Cookie Policy

Kappa Rus- DATA PROTECTION NOTICE

1. PURPOSE AND PURPOSE OF THIS NOTICE

This notice explains how Kappa Rus collects and processes your personal data (“Personal Data”) collected by companies and/or third party service providers on behalf of the company in the context of your interactions with us.

For the purposes of this notice, the controller of your Personal Data is Kappa Rus, registered at the following address: Promyshlennaya, 9, Moscow.

If you have any questions regarding this notice, please contact the legal department sales@kapparus.ru

2. APPLICABILITY OF THIS NOTICE

IMPORTANT: While we have tried to include information in this Notice that is as complete and accurate as possible, it is not meant to be exhaustive. Subject to Section 11 of this Notice, the information contained in this Notice may be updated from time to time.

This Notice is divided into a number of sections, some or all of which may apply to you, depending on your interactions with the companies. In any case, you have certain rights under data protection law. These are set out in section 10. In particular, you have the right to object at any time to the processing of your Personal Data that we carry out on a lawful basis in pursuit of our legitimate interests.

Marketing and Business Contacts: If you have signed up to receive marketing information from us, you guarantee the confidentiality of your information.

Site User: if you use our Site [www.kapparus.ru], (hereinafter referred to as the “Site”), you can read about how we use the Personal Data of Site users in Section 5A. Site users should also review our Cookie Policy.

Social media users: if you use our social media accounts (VK), you can read the information about how we process your Personal Data as a social media user in Section 5B.

Existing Customers: If you are a customer of Kappa Rus, please see Section 6 for information on how we process your Personal Data for administrative and commercial purposes.

3. WHAT PERSONAL DATA WE PROCESS

Depending on your interaction with us, we process the following types of personal data:

• If you are our marketing or business contact: your name, employment details, contact details, business operations and interests, and information related to your subscription, receipt of newsletters or interests in mailing lists.
• If you use the Site: information about your visits to the Site, your location and IP address, browser version, and the time and date of your visit to the Site.
• If you interact with our social media accounts, we collect personal data about you such as name, location, country, job title, areas of interest, provided that these data are open in your social media accounts.
• If you are our client: your name, employer details, payment details, details of visits, correspondence and communications with our employees and any information provided to us by you or on your behalf.

4. MARKETING AND BUSINESS CONTACTS

If you are our marketing or business contact, we may receive, collect and process your personal data for the following purposes:

• to promote the commercial activities of the company;
• to invite you to events;
• to establish and maintain a relationship with you;
• to manage and administer your relationship with our business contacts and customers;
• to send you marketing materials, newsletters and other data;
• to monitor and analyze your interest in the materials we send to you;
• to send marketing information by mail, unless you have expressed your objection;
• to produce, collect and publish photos from company events.

In these cases, we usually rely on your consent to provide you with information about our products and services through direct marketing. In all other cases, including if we have already contacted you, we rely on our legitimate interest in providing you with information about our products that we think may be of interest to you.

You always have the option to opt out of receiving marketing communications. You may opt-out of mailings using the contact details set out in Section 11. [You can always opt-out of receiving marketing emails by clicking on the “unsubscribe” link at the bottom of every marketing email from us].

5A. SITE USERS

If you visit our Site, we may receive, collect and process your personal data for the following purposes:

• to provide, improve, test and monitor the effectiveness of the Site;
• to control metrics such as total visitors, traffic, and demographic patterns;
• to ensure the most effective presentation of content on the Site and improve the convenience of using the Site;
• to notify you of any changes to the Site and/or our services.

We receive, collect and process this Personal Data based on our legitimate interest in ensuring the correct operation of our Site, as well as to analyze the interest of visitors in certain content. This data helps us maintain the Site and improve your experience on the Site.

5 B. SOCIAL NETWORKS USERS

If you visit our social media accounts, we may receive, collect and process your personal data for the following purposes:

• To better understand our audience demographics, preferences and interests, to be able to provide our readers with the most relevant information and news through our social media accounts.
• For the purpose of optimizing our audience and targeting.

6. EXISTING CUSTOMERS

If you are our customer, we may receive, collect and process your personal data for the following purposes:

• to carry out administrative, financial and operational processes;
• to review and respond to messages or requests you send to us;
• to monitor sales levels and improve sales models; to conduct due diligence;
• to fulfill orders and fulfill our obligations under any sales contracts that may be entered into with you;
• to process any financial payments and manage your customer account;
• to enter into any contractual relationship with an organization to which you are affiliated;
• to send you marketing information. See Section 4 of this Notice for more details.

We receive, collect and process your Personal Data for the purposes described above on the following legal grounds:

• our legitimate interest in operating our company and maintaining a partnership with you;
• necessary for the purpose of entering into and maintaining contracts with you;
• the need to process your personal data to fulfill legal obligations in accordance with applicable Russian law.

If you do not wish to provide us with your Personal Data for us to process it for the purposes described above, we will not be able to provide services or sell products to you.

7. DISCLOSURE OF YOUR PERSONAL DATA

Depending on our relationship with you, we may disclose some or all of your Personal Information to the following: technical support providers, IT and web service providers, marketing companies, PR agencies, printers, advertising agencies and other vendors, other people in your organization, third parties involved in the holding or organization of events or trade shows, professional tax or legal advisors, accountants, regulatory authorities (for example, law enforcement agencies and government agencies) and third parties involved in the sale or purchase of companies or assets, owned by the company.

8. INTERNAL TRANSFER OF YOUR PERSONAL DATA

We may share your Personal Data with other company members and other recipients. Certain recipients (our third party service providers and other Kappa Rus companies) who process your Personal Data on our behalf may transfer your Personal Data outside of the Russian Federation, which does not provide an adequate level of protection for your Personal Data. Our policy applies to such transfers: a) no transfer of data takes place without prior written consent; and b) an appropriate agreement is entered into to protect your Personal Data. If you need more information about such transfers, please contact our data protection officer, whose contact details are set out in section 11 of this Notice.

9. STORAGE OF YOUR PERSONAL DATA

We generally retain Personal Data for a certain period of time after contact for marketing purposes. When we understand that we no longer need your Personal Data, we delete it from our systems.
In certain cases, we may retain your Personal Data for a longer period of time, for example, if we are in the process of processing legal action or if we have reasonable grounds to believe that regulatory authorities may request your Personal Data from us. If you need more information about data retention periods, please contact our data protection officer, whose contact details are set out in Section 11 of this Notice.

10. YOUR RIGHTS AND HOW TO EXERCISE THEM

This section sets out your rights in relation to Personal Data. In particular, you have the right to object to the processing of your Personal Data for our legitimate interests. In certain cases, these rights may not be absolute.

RIGHTS	ADDITIONAL INFORMATION
Right to object	You can object at any time to the processing of your Personal Data that we carry out on legitimate grounds in order to pursue our legitimate interests. When we process your Personal Data on the basis of our legitimate interests, we take into account any consequences of such processing on you and your data protection rights. We will not use your Personal Data if the impact on you is beyond our interests.
Access right	You have the right to request a copy of the Personal Data we hold about you in order to access it. If we believe that your request is unjustified or excessive, we may charge you a fee for providing Personal Information
Right to Correction	You have the right to correct or correct inaccurate Personal Data about yourself.
Right to erasure	In certain cases, you may also request deletion of your Personal Information. For example, if you have exercised your right to object (see below) and we have no compelling reason to process your Personal Data, or if we no longer need your Personal Data for the purposes set out here.
Right to restriction of processing	In certain cases, you have the right to ask us to restrict the processing of your Personal Data, including if you believe that the Personal Data we hold is inaccurate or that we are using it unlawfully. If you exercise this right, we will store your Personal Data but will not process it until the issue is resolved.
Right to data portability	You may ask us to provide you with your Personal Data in a structured, common and machine-readable format. You can also ask us to transfer your Personal Data directly to another data processing unit if this is technically feasible. This right only applies in the following cases: (1) we process your Personal Data with your consent or as necessary to interact with you; and (2) the processing is carried out by automated means.

To exercise any of these rights, please send a written request to the Legal Department at: 115516 Russia, Moscow, st. Industrial, d. 9.

We will provide you with information on the actions taken as a result of receiving your request regarding these rights within a maximum of 1 month from the date of receipt of the request. If necessary, we can extend the response time up to 2 months. In this case, you will receive a corresponding notification. If you wish to exercise any data protection right, we may ask you to verify your identity.

You also have the right to lodge a complaint with the Data Protection Commission.

11. CHANGES TO THIS POLICY AND ISSUES

We may change the contents of this Notice at our sole discretion, either in whole or in part. Any changes will be effective immediately upon your receipt of the updated notice.

If at any time we decide to use your Personal Information for purposes that are materially different from those described in this document or otherwise communicated to you at the time of collection, we will notify you by email or regular mail and you will be able to authorize or prevent us from using your Personal Data for these purposes.

If you have any questions, comments or claims regarding the use or processing of your Personal Data by the Company, please submit a written request to the Legal Department by e-mail sales@kapparus.ru or at the following address: 115516 Russia, Moscow, Promyshlennaya str., d. 9.