Personal Data Processing Policy — ILC Stor

Application: ILC Stor
Operator: ILS LLC (TIN 9716000590, OGRN 1247700636743)
Address: 129323, Moscow, Snezhnaya St., 26
Contact: via the "Contacts" section in the app

1. General Provisions

This Personal Data Processing Policy (hereinafter — the Policy) is drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and governs the processing of personal data and the measures taken to ensure the security of personal data by ILS LLC (hereinafter — the Operator) in the ILC Stor mobile application.

1.1. The Operator's primary goal is to observe the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrecy.

1.2. This Policy applies to all information the Operator may receive about users of the ILC Stor mobile application.

2. Key Definitions

Automated processing of personal data — processing of personal data by means of computer technology.

Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).

Personal data — any information relating directly or indirectly to an identified or identifiable individual (the data subject).

Processing of personal data — any operation or set of operations performed on personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer, depersonalisation, blocking, deletion or destruction of personal data.

Operator — a legal entity that independently or jointly with others organises and/or carries out the processing of personal data and determines the purposes of processing, the composition of personal data to be processed, and the operations to be performed.

User — any user of the ILC Stor mobile application.

3. Rights and Obligations of the Operator

The Operator has the right to:

• Receive reliable information and/or documents containing personal data from the data subject;
• Continue processing personal data without the data subject's consent where grounds exist under the Personal Data Law;
• Independently determine the measures necessary to fulfil obligations under the Personal Data Law.

The Operator is obliged to:

• Provide the data subject, upon request, with information concerning the processing of their personal data;
• Organise the processing of personal data in accordance with applicable Russian Federation law;
• Respond to requests from data subjects and their legal representatives in accordance with the Personal Data Law;
• Take legal, organisational and technical measures to protect personal data;
• Cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law.

4. Rights and Obligations of Data Subjects

Data subjects have the right to:

• Obtain information about the processing of their personal data;
• Request correction of inaccurate personal data;
• Request blocking or deletion of personal data processed unlawfully;
• Withdraw consent to the processing of personal data;
• Appeal against the actions or inaction of the Operator to the authorised body for the protection of the rights of personal data subjects.

5. Personal Data Processed

The following categories of personal data are processed in the ILC Stor application:

• Last name, first name, patronymic;
• Email address;
• Phone number;
• Delivery addresses;
• In-app behaviour data and IP addresses.

The processing of special categories of personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, health data) is not carried out.

6. Purposes, Legal Grounds and Retention Period

Personal data is processed for the following purposes:

• User identification and authentication — legal ground: consent of the data subject;
• Providing services and fulfilling contractual obligations — legal ground: performance of a contract;
• Sending order and notification messages — legal ground: consent of the data subject;
• Improving the application — legal ground: legitimate interests of the Operator;
• Compliance with applicable law — legal ground: legal obligation.

Personal data is retained for the period necessary to fulfil the stated purposes, but no longer than required by applicable law.

7. Personal Data Processing Conditions

Processing of personal data is carried out under the following conditions:

• With the consent of the data subject;
• Where processing is necessary for the performance of a contract to which the data subject is a party;
• Where processing is necessary to fulfil an obligation imposed on the Operator by law;
• Where processing is necessary for the legitimate interests of the Operator or third parties.

8. Transfer of Personal Data

Personal data is not transferred to third parties except in the following cases:

• With the explicit consent of the data subject;
• Where required by applicable law;
• To service providers acting on behalf of the Operator under data processing agreements.

Cross-border transfer of personal data is carried out only to countries that provide adequate protection of the rights of personal data subjects.

9. Security of Personal Data

The Operator takes the following organisational and technical measures to ensure the security of personal data:

• Appointing persons responsible for the processing of personal data;
• Applying legal, organisational and technical measures to ensure the security of personal data;
• Assessing the harm that may be caused to data subjects in the event of a breach of the Personal Data Law;
• Familiarising employees who process personal data with the provisions of the Personal Data Law.

10. Final Provisions

Users may obtain any clarification on matters relating to the processing of their personal data by contacting the Operator via the "Contacts" section of the ILC Stor application.

The Operator reserves the right to amend this Policy. A new version takes effect from the moment it is published in the mobile application. The current version is always available in the app.