Privacy Policy

Centrarium Privacy Policy (the "Policy") contains information on how Centrarium processes and protects personal data.

1. General policy provisions

1.1 This Policy is an integral part of the User Agreement and License Agreement, as well as other agreements concluded with the User in the course of using the Centrarium.com Website, when expressly provided for by its terms and conditions.
1.2 This Policy applies to all personal data that Centrarium may receive from the User during the use of Centrarium's Websites and mobile applications.
1.3 Centrarium does not control and is not responsible for third party websites to which the User may access through links available on Centrarium.com. Third party sites may have their own privacy policies and may collect or request other personal data from the User.
1.4 For specific services, Centrarium may publish additional terms and conditions supplementing this policy.

2.Composition and purposes of personal data processing

2.1 The main purpose of personal data processing is to fulfill the obligations to the User stipulated by the Centrarium License Agreement and other agreements on the use of the Website services and Centrarium mobile application. More detailed information about the purposes of personal data processing and the composition of the processed data is provided in the Offer Agreement and relevant agreements with the User.

3. Principles and methods of personal data processing

3.1 Centrarium is guided by the following principles when processing personal data:
3.1.1. ensuring the lawfulness of the purposes and methods of personal data processing;
3.1.2. compliance of the purposes of personal data processing with the purposes predetermined and stated at the time of personal data collection;
3.1.3. compliance of the scope and nature of the processed personal data, as well as the methods of personal data processing with the purposes of personal data processing;
3.1.4. absence of redundant personal data in relation to the purposes declared during the collection of personal data;
3.1.5. ensuring the reliability of processed personal data;
3.1.6. use of separate databases for incompatible purposes of personal data processing.
3.2 Centrarium processes personal data both with the use of automation tools and without the use of automation tools.

4. Rules of personal data processing

4.1 Personal data is obtained directly from Users in the process of using the Website and Centrarium mobile application.
4.2 Personal data is collected using the Centrarium.com Website.
4.3 In cases stipulated by Centrarium's personal data processing processes, personal data may be transferred to third parties. Personal data may be transferred to third parties with the User's consent, as well as in cases provided for by the legislation of the Russian Federation and based on the requirements of federal laws. More detailed information on third parties to whom personal data may be transferred, as well as on the conditions under which personal data may be transferred to third parties, is provided in Offer Agreements and other agreements that the User accepts when applying for services on the Centrarium.com website.
4.4 Processing of personal data is carried out during the validity period of the License Agreement, other Agreements, agreements on the use of services of Centrarium Websites and mobile applications, and the terms established by law.

5.Ensuring the security of personal data

5.1 Centrarium takes all necessary protection measures, including those provided for by the legislation of the Russian Federation, aimed at ensuring confidentiality and security of personal data. The personal data protection measures applied at Centrarium include, among others:
5.1.1. a person responsible for ensuring the security of personal data at Centrarium has been appointed;
5.1.2. current threats to the security of personal data are identified;
5.1.3. a set of protection measures has been developed and implemented to ensure neutralization of actual security threats;
5.1.4. the rules of personal data security during their processing are defined;
5.1.5. periodic control and evaluation of the efficiency of the personal data protection measures taken is carried out.

6. Rights of Users in relation to their personal data

6.1 Users in accordance with Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" have the right to:
6.1.1. request information about their personal data processed by Centrarium, including:
- confirmation of the fact of personal data processing;
- legal grounds and purposes of personal data processing;
- the methods used for processing personal data;
- full name and location of Centrarium, information about third parties who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with Centrarium or on the basis of federal law;
- the composition of the personal data being processed and the source of their receipt;
- the terms of personal data processing, including the terms of their storage;
- the procedure for exercising the rights of the personal data subject provided for by law;
- information on the realized or supposed trans-border transfer of data;
- name and address of the person who processes personal data on behalf of Centrarium, if the processing has been or will be entrusted to such a person;
- other information required by law;
6.1.2. request familiarization with the personal data being processed;
6.1.3. demand clarification of personal data if it is incomplete, outdated or inaccurate;
6.1.4. request blocking of personal data if it is incomplete, outdated or inaccurate, or if Centrarium's processing of personal data is unlawful;
6.1.5. request the destruction of personal data if they are illegally obtained, or if they are not necessary for the stated purpose of processing, or in case of withdrawal of consent to the processing of personal data.
6.1.6. require Centrarium to notify all persons to whom incorrect or incomplete personal data have been previously communicated of any exceptions, corrections or additions made to such data;
6.1.7. appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of Centrarium in the processing and protection of his/her personal data.

7. Clarification and destruction of personal data

7.1 The User shall clarify personal data independently using the functions of the Website and mobile application.
7.2 Personal data processed by Centrarium shall be destroyed in the following cases:
7.2.1. upon achievement of the purposes of their processing or in case of loss of necessity in their achievement within a period not exceeding thirty days from the moment of achievement of the purpose of personal data processing, unless otherwise provided for by the contract to which the personal data subject is a party, beneficiary or guarantor, or by any other agreement between Centrarium and the personal data subject;
7.2.2. in case Centrarium identifies unlawful processing of personal data within a period not exceeding ten business days from the date of identification of unlawful processing of personal data;
7.2.3. if the personal data subject revokes his/her consent to the processing of personal data, if the personal data retention is no longer required for the purposes of personal data processing, within a period not exceeding thirty days from the date of receipt of the said revocation, unless otherwise provided for by the contract to which the personal data subject is a party, beneficiary or guarantor, or by any other agreement between Centrarium and the personal data subject;
7.2.4. in case of expiry of the personal data retention period determined in accordance with the laws of the Russian Federation and Centrarium's organizational and administrative documents;
7.2.5. in the event of an order from an authorized body for the protection of the rights of personal data subjects, the Russian Prosecutor's Office or a court decision.
7.3 Consent to the processing of personal data may be withdrawn by the User at any time. To exercise the right of revocation, the User should send a corresponding application to [email protected].
7.4 Withdrawal of the User's consent to the processing of personal data may not be grounds for Centrarium to terminate the processing if Centrarium has the grounds provided for in paras. 2, 7, 10 of Part 1 of Article 6 of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data".
7.5 In the event that services containing Google API technology (e.g. YouTube API Services) are used on the Centrarium Website, the User's data shall also be processed in accordance with https://www.youtube.com/t/terms and https://policies.google.com/privacy.