Privacy Policy

Personal data processing policy of the website promokodus.com

g. Saint Petersburg
«13» September 2022

This Personal Data Processing Policy (hereinafter referred to as the Policy) is a public offer and determines the policy for processing personal information of Users of the promokodus.com website.

1. For the purposes of this Agreement, basic concepts are used.

1.1. Website – a set of interconnected static and dynamic pages of the Site containing text data, pictures, videos and other digital information and united under the address https://promokodus.com on the Internet and its subdomains.
1.2. Venue – a service of discounts, promotions and offers, which is an electronic catalog containing the ability to access Information.
1.3. User – any person who has access to the Site via the Internet. The user can also use the materials and services of the Site and receive the services declared by the Site.
1.4. Site Administration – employees authorized by the Site owner to manage the Site, acting on behalf of the Site owner.
1.5. Personal data – any information relating directly or indirectly to the User, including his name, surname, telephone number, email address, residential address, cookie data, IP address, information about location (geoposition), type and version of operating system, type and the version of the browser (or other program with which access to services is provided), the language of the operating system, the technical characteristics of the equipment and software used by the User, the type of device and its screen resolution, the source (website, advertisement) from which the User came to the Site (referrer), as well as the date and time of access to the services, addresses of the pages requested by the User and other similar information.
1.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision , access), depersonalization, blocking, deletion, destruction of personal data.
1.7. Account (account) – a set of data about the User that is stored in a computer system. Necessary for identifying a participant (authentication) and providing access to his personal data and settings.
1.8. Link – part of a hypertext document that refers to another element (command, text, heading, note, image) in the document itself, to another object (file, directory, application) located on a local disk or on a computer network, or to elements of this object.
1.9. Cookie – a small piece of data sent by a web server and stored on the User’s computer in the form of a file, which a web client or web browser sends to the web server every time in an HTTP request when trying to open a page of the corresponding site. Cookie serves to ensure proper operation of the Site, as well as to record statistics of all User actions and User purchases.
1.10. IP address — a unique network address of a node in a computer network built using the IP protocol.
1.11. User - any individual with legal capacity who has reached the age of majority, is not limited in the rights to use the services of the Site, or is an authorized representative of a legal entity.

2. The personal data processing policy is part of the User Agreement for the use of materials and services of the promokodus.com website. Joining the User Agreement means simultaneous familiarization with, as well as full and unconditional agreement with the Personal Data Processing Policy.
Use of the Site’s services means the User’s unconditional consent to this Policy and the conditions for processing his personal data specified therein. In case of disagreement with these terms, the User must refrain from using the Site services.

3. By accessing the Site, the User simultaneously provides his personal data and gives, of his own free will and in his own interest, consent to the processing of his personal data (name, email address). This Policy applies to all information (User data) that the Site Administration can obtain about the User while the latter is using the Site.
This Policy applies only to the Site. The Site Administration does not control and is not responsible for third party sites that the User can access via links available on the Site.

4. The collection and processing of Users’ personal data (including using information and telecommunication networks, including the Internet) is carried out by the Site Administration.
The Site Administration collects and stores only those personal data of the User that are necessary to provide services or fulfill agreements and contracts with the User, except in cases where the law provides for mandatory storage of personal information for a period specified by law.

5. The collection and processing of Users’ personal data is carried out in order to fulfill the Site Administration’s obligations to the User, identify the User registered on the Site, provide the User with access to the Site services, carry out advertising activities, in order to promote goods, works and services, conduct electronic and SMS surveys, monitoring the results of marketing campaigns, customer support, monitoring the User’s satisfaction with the quality of services provided, establishing feedback with the User, including sending notifications, requests regarding the use of the Site, providing services, processing requests and applications from the User, determining the User’s location to ensure security, providing the User effective customer and technical support in case of problems related to the use of the Site.

The Site Administration does not verify the accuracy of personal data provided by Site Users. The user bears full responsibility in the event of errors in the Policy that may affect the quality of his receipt of the services of the Site

6. The Site Administration collects and processes certain User data.

6.1. Personal data that the User provides about himself independently in the process of using the services of the Platform, namely: first name, last name, telephone number, email address, residential address.
6.2. Data that is automatically transferred to the Site Administration during the use of the Site services by the User using software installed on the User’s device, including cookie data, IP address, information about location (geoposition), type and version of the operating system, type and version browser (or other program through which services are accessed), operating system language, technical characteristics of the equipment and software used by the User, type of device and its screen resolution, information about the source (website, advertisement) from which the User came to Website (referrer), as well as the date and time of access to services, addresses of pages requested by the User and other similar information.

7. The User is obliged to provide information about personal data necessary to use the Site, as well as to subsequently update and supplement the provided information about personal data if this information changes.
The user expresses specific, informed, conscious and voluntary consent to the processing of personal data specified in clause 6 of this Policy, as well as any other personal data.

8. The Site Administration has the right to use Cookies technology for the purpose of system administration (including using the Yandex.Metrica and Google Analytics tools). The user agrees to the collection, analysis and use of cookies, including by third parties, for the purpose of generating statistics and optimizing advertising messages. The user agrees to the addition of an identifier to his cookies. 

The user can refuse to store cookies by changing the settings of the browser or mobile device, which allows you to block the storage of cookies. If cookies are blocked by the User, access to some specialized applications of the Site will be limited for him.

9. The Site Administration receives information about the User’s IP address. This information is not used to identify the visitor.

10. The Site Administration informs that it is taking measures to protect Users’ personal data from unlawful actions of third parties.
10.1. Employees responsible for ensuring the security of personal data processing and employees directly responsible for the processing of personal data are appointed.
10.2. The above mentioned employees are trained and instructed.
10.3. The job descriptions of the above employees have been approved.
10.4. Access to premises where personal data is processed is limited.
10.5. Storage of personal data media is ensured.

11. The security of personal data processing is ensured through the use of the following means: anti-virus software installed on the devices, as well as a locked cabinet for storing storage media.

12. The User agrees to the transfer of any personal data provided to the Site Administration to any third parties without notifying the User if there are agreements duly concluded between the Site Administration and such third parties, subject to maintaining their confidentiality.

The Site Administration provides the User’s personal data without notifying the User to third parties in the following cases:
- The user has expressed consent to such actions;
- The transfer is necessary as part of the User’s use of a certain service or to provide a service to the User;
- Transfer of the following User data: information about cookies, IP addresses, location information (geoposition), addresses of pages requested by the User – is necessary for any third parties in order for the Site Administration to receive remuneration for services provided to third parties (work performed);
- The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;
- The transfer occurs as part of the sale or other transfer of a business (in whole or in part), and all obligations to comply with the terms of this Policy in relation to the personal information received by him are transferred to the acquirer;
- The user agreed in writing that his personal data becomes publicly available.

13. The processing of the User's personal data is carried out until the withdrawal of personal data via email, including in personal data information systems using automation tools or without the use of such tools.

14. The processing of Users’ personal data is carried out in accordance with the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” and other legislative acts of the Russian Federation regulating this area of legal relations.

15. In the event of the sale of the Site, all obligations to comply with the terms of this Policy in relation to the personal information received by him are transferred to the acquirer.

16. If the Site Administration receives information about the loss or disclosure of the User’s personal data, the Site Administration has the right to inform the User about the loss (disclosure) in one of the following ways: by posting an appropriate information message on the Site, by sending notifications by email, or by push notifications. The user does not have the right to refuse to receive such messages.

At the same time, the Site Administration, together with the User, takes all necessary measures to prevent losses and other negative consequences caused by the loss or disclosure of the User’s personal data, including by sending the User a timely mandatory notification.

17. The Policy (version of the Policy) comes into force from the moment it is posted on the Site. The Site Administration has the right to make changes to this Policy without the consent of the User. Versions of the Policy also come into force from the moment it is posted on the Site. The user must independently familiarize himself with the updated versions of the Policy.

18. This Policy is an integral part of the User Agreement for the use of materials and services of the Internet site promokodus.com.

19. All information, claims and notifications are sent by the User to the Site Administration by sending an email to the address support@promokodus.com.

20. All information is stored on servers located on the territory of the Russian Federation.

21. The operator of personal data processing is SmartLeads LLC. INN/KPP 7811695638/ 781401001, 197342, St. Petersburg, vn.ter.g. municipal district Chernaya Rechka, Lisichanskaya st., 6, letter A, premises. 26-N, office 56