Privacy policy

This Privacy Policy (terms of processing information about users) of Rostelecom Information Technologies Limited Liability Company (hereinafter referred to as «RTK IT» LLC / Operator) (hereinafter referred to as the Terms) applies to information and data that the Operator may obtain about the User. The Terms are applicable only to the Operator's Services. The Operator does not control and is not responsible for websites/services of third parties, to which the User can access via links available on the Operator's Services, including information about the User processed by third parties.

Use of the Operator's Services means that the User agrees with the Terms and Conditions and the procedure for processing his/her personal information specified therein; in case of disagreement with these terms, the User shall refrain from using the Operator's Services.

Other documents of the Operator determining the terms of use of certain of its Services or certain functionalities (add-ons) provided by such Services, including joint partnership projects and services of Internet sites, may determine additional terms, composition, collection, storage, protection, processing and distribution of information about Users.

These Terms shall take precedence over the above-mentioned documents, which shall be applied only if they do not contradict these Terms and provided that these documents do not explicitly state or the contrary does not follow from them that their provisions regarding the protection of Users' information and (or) the procedure of its processing by the Operator within a certain Operator's Service shall prevail.

1. Terms and definitions used in the Conditions

1.1. For the purposes of these Terms and Conditions, the following terms shall be used with the following meaning: Operator - Limited Liability Company Rostelecom Information Technologies (LLC RTK IT) address of location: Russian Federation, 142784, Moscow, Moskovsky settlement, Kievskoe highway, 22nd km, building 6, p.1 office E434 (office park Komsity), postal address: Russian Federation 108811, Russian Federation, Moscow, 22nd kilometre Kievskoe Shosse (Moskovskoe settlement), 22nd km, building 6, building 1, office E434.OGRN 1095030001131, TIN 5030065734.

User - a natural person, an Internet user who uses the Operator's Internet sites for his/her own purposes, as well as other natural person in whose interests this user acts.

Operator's Service(s) - any of the Operator's Internet sites, computer programmes (mobile applications) running Android, iOS and other operating systems, as well as directly products and (or) services provided by the Operator via Internet sites.

2. Information of Users that may be received and processed by the Operator

2.1. In accordance with these Terms and Conditions, information about the Users of the Operator's Services includes:

2.1.1. Information that the User provides about himself or herself or through a third party:

• during registration on any of the Operator's Services (account creation), such as name, phone number, e-mail address, address of service provision;
• in the process of using the Operator's Service (such as date and time of accessing the Service);
• when communicating with the Operator (information necessary for processing the user's request);
• when using services (interfaces) of third parties, including within the framework of OpenID and OAuth protocols;
• payment card data, other payment information provided by the User, as well as received from persons involved in the payment transaction using the Services. The use of certain Operator's Services or their separate functionality by the User is possible only if the necessary data is provided.

2.1.2. Standard data automatically received by the http-server when the User accesses the Operator's Service (host ip-address, address of the requested resource, time, type and information about the viewer that sent the resource request, type of the user's operating system, address of the Internet page from which the transition to the requested resource was made, header containing the session identifier for the authorised user);

2.1.3. Information automatically received when accessing the Operator's Services and stored on the browser side, including but not limited to information contained in bookmarks (cookies) (hereinafter - information stored on the browser side);

2.1.4. Information on geolocation, in case of implementation of the relevant technologies on the Operator's Services and setting of the relevant settings by the User in the browser and/or when using a mobile application (computer software);

2.2. Except for cases of identification of Users on the grounds and in accordance with the procedure stipulated by the current legislation of the Russian Federation and applicable agreements of the Operator with the User, the Operator does not verify the reliability of personal information provided by the User. However, the Operator assumes that the User provides true and sufficient personal information and keeps this information up to date.

2.3. All information collected, stored and processed by the Operator about Users is considered restricted information, unless otherwise provided for by the legislation of the Russian Federation or these Terms and Conditions.

3. Applicable legislation

3.1. The legislation of the Russian Federation and regulations governing relations in the field of personal data security shall apply to these Terms and Conditions and relations between the Users and the Operator arising in connection with the application of the Terms and Conditions.

• We may share or transfer your information in connection with, or during negotiations about, any merger, sale of company assets, financing or acquisition of all or part of our business by another company

4. Terms of accessing the Operator's Services

4.1. The Operator assumes that the User initiating access to the Operator's Services

4.1.1. Knowingly uses the Operator's Services on his/her own behalf and truthfully indicates information about himself/herself to the extent and in cases when it is required when registering, accessing and using the Operator's Services;

4.1.2 Consciously determines and controls the settings of the software he/she uses in accordance with his/her preferences regarding the protection of information stored on the browser side, personal data, information about his/her own hardware and software and Internet connection;

4.1.3. has the opportunity to familiarise himself/herself with the rules and protocols of information exchange set forth in the open standards of the Internet (rfc-editor.org);

4.1.4. Has familiarised himself and has the opportunity to familiarise himself at any time with the current Terms and Conditions by clicking on the hypertext link placed on the Operator's Service, with the terms of use of the relevant Operator's Services.

4.1.5 By filling in the registration form on the Operator's Services and providing his/her personal data to the Operator, the User confirms that he/she accepts the terms and conditions of such Services, as well as these Terms and agrees to the processing of his/her personal data by the Operator in accordance with the terms and conditions of such Services and these Terms. The specific list of personal data to be processed together with the purposes and terms of processing are set out in Appendix No. 1 to the Terms, and may also be specified in the agreement on the use of the Service.

4.1.6 By providing data of third parties necessary for using the Operator's Service, the User confirms that he/she has received the consent of such persons to the processing of their personal data or that the User is authorised to express consent on behalf of such persons.

4.2 When registering and accessing the Operator's Services, the User is prohibited to provide false and/or incomplete information about himself/herself. The User shall bear the risks of any unfavourable consequences in cases of providing false and/or unreliable personal data.

4.3 The consent provided by the User when using the Operator's Services and communicating his/her personal data and (or) personal data of third parties to the Operator extends to any processing (by any means), if it is aimed at ensuring the possibility of using the Operator's Services according to their purpose, including for the purposes of maintaining the operability of the Operator's Services, analysing information on their use, performing actions aimed at connecting the User to the Operator's services, including conclusion of a contract on behalf of the Operator.

4.4 The Operator is not responsible for the fact that the User is really the person on whose behalf the registration and/or use of the Operator's Service was made, and is not liable for possible damage caused to other Users or other persons in case the User is not such a person.

4.5 Unless otherwise provided by the Terms and Conditions, the Operator does not assume any obligation to verify the accuracy of personal data provided by the User, and is not liable if the User provides more data than it is provided for by the registration form and the purposes of personal data processing. By providing more personal data than it is provided by the registration form and the purposes of personal data processing, the User expresses their consent to the processing of such personal data by the Operator.

4.6 When registering and/or using the Operator's Services, the User may use the User's accounts in social networks. At the same time, the Operator does not process more data (i.e. does not take data from social networks), can only process the data specified in Appendix No. 1 to the Terms and Conditions.

4.7 The mixed processing of personal data of the Users and other persons whose personal data are specified during registration and use of the Operator's Services, i.e. both processing without the use of automation tools and automated processing with the transmission of the received information using the Internet is envisaged.

4.8 This consent is granted for the entire period of use of the Operator's Services according to its purpose, as well as 3 (three) years after the termination of such use, unless otherwise provided for by the legislation of the Russian Federation.

4.9. The User is aware that he/she may withdraw consent to the processing of personal data by submitting a paper or electronic application to the Operator, including by using his/her account (account) on the Operator's Service, specifying in such application the data provided for by the Federal Law No. 152-FZ «On Personal Data» dated 27.07.2006.

4.10. In case of receipt of revocation of the User's consent to the processing of personal data in paper form, the Operator, in order to identify the subject of personal data, has the right to request from such person additional information provided by the subject of personal data when registering on the Service, or ask such person to send an electronic request for revocation of consent to the processing of personal data through the relevant account (account) of the subject of personal data on the website.

If the person who requested such additional actions fails to do so, the Operator shall have the right to refuse to revoke such person's consent to the processing of personal data in order to protect the rights of third parties.

If the User or third parties, whose personal data were received by the Operator from the User, revoke the previously issued consent to personal data processing, the said subjects will not be able to use the Operator's Services and the services and opportunities provided with its help.

4.11. The Operator has the right to continue processing the User's personal data after the User revokes his/her consent in cases stipulated by the legislation of the Russian Federation. At the same time, the User is notified that he/she continues to bear responsibility established by the legislation of the Russian Federation in case of specifying incorrect contact data, as well as data of third parties without obtaining appropriate authorisation from them.

5. Collection and processing of information about Users

5.1 The Operator processes information about Users in accordance with these Terms and Conditions, terms and conditions of specific Operator's Services and internal regulations.

5.2 The Operator collects and processes only that information which is necessary for provision of the Operator's Services, execution of agreements with the User, except for cases when the legislation provides for mandatory receipt and storage of certain information. The information shall be stored no longer than required for the purposes of processing, unless the period of storage of such information is established by the legislation of the Russian Federation, the agreement on the User's use of the Operator's Services.

5.3 The Operator may process the User's information for the following purposes:

5.3.1 Conclusion and execution of User's agreements with the Operator, including for the purposes of User identification, creation of User's accounts, use of other Operator's Services by the User;

5.3.2 Communicating with the User, including sending notifications, requests and information regarding the use of the Operator's Services, as well as processing requests and applications from the User;

5.3.3 Processing is necessary to fulfil the rights and legitimate interests of the Operator, for example, in the following cases:

(a) improving the quality of the Operator's Services, their usability;
(b) development of new Operator's Services;
(c) offering personalised Operator's Services to the User;

5.3.4 Carrying out statistical and other research on the basis of anonymised data;

5.3.5 Detecting and (or) preventing conditions that promote the use of the Operator's Services for illegal or prohibited by the rules of the relevant Operator's Services.

5.3.6 Increasing the loyalty of Users to the Operator's Services.

5.3.7 Identifying and eliminating errors in the Operator's software.

5.3.8. Processing is necessary for compliance with the statutory obligations.

6. Protection of information

6.1 The Operator shall take all reasonable measures to protect information about Users from destruction, distortion or disclosure.

6.2 The Operator shall ensure confidentiality of the relevant information within the limits and under the conditions established by the current legislation of the Russian Federation and these Terms and Conditions.

7. Access to information about Users

7.1 In addition to the Operator, the following persons have access to information about Users, subject to the requirements of the legislation of the Russian Federation:

7.1.1. Persons whose rights and obligations to access the relevant information are established by the federal laws of the Russian Federation;

7.1.2. Users of the Operator's Services in terms of access to the information identifying their identity (personal data of Users) using the password and login specified by them during registration;

7.1.3. Operator's Partners in relation to joint partnership projects and Operator's Services within the limits and on the terms and conditions established by the relevant documents determining their use;

7.1.4. Users of other projects and Services of the Operator within the limits and on the terms and conditions established by the relevant documents of the Operator determining their use;

7.1.5 Persons and organisations providing technical support of the Operator's Services to the extent necessary for such technical support, provided that they observe confidentiality of information about Users;

7.1.6. the Operator has the right to involve third parties in processing information about the User by assigning third parties to process such data. Involvement of third parties in data processing may be carried out only on condition that such third parties process the data in the minimum necessary composition and exclusively to achieve the purpose of data processing stipulated by the consent, as well as on condition that such third parties ensure confidentiality and security of data processing and consent to transfer of personal data. Third parties include, in particular, the counterparties listed in Appendix No. 2 to the Terms and Conditions.

8. User's rights in relation to information

8.1 The Operator guarantees observance of the following rights of the User of the Operator's Services:

8.1.1 The right to be informed whether the Operator is processing personal data;

8.1.2. The right to delete the processed personal data;

8.1.3 The right to edit, clarify or correct the processed personal data provided that the requirements of these Terms and Conditions are met. Deletion of personal data shall take place within 3 (three) working days from the date of receipt of the User's request and may result in the inability of the User to use the relevant Operator's Services.

8.1.4 The Operator has the right to delete information about the User in case the latter violates the Operator's regulatory documents, including those determining the terms of use of certain Operator's Services.

8.2 The User has the right to disseminate his/her personal data by any lawful means. The Operator is not liable for the actions of third parties who have gained access to the information about the Users as a result of such dissemination, or have unauthorised access to the protected information about the Users.

9. Restrictions on the use of Users' information

9.1 If a User becomes aware of another User's login and password, as well as other confidential information about the latter, he/she is obliged to notify the Operator and not to use the information that has become known to him/her.

9.2 The Operator uses information about Users for the purposes of analysing the interests and preferences of users, adapting the Operator's Services according to the results obtained from the above analysis, as well as for the purposes of advertising on the Operator's Services to the extent necessary to show it to the target audience. The information from the Users' profiles is not used by the Operator to send any information to the Users, except for the cases stipulated by the rules (regulations) of using the relevant Operator's Services or at their explicit request.

10. Use of Information Stored on the Browser Side

10.1 The Operator uses the information stored on the browser side, in accordance with the purposes defined in these Terms and Conditions, to determine the unique identifier of the User's access to the Operator's Services, for the following purposes:

10.1.1 Supporting the functioning of resources that require the use of information stored on the browser side;

10.1.2 Displaying advertisements to the target audience;

10.1.3 Measuring the size of the Services' audiences, their aggregations and overlaps;

10.1.4. Determination of statistical information preferences of Users when accessing different Operator's Services;

10.1.5. Determining for research purposes the correlation of statistical data on the attendance of the Services with sociometric data on the Operator's Users.

10.2 The User may prohibit the use of information stored in the browser on his/her computer (mobile device) by configuring the software, but this may result in partial or complete loss of functionality of the Operator's Services.

10.3 The Operator has the right to provide the relevant information to the persons specified in clause 7 of these Terms.

11. Access to services and Internet resources of third parties

11.1 The User's access to the Operator's Services may cause access to third party services and Internet resources and download from them programme code and/or graphic objects (including those invisible when Internet pages are displayed by a browser) used for advertising purposes and for the purposes of collecting statistics.

11.2 The owners of Internet resources have the technical capability to collect information about Users and independently determine the conditions of its use.

11.3 By configuring the software, the User has the ability to block requests for graphic images hosted on third-party servers, but this may lead to loss of readability and errors in the display of resources.

11.4 When Users switch from the pages of the Operator's Services to the pages of third party services and Internet resources, Users independently determine the limits of using information about them within the terms and conditions and rules determined by the owners of the relevant services and Internet resources. The latter have the technological ability to access the information stored on the browser side and are responsible for observing the rights of users in connection with its use.

12. User communications

12.1 The Operator considers requests related to these Terms and Conditions, including requests from Users regarding the use of their personal data via the feedback form.

12.2 The term of response to the received requests is 30 (thirty) working days from the date of receipt of the respective requests. Anonymous appeals are not considered. All correspondence sent by Users to the Operator (letters in regular or electronic form) is considered by the Operator as restricted information and may be published only with the written consent of the User, and addresses, personal data and other information about Users who sent these letters may not be used without their special consent except for answering the subject of the received address.

13. Access to the Terms and Conditions

13.1 These Terms and Conditions are an open and publicly available document. The current version is available on the Internet via the Internet link at the following address

13.2 The Operator is entitled to offer the User to amend and/or supplement these Terms and Conditions by publishing the Terms and Conditions in a new version on the website at the address specified in clause 13.1 of the Terms and Conditions. The User's acceptance of such an offer shall constitute a conclusive action to use any of the Operator's Services on the new terms and conditions.