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PRIVACY POLICY
This document, the Privacy Policy (hereinafter referred to as the "Policy"), outlines the rules governing the processing of personal data by Estelavia (sole proprietor Viktor Sergeyevich Popov, TIN 183 402 830 900, PSRNSP 316 183 200 095 263, hereinafter referred to as "Sole Proprietor V.S. Popov" or the "Operator"). The Policy applies to:

- Personal data of the Operator’s employees;
- Personal data of the Operator’s contractors;
- Personal data of other data subjects, including Users, which the Operator (including all entities within the same corporate group as the Operator, such as franchisees) may obtain in the following contexts:
 - Employees: During employment relationships;
 - Other individuals, including Users: Through the use of websites under the domains (including subdomains) estelavia.ru (hereinafter the "Website"), as well as the Operator’s services, programs, products, or during the execution of agreements with Users or third parties.

By accepting the Personal Data Processing Agreement, the User agrees to this Policy. Use of the Website constitutes unconditional consent to this Policy and its terms of personal data processing. If the User disagrees, they must refrain from using the Website.
General Provisions
This Policy is an integral part of the Agreement on the processing of the User's personal data, as well as other agreements concluded between the User and the Operator.
The processing of personal data is necessary for the execution of contracts (agreements) to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of contracts on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor.

The processing of personal data of the Operator's employees is necessary for the implementation and fulfillment of the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation, in particular:
compliance with the requirements of legislation in the field of labor, taxation, legislation on compulsory types of insurance, including individual (personalized) accounting in the system of compulsory pension insurance, compulsory medical insurance;
maintaining current accounting and tax records, forming, producing and timely filing accounting, tax and statistical reports.

This Policy has been drawn up in accordance with the Federal Law "On Personal Data" No. 152-FZ of July 27, 2006, as well as other regulatory legal acts of the Russian Federation, including in the field of personal data protection and processing, and applies to all personal data that the Operator may receive from the User, employees The operator and other subjects of personal data.

The Operator has the right to make changes to this Policy by approving additions (amendments) to the Policy by the Director General of the Operator or approving a new version of the Policy by the Director General of the Operator. When making changes, the date of the last revision update is indicated in the Policy header. The new version of the Policy comes into force from the moment it is posted on the website, unless otherwise provided by the new version of the Policy.

The legislation of the Russian Federation is subject to application to this Policy, including the interpretation of its provisions and the procedure for adoption, execution, amendment and termination.
Personal information processed by the Operator
Personal information in this Policy means:
· information provided by the User independently during registration (account creation) or during the use of the Site, including the User's personal data. The information required to be provided by the Website is marked in a special way. Other information is provided by the User at his discretion.;
· data that is automatically transmitted to the Site during its use using software installed on the User's device, including IP address, cookie data, information about the User's browser (or other program that accesses the Site), technical characteristics of the hardware and software used by the User, date and time of access to the Site, addresses of the requested pages and other similar information;
· other information about the User, the processing of which is provided for by the terms of use of the Site;
· personal data of the Operator's employees;
· personal data of the Operator's counterparties.

This Policy also applies to information processed during the use of the Website. The Site does not control and is not responsible for the processing of information by third-party sites to which the User can click on the links available on the Site.

The Site does not verify the accuracy of the personal information provided by the User and does not have the ability to assess his legal capacity. The personal data of the following personal data subjects is subject to processing by the Operator:

Personal data of the Operator's employees as part of:
§ last name, first name, patronymic;
§ gender;
§ date of birth, place of birth;
§ citizenship;
§ information about education (including the name of the educational institution, specialty, qualification);
§ marital status, information about the composition of the family;
§ passport data (type of document, series and number of the document, issuing authority, date of issue of the document);
§ address of registration and actual place of residence;
§ information about employment;
§ military registration information;
§ academic degree, academic title;
§ honorary title;
§ information about the defense and topic of the dissertation, diploma, and professional development;
§ information about awards and incentives;
§ information on bringing to disciplinary, material, civil, administrative and criminal liability;
§ biographical information;
§ information about state pension insurance;
§ taxpayer identification number;
§ information about deductions to the Federal Tax Service;
§ information about contributions to the Pension Fund of Russia;
§ information about charges and deductions;
§ division, position, service number;
§ information about the employment contract (number, date, probation period);
§ work schedule;
§ disability;
§ information about tax deductions;
§ vacation information;
§ social benefits;
§ sick leave data;
§ income information;
§ information about additional skills;
§ contact phone number;
§ photographs;
§ other personal information provided by the Operator's employees.

Personal data of the User and other subjects of personal data as part of:
§ last name, first name, patronymic;
§ citizenship;
§ position, organization;
§ phone number;
§ passport data (type of document, series and number of the document, issuing authority, date of issue of the document);
§ date and place of birth;
§ gender;
§ SNILS;
§ residential address;
§ areas of interest, services, and directions;
§ e-mail address;
§ the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity (biometric data);
§ other personal data specified by the User in the forms or files attached to the forms, as well as when concluding contracts (agreements) with the Operator.

Personal data of the Operator's counterparties:
§ last name, first name, patronymic;
§ OGRN (OGRNIP);
§ statistics codes;
§ OKVED;
§ location (postal address);
§ contact phone number;
§ the number of the settlement (personal) account, bank details;
§ information about the contract (agreement);
§ other personal data specified by the counterparty in the forms or files attached to the forms, as well as when concluding contracts (agreements) with the Operator.
Purposes of personal data processing
The Operator collects and stores only the personal information that is necessary for the provision of services or the execution of agreements and contracts with the User, the implementation of employment relations with the Operator's employees, and the implementation of legal relations with the Operator's counterparties, except in cases where legislation provides for the mandatory storage of personal information for a period specified by law.

The Site processes the User's personal information for the following purposes:
· identification of the party within the framework of services, agreements and contracts with the Operator;
· provision of personalized services and services to the User, as well as execution of agreements and contracts;
· sending notifications, requests and information regarding the use of the Site, the execution of agreements and contracts, as well as processing requests and requests from the User;
· improving the quality of the Website, its user-friendliness, and the development of new services;
· targeting of advertising materials;
· conducting statistical and other research based on anonymized data.
Conditions for the processing of personal data and their transfer to third parties
With respect to personal data, their confidentiality is maintained, except in cases where the User or other subjects of personal data provided for in this Policy voluntarily provide information about themselves for general access to an unlimited number of persons.

The Website has the right to transfer personal data to third parties in the following cases:
· The User (other entity) has consented to such actions;
· The transfer is necessary for the User (other entity) to use a certain service or to fulfill a certain agreement or contract with the User (other entity);
· The transfer is necessary for the functioning and operability of the Operator and/or the Site;
· The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;
· Such transfer takes place as part of a sale or other transfer of a business (in whole or in part), while the acquirer assumes all obligations to comply with the terms of this Policy in relation to the personal information received by him;
· In order to ensure the possibility of protecting the rights and legitimate interests of the Site or third parties in cases where the User (other entity) violates the User Agreement of the Site, this Policy, or documents containing the terms of use of specific services.

As a result of processing the User's (other subject's) personal information by depersonalizing it, depersonalized statistical data is obtained, which is transferred to a third party for conducting research, performing work or providing services on behalf of the Operator.
Modification and deletion of personal data. Mandatory data storage
The User (other subject) may at any time change (update, supplement) the personal information provided by him or part of it by contacting the Operator at the email address: estelavia@yandex.ru and the postal address: 426 008, Izhevsk, st. Krasnoarmeyskaya, 135, sq. 10.

The rights provided for in clause 5.1. of this Policy may be limited in accordance with the requirements of the legislation. For example, such restrictions may provide for the Operator's obligation to save information changed or deleted by the User for a period established by law and transfer such information in accordance with a legally established procedure to a government agency.
Processing of personal data using cookies and counters
Cookies transmitted by the Operator to the User's (other entity's) equipment and the User's (other entity's) equipment to the Operator may be used by the Operator to provide personalized services to the User (other entity), to target advertisements that are shown to the User (other entity), for statistical and research purposes, as well as to improve the Site.

The user (other subject) is aware that the hardware and software used by him to visit sites on the Internet may have the function of prohibiting operations with cookies (for any sites or for certain sites), as well as deleting previously received cookies.

Yandex, Google, Facebook, VKontakte, Google Inc. — the right to establish that the provision of a particular service or services is possible only under condition that the acceptance and receipt of cookies by the User (or other subject).
The structure of the cookie file, its content and technical parameters are determined by the Operator and may change without prior notice to the User (other subject).

The counters placed by the Operator can be used to analyze the cookies of the User (other subject), to collect and process statistical information about the use of the Site, as well as to ensure the operability of the Site as a whole or their individual functions in particular. The technical parameters of the counters are determined by the Website and may change without prior notification to the User (other entity).
Personal data protection
The Operator takes necessary and sufficient organizational and technical measures to protect the User's (other subject's) personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions with this data by third parties.
Contacts and questions about personal data
The User (other subject) has the right to send all suggestions, questions, requests and other requests regarding this Policy and the use of his personal data to the Operator:
· by e-mail: estelavia@yandex.ru
· at the postal address: 426 008, Izhevsk, st. Krasnoarmeyskaya, 135, sq. 10.

Date of publication of this Policy: January 01, 2018
Personal Data Processing Agreement
This Agreement is a public offer, developed in accordance with the legislation of the Russian Federation. By joining this Agreement and leaving your data on the sites in the following domains (including subdomains): estelavia.ru (hereinafter referred to as the Website) by filling in the fields of the online application, the User agrees to consent to the processing of personal data and their transfer to the operator of personal data processing — Estelavia company (Individual entrepreneur Popov Viktor Sergeevich, TIN 183 402 830 900, OGRNIP 316 183 200 095 263 (hereinafter referred to as the Operator), which owns the Site, on the following terms:

User:
· confirms that all the data provided by him belongs to him personally;
· confirms and acknowledges that he has carefully read the Agreement and the terms of processing of his personal data, indicated by him in the fields of the online application (registration), the text of the Agreement and the terms of processing of personal data are clear to him;
· agrees to the processing of personal data without reservations and restrictions. The Site contains Consent to the processing of personal data, with which the User fully agrees and undertakes to comply (hereinafter referred to as Consent). The moment of acceptance of Consent is the marking of the corresponding field in the form posted on the Site and clicking on the button to submit the form on any page of the Site.;
· confirms and agrees that the Operator and other persons who have gained access to the User's personal data may disclose and distribute the User's personal data to third parties;
· confirms that by giving Consent, he acts voluntarily, freely, of his own free will and in his own interest;
· accepts all the terms of this Agreement in full without any exceptions or restrictions and undertakes to comply with them or stop using the Site.;
· any special notification. The new version of the Agreement comes into force from the moment it is posted on the Website or communicated to the User in another convenient form, unless otherwise provided by the new version. Agreements;
· hereby gives his voluntary consent to inform him about all actions of the Operator related to the sale of goods and / or the provision of services, including the status of order fulfillment, as well as other events of any kind related to the services of the Site, including consents to receive information distribution to the User by the Operator or third partiesauthorized by the Operator, via SMS and email distribution to the phone and email address specified by the User when subscribing through the subscription service on the Website;
· agrees that the Operator is not responsible in any way for delays, failures, incorrect or late delivery, deletion or non-preservation of any notifications. At the same time, the Operator reserves the right to re-send any notification if it is not received by the User.;
· you can ask all questions about information support at the address: 426 008, Izhevsk, st. Krasnoarmeyskaya, 135, sq. 10;
· acknowledges that the accompanying product description on the Website does not purport to be exhaustive and may contain inaccuracies.;
· recognizes that the Operator makes sufficient efforts to ensure that the external The type and other characteristics of the products corresponded to the descriptions given in the Website catalog.;
· acknowledges that the actual appearance and other characteristics of the product may differ from their descriptions on the Website, as well as in the case of changes to the product directly by the manufacturer;
· I am informed that the price and availability of goods on the Website changes around the clock without prior notice;
· I am informed that the Site's services may contain links to other resources. Acknowledges and agrees that the Operator is not responsible in any way for the availability of these resources and for their content, as well as for any consequences associated with the User's use of the content of these resources;
· agrees that the Operator does not bear any responsibility for the User's personal data, which he provides to third-party resources and/or other third parties in case of access to them from the Site;
· confirms that the Operator is not responsible for the possible loss and/or damage of data that may occur due to the User's violation of the provisions of this Agreement, as well as improper access and/or use of the personalized services of the Site;
· recognizes and understands that responsibility for the actions of minors, including their purchase of products from the catalog on the Website, lies with the legal representatives of minors;
· agrees that in the event of non-fulfillment and/or improper fulfillment by the Operator of obligations in connection with the provision of false and /or invalid personal data by the User, as well as non-fulfillment by the User of the terms of this Agreement, the Operator is not responsible;

Agrees not to use the Site's services for the purpose of:
· downloading content that is illegal, violates any rights of third parties; promotes violence, cruelty, hatred and/or discrimination on racial, national, sexual, religious, social grounds; contains false information and/or insults against specific individuals, organizations, authorities;
· incitement to commit illegal acts, as well as assistance to persons whose actions are aimed at violating restrictions and prohibitions in force on the territory of the Russian Federation;
· violating the rights of minors and/or harming them in any form;
· Infringement of the rights of minorities;
· impersonating another person or representative of an organization and/or community without sufficient rights, including employees of the Site;
· misleading about the properties and characteristics of any products from the catalog on the Website;
· incorrect comparison of goods, as well as the formation of a negative attitude towards persons who (do not) use certain goods, or the condemnation of such persons;
· downloading content that the User does not have the right to make available under the legislation of the Russian Federation or according to any contractual relationship;
· downloading content that affects and/or contains any patent, trademark, trade secret, trade name, copyright and related rights, as well as other intellectual property rights owned or lawfully used by third parties;
· downloads of advertising information and/or spam that are not specifically authorized;
· collection and processing of personal data, information about the private life of any persons;
· disruptions to the normal operation of the Site;
· Violations of Russian or international law.
· agrees not to use abusive words, obscene and offensive images, comparisons and expressions on the Site, including in relation to gender, race, nationality, profession, social category, age, language of a person and citizen, as well as in relation to organizations, authorities, official state symbols (flags, coats of arms, etc.names), religious symbols, cultural heritage sites (historical and cultural monuments);
· acknowledges and agrees that the Operator has the right (but not the obligation) at its sole discretion, refuse to post and/or remove any content available through the Site's services;
· I agree that the term of this Agreement is unlimited, unless otherwise stated on the Website.
Privacy policy
The terms of the Privacy Policy and the relationship between the User and the Operator related to the processing of personal data are regulated by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".
The Privacy Policy applies to personal data that the Operator has received or may receive from the User when registering on the Site, and is necessary to fulfill obligations on the part of the Operator. The user confirms that this Privacy Policy is binding on him and is available at the link: estelavia.com , which he is fully familiar with.

This Consent is given to the processing of personal data both without the use of automation tools and with their use. Consent is given to the processing of the following personal data of the User specified by the User in the forms or in the files attached to the forms:
· Last name, first name, patronymic;
· Citizenship;
· Position, organization;
· Phone number;
· passport data (type of document, series and number of the document, issuing authority, date of issue of the document);
· Date and place of birth;
· Gender;
· SNILS;
· Residential address;
· Areas of interest, services, and directions;
· Email address;
· The physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity (biometric data);
· Other personal data specified by the User in the forms or files attached to the forms, as well as when concluding contracts with the Operator.
The purpose of processing personal data is to fulfill the contract, as well as their storage and use, including:
· Responses to User requests;
· Ensuring the User's work with the Operator's Website;
· Sending analytical materials to Users and informing Users about upcoming events organized by the Operator, as well as registering Users to participate in such events.

By accepting the terms of this Agreement, the User expresses his interest and fully agrees that the processing of his personal data includes any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

The User's consent to the processing of personal data is specific, informed and conscious. The User's present Consent is deemed fulfilled in a simple written form.

The consent is valid indefinitely from the moment the data is provided and can be revoked by the User by submitting a written application to the Operator indicating the data defined by Federal Law No. 152-FZ "On Personal Data" at the address: Address: 426 008, Udmurt Republic, Izhevsk, Kroasnoarmeiskaya str., 135, sq. 10.
If the User withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the User's consent, provided there are grounds provided for by Federal Law No. 152-FZ "On Personal Data".

During the processing of personal data, the Operator has the right to: collect, record, systematize, accumulate, store, clarify (update, modify), extract, use, transfer (distribute, provide, access), depersonalize, block, delete, destroy the User's personal data.

The transfer of the User's personal data to third parties is not carried out, with the exception of persons who process personal data on behalf of and on behalf of the Operator, as well as cases established by law.
The Operator has the right to amend this Agreement at any time. When making changes to the current version, the date of the last update is indicated. The new version of the Agreement comes into force from the moment it is posted, unless otherwise provided by the new version of the Agreement.

The current version is always available on the page at: estelavia.com

Operator's details:
· Individual entrepreneur Viktor Sergeyevich Popov
· INN: 183 402 830 900
· OGRN: 316 183 200 095 263
· Address: 426 008, Udmurt Republic, Izhevsk, Kroasnoarmeiskaya str., 135, sq. 10.
· E-mail for inquiries: estelavia@yandex.ru

Date of publication of this Policy: January 01, 2018