Privacy policy

1. GENERAL PROVISIONS

1.1. This Privacy and Personal Data Processing Policy for users of the website kritter.ru (hereinafter referred to as the Privacy Policy or Operator’s Policy) of the Limited Liability Company “Universal Cigarette Manufactory” (hereinafter — LLC “UCM”, the Company, the Operator) applies to all information that this website may receive about the User, including their personal data.

1.2. The following terms are used in this Privacy Policy:

• “Operator” – the legal entity LLC “UCM” (TIN 7743228819, KPP 390601001, registered address: 236022, Kaliningrad Region, Kaliningrad, Gostinaya St., Building 5, Room Х, Office 48);

• “Personal data” – any information relating directly or indirectly to an identified or identifiable individual (personal data subject);

• “Website” – the official website of LLC “UCM”, kritter.ru;

• “Processing of personal data” – any action (operation) or set of actions (operations) performed by the Operator with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

• “Confidentiality of personal data” – a mandatory requirement for the Operator to prevent the intentional distribution of personal data received through the website kritter.ru without the consent of the personal data subject or other legal grounds.

• “User/Website User (hereinafter referred to as User)” – a person who has access to the website kritter.ru via the Internet and uses the website for their own purposes. This person is the personal data subject.

1.3. This Policy applies to all information that the Operator may obtain about Users of the website kritter.ru. Personal data is processed in accordance with Federal Law No. 152-FZ “On Personal Data”.

• “Cookies” – small text files that the Website sends to your browser and stores on the User’s computer to retain information about the visit. They are used for various purposes such as remembering settings, automatic login, personalizing content, and tracking user activity on the Website.

1.4. Using the Website services implies the User’s unconditional consent to this Policy and the terms of processing their personal data specified herein. If the User disagrees with these terms, they must refrain from using the Website services.

1.5. LLC “UCM” does not verify and is not responsible for the accuracy of the personal data provided by the Website User.

1.6. All persons who have entered personal data on the Website and/or submitted other information through the forms confirm their consent to the processing and transfer of personal data to the Operator.

1.7. The Website collects personal data from Users such as name, company name, email address, phone number, and other data provided through contact forms.

1.8. Submitting personal data via the Website’s contact forms is voluntary. By submitting their data, the User gives informed and conscious consent to its processing for the purposes specified in this Policy.

1.9. Users can disable cookie collection via browser settings; however, this may limit some Website functionality.

1.10. This Privacy Policy applies only to the website kritter.ru and does not cover or take responsibility for third-party websites accessible via links on this Website.

2. PURPOSES OF PROCESSING USERS’ PERSONAL DATA

2.1. The Operator collects and stores only the personal information necessary to identify the User and achieve the goals outlined in Clause 2.7 of this Policy.

2.2. Personal data is processed until the intended purpose is achieved unless a different term is specified by the User.

2.3. By submitting personal data via the Website, the User consents to receiving periodic information about the Company’s product updates, special offers, pricing, and other data on behalf of the Website, in compliance with Russian law.

2.4. If the User withdraws their consent to personal data processing, the Operator ceases processing upon receiving such notification.

2.5. The withdrawal notification should be sent via email to info@ucmrussia.com and/or in writing to the Company’s legal address: 236022, Kaliningrad Region, Kaliningrad, Gostinaya St., Building 5, Room Х, Office 48.

2.6. The withdrawal notice must include the sender’s information (the personal data subject), a list of data to be withdrawn, contact details, and the subject’s or their representative’s signature with legal authority confirmation.

2.7. Purposes for collecting and processing personal data:

• Identifying the User for feedback and request processing;

• Ensuring communication with the User, including sending responses, notifications, and information related to the Website;

• Creating and fulfilling contractual relations (if needed);

• Improving service quality and Website performance;

• Collecting cookies using Yandex.Metrica for:

  • visitor tracking for evaluating Website efficiency;

  • activity tracking for content and structure analysis;

  • simplifying return visits by remembering preferences;

  • conversion rate analysis;

  • ensuring security;

  • improving Website performance;

• Complying with the requirements of the Russian Federation’s legislation regarding personal data processing and storage.

3. CONDITIONS FOR PROCESSING PERSONAL INFORMATION AND ITS TRANSFER TO THIRD PARTIES

3.1. User personal data is kept confidential unless the User voluntarily makes the data publicly available.

3.2. Personal data may be transferred to third parties in the following cases:

3.2.1. With the User’s consent;

3.2.2. If necessary to fulfill a contract with the User;

3.2.3. If required by Russian law.

3.4. Personal data is processed until the objectives are achieved or until the User withdraws consent by means including: collection, recording, systematization, accumulation, storage, retrieval, usage, transfer, blocking, deletion, and destruction—automated or manual.

3.5. Personal data is processed in compliance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006.

3.6. Data is stored according to the data retention periods established by Russian archival legislation.

3.6. If personal data is lost or disclosed, LLC “UCM” will inform the User via phone or email provided through the Website.

3.7. Notification is considered valid until the User provides updated contact information to LLC “UCM”.

3.8. The Operator collects statistical and other data on Website visitors using Yandex.Metrica.

3.9. The Company implements necessary organizational and technical measures to protect personal information from unauthorized access, destruction, alteration, blocking, copying, and other unlawful actions.

3.9.1. Measures for securing personal data processed via automation tools:

• Identifying threats to personal data in information systems;

• Organizational and technical security measures;

• Logging all actions in automated systems;

• Monitoring unauthorized access and taking appropriate legal actions;

• Implementing secure storage conditions (passwords, antivirus software, firewalls, etc.).

3.9.2. Measures for securing personal data processed manually:

• Clearly defining data storage locations and authorized personnel;

• Secure physical storage (safes, locked cabinets, alarms).

4. OBLIGATIONS

4.1. LLC “UCM”, as the Operator, assumes the following responsibilities:

4.1.1. Use personal data strictly for purposes outlined in this Policy or where required by Russian law;

4.1.2. Keep confidential data secret, and not sell, exchange, or disclose personal data, except where permitted under this Policy;

4.1.3. Implement legal, organizational, and technical measures for protection:

• Developing internal policies and documents;

• Appointing data protection officers;

• Internal security controls;

• Access management;

• Using passwords and antivirus tools;

• Employing unauthorized access prevention tools.

4.1.4. Block personal data upon User request or by competent authorities if data is found to be inaccurate or unlawfully processed, pending verification.

5. LIABILITY

5.1. Individuals responsible for violating personal data processing rules shall be held liable in accordance with Russian Federation legislation.

6. ADDITIONAL TERMS

6.1. The Company reserves the right to amend this Privacy Policy without the User’s consent.

6.2. The User may disable data collection through browser settings, but this may limit Website functionality.

6.3. The User has the right to request clarification regarding personal data processing by contacting the Operator at info@ucmrussia.com or sending a letter to: 236022, Kaliningrad Region, Kaliningrad, Gostinaya St., Building 5, Room Х, Office 48.

6.4. This Policy becomes effective upon approval by the Director of LLC “UCM” or an authorized person.

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