inability of the User to gain access to some sections and services on the Website.

  7. Obligations borne by the parties

    7.1. If it has not fulfilled its obligations, then the Website administration is liable for losses incurred by the User owing to the unlawful use of that User’s personal data in accordance with Russian Federation legislation.

    7.2. If confidential information is lost or disclosed, then the Website administration is not liable if this confidential information:

    7.2.1. Became public domain before it was lost or disclosed.

    7.2.2. Was received from a third party before the time that it was received by the Website administration.

    7.2.3. Was disclosed after the User provided consent to do so.

  8. Dispute resolution

    8.1. Before filing a claim with the relevant court for disputes that arise from a relationship between the User and the Website administration, it is mandatory to submit a grievance (a written proposal to try to settle the dispute voluntarily).

    8.2. The party that receives the grievance shall notify the party that submitted the grievance in writing within 30 (thirty) calendar days from the date it received the grievance on the results following a review of that grievance.

    8.3. If an agreement cannot be reached, then that dispute will be conveyed to the court for review in conformance with current Russian Federation legislation.

    8.4. Current Russian Federation legislation is applicable to this Confidentiality Policy and the relationship between the User and the Website administration.

  9. Additional terms and conditions

    9.1. The Website administration has the right to make amendments to this Confidentiality Policy without the User’s consent.

    9.2. The Operating Organization has the right to made amendments to this Policy at any time. A new version of this Policy enters into force from the time that the Policy is published on the Website. The User is responsible for independently keeping track of any Policy updates that might be published on the Website.

    9.3. All suggestions or questions related to this Confidentiality Policy can be communicated to the electronic mail address [email protected].

    9.4. The current Confidentiality Policy is posted on the web page located at the address: www.sputnikvaccine.com/policy/.

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