Date of publication: 1 Jan 2019
Current version is available at here:
To provide you with access to the Sites and Services, your Personal information is collected and used by Sole trader Roman Zolotarev registration number 317169000003180.
When you use the Sites and/or Services, the ST processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.
Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your user account or without logging in. When you are logged in to your user account as you are using the Sites or Services, Personal information collected by the ST may be collated and combined with other Personal information collected by the ST in your user account.
The ST does not verify Personal information provided by you and cannot posit if it is true and whether you have the legal capacity required. However, the ST assumes that the information you provide is true, sufficiently complete and up-to-date.
Personal information collected by the ST when you access, interact with or operate the Sites and/or Services includes:
(i) Information provided by you when you register (create) a user account, such as your name and email address;
(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software);
(iii) date and time of accessing the Sites or Services;
(iv) information related to your activity when using the Sites or Services; and
(v) information about you that we may receive from a Partner of the ST in accordance with an agreement you made with this Partner and an agreement between the ST and this Partner.
The ST does not actively collect any sensitive personal data (such as racial origins, political opinions, health, or biometric data).
The ST does not perform any form of profiling which has the potential to significantly impact your rights and freedoms.
The ST is not allowed to process your Personal information if it does not have a valid legal ground. The ST will therefore only process your Personal information if:
(i) The processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services;
(ii) the processing is necessary to comply with our legal or regulatory obligations; or
(iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of the ST and does not unduly affect your interests or fundamental rights and freedoms. Please note that when the ST processes your Personal information on this basis, the ST will always seek to maintain a balance between legitimate interest of the ST and the protection of your privacy.
Examples of such legitimate interests are:
(iv) for specific purposes we may ask your consent for processing of your Personal information.
The ST always processes your Personal information for a specific purpose and only processes Personal information which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:
(i) To provide you with the Sites and/or Services;
(ii) to provide you with access to your user account;
(iii) to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application;
(iv) to provide advertisements and/or commercial offers based on your preferences and other Personal information available to the ST;
(v) to improve user experience;
(vi) to develop new products, applications, and services;
(vii) to protect your rights and the rights of the ST; and
(viii) to collect, process and present statistical data, or perform other research and/or analysis of Personal information.
In most cases, Personal information is processed automatically. To protect your Personal information and ensure its confidentiality, the ST follows technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.
The ST may transfer Personal information to third parties to complete the purposes listed in Section 5 above. Such third parties may include:
(i) Partners, such as media publishers, advertising networks and other partners providing ST with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners;
(ii) advertisers or other Partners serving targeted advertisement on the ST Sites or Services; and third parties who process Personal information, such as IT systems providers and/or consultants.
(iii) any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
(iv) any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;
(vi) third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;
(iv) any third party to ensure legal protection for the ST and/or the third parties if you violate the User Agreement of any of the ST Services (https://www.romanzolotarev.com/terms.html), this Policy, or if there is a threat of such violation.
The ST will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.
If you wish to have any Personal information removed from databases of the ST, you can have it removed via your account or using interface of the Sites or Services (where applicable).
If it is provided by applicable law, you have a right of access to your Personal information as processed by the ST under this Policy.
If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.
If it is provided by applicable law, you also have the right to:
The ST will honour any such requests or objections as required under applicable law.
To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.
To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact the ST (see Section 12 hereof).
If you are not satisfied with how the ST processes your Personal information, please let the ST know and the ST will investigate your concern. If you are not satisfied with response from the ST, you have the right to make a complaint to the competent data protection authority.
Cookies are small text files placed on the device you use to access our Sites. They contain information that is collected from your device and sent back to the Sites on each subsequent visit so as to remember your actions and preferences over time.
The following types of cookies are used on the Sites:
strictly necessary cookies: these cookies are required to run the Sites and provide you with the Services and may, among other, allow the ST to identify your hardware and software, including your browser type;
statistical cookies: these cookies enable the ST to recognise users, count the number of users and collect information such as your actions on the Sites and the Services, including the web pages you visit and the content you retrieve;
performance cookies: these cookies collect information about how users interact with the Sites and Services, enabling the ST to identify errors and test new functionalities to improve the performance of the Sites and the Services;
functionality cookies: these cookies enable the ST to provide specific functionalities in order to improve your experience on the Sites, for example by storing your preferences;
advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable the ST to display advertising which may be of interest to you based on collected Personal information. These cookies are also used for statistical and research purposes.
ST only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.
Personal information collected through cookies placed on your device may be transmitted to and accessed by the ST or the third parties referred to in Section 7 hereof. The use of Personal information outside of the Sites for advertising purposes, if any, may be subject to separate policies available on the above third parties' websites. The ST or those third parties might also provide you with a possibility to opt out of receiving targeted advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.
The ST may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:
(i) to track your actions on the Sites and when using the Services, by accessing and interacting with the cookies stored on your computer;
(ii) to collect statistical information related to operating the Sites, the Services or products, utilities, advertisements or other ST offerings.
This Policy may be subject to amendments. The ST shall be entitled to make such amendments at discretion of the ST, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.
The ST undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site (e.g. via a pop-up or web banner) prior to such changes taking effect, and you may also be notified via other channels (e.g. by email) if you have provided us with your contact details.
The ST welcomes your questions or suggestions concerning implementation
of or amendments to this Policy. To contact the ST please use this
You can also use this form to exercise your rights or report any inaccuracies in your Personal information or protest its processing.