regarding the processing of personal data
(Privacy Policy)

City of Moscow, August 18, 2020
1. Definitions

1.1. Policy – the policy of the Oniclay Project regarding the processing of personal data (Privacy Policy).

1.2. Operator – Rychagov Anton Vladimirovich, the details are given in section 12 of the Policy, the owner of the Oniclay Project.

1.3. Services – websites, programs, products or services of the Oniclay Project.

1.4. Personal information – all data, including personal within the meaning of the applicable law that the Operator may obtain about you during the process of using of any Services.

2. Who processes the information

2.1. Your Personal information is collected and used by the Operator to ensure the use of the Services.

3. Policy objective

3.1. Protection of your Personal information and your confidentiality. When you use the Services, the Operator protects and processes your Personal information in strict accordance with the applicable law.

4. What Personal information does the Operator collect about you

4.1. Personal information collected during the operation of the Services may differ depending on your actions.

4.2. The operator does not verify the Personal information provided by you, except in cases stipulated by the Policy, and cannot make any judgement to its accuracy, as well as whether you have sufficient legal capacity to provide your Personal information. However, the Operator assumes that you provide reliable and sufficient Personal information, as well as update it in a timely manner.

4.3. The Operator may collect the following categories of your Personal information while using the Services:

- Personal information provided by you when entering data in the "Waiting List" form on the website oniclay.com, such as your last name, first name, patronymic indicated in your identity document, contact phone number, postal code, country, city, street, house and apartment number;

- electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information);

- date and time of access to the Services;

- other information about you that is necessary for processing in accordance with the agreements and other terms governing the use of the Operator's Services;

- the Operator does not purposefully collect sensitive personal information (such as your race, political views, health information, and biometric data), except in cases stipulated by the agreements of individual Services. However, you can provide this information to the Operator yourself, and in this case the Operator will process it as part of providing you with the Services. In this case, you should take into account that the Operator cannot request your consent to such processing, because it is not aware in advance of the potentially sensitive nature of Personal information that you can provide to the Operator.

4.4. The operator does not collect data for the purpose of creating a "portrait" of the user to the extent that this may significantly affect your rights and freedoms under the applicable law.

5. What is the legal basis and purpose of processing Your Personal information

5.1. The Operator does not have the right to process your Personal information without sufficient legal grounds. Therefore, the Operator processes your Personal information only if:

- processing is necessary to fulfill the Operator's contractual obligations to you, including ensuring the operation of the Services;

- processing is necessary to comply with the legal obligations;

- when required by the applicable law, processing is necessary to protect the legitimate interests of the Operator, if such processing does not significantly affect your interests, your fundamental rights and freedoms. Please note that when processing your personal information on this basis, the Operator will always strive to maintain a balance between its legitimate interests and the protection of your privacy.

5.2. The Operator processes Your Personal information to ensure its legitimate interests, for example, in the following cases:

- to better understand how you interact with our Services;

- to improve, change, personalize, or otherwise improve the Services for the benefit of all users;

- for specific purposes or as required by the applicable law, we may request your separate consent to process your Personal information. For jurisdictions where consent is recognized as a separate legal basis, the beginning of your use of the Operator's Services indicates your consent to such processing. We hereby inform you and you confirm that you have no obligation to provide us with any Personal information when you use the Services and this provision is based solely on your free will. You acknowledge, however, that without providing Personal information, we will not be able to provide you with the Services, in which case your use of the Services will be limited.

5.3. The Operator always processes your Personal information for certain purposes and only the Personal information that is relevant to achieving those purposes. In particular, we process Your Personal information for the following purposes:

5.3.1. adding a product to the Waiting List;

5.3.2. delivery of products;

5.3.3. promotion of products, works, and services through direct email contacts;

5.3.4. transfer of personal data to a third party JSC "Russian Post", including the courier service of the Russian Post "EMS" (TIN: 7724490000).

6. How the Operator protects Your Personal information

6.1. In most cases, Personal information is processed automatically without access to it by any of the Operator's employees. If such access is required, it can only be granted to those employees of the Operator who need it to perform their tasks.

6.2. To protect and ensure the confidentiality of data, all employees must comply with internal rules and procedures regarding the processing of Personal information. They must also follow all technical and organizational security measures in order to protect your Personal information.

6.3. The Operator has also implemented sufficient technical and organizational measures to protect Personal information from unauthorized, accidental or unlawful destruction, loss, alteration, unfair use, disclosure or access, as well as other illegal forms of processing. These security measures were implemented taking into account the state-of-the-art technology, the cost of implementing them, and the risks associated with the processing and nature of Personal information.

7. Who else has access to your Personal information and to whom it may be transferred

7.1. Within the Operator Group

7.1.1. The Operator may transfer your personal information to its employees. The operator may also transfer your Personal information to its affiliates, including other companies from the group of persons to which the Operator belongs.

7.1.2. Please note that the level of protection of Personal information in some countries may not coincide with the level established in your jurisdiction, and by using the Operator's Services, you agree to the information transfer.

7.2. In all cases, Personal information will also be processed only for the purposes set out in the Policy section 5, unless otherwise provided by the terms of use of the Services.

The Operator may also transfer Personal information to third parties in order to achieve the purposes specified in the Policy section 5. These third parties may include:

7.2.1. legal entities with regard to whom the rights or obligations have been assigned or innovated by the relevant agreement;

7.2.2. any national or international regulatory authority, law enforcement authorities, central or local executive authorities, other official or state bodies or courts in respect of which the Operator is required to provide information in accordance with applicable law upon request;

7.2.3. third parties, if you have agreed to the transfer of Your Personal information, or the transfer of Personal information is required to provide you with the relevant Service or to fulfill a certain agreement or contract concluded with you.

8. Where your Personal information is stored and processed

8.1. Your Personal information will be stored in the Russian Federation.

8.2. For Russian users: the Operator records, arranges, accumulates, stores, clarifies (updates, changes), and extracts personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

8.3. For users from the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, the Operator has taken appropriate measures to ensure that such transfers are made in accordance with the current EU data protection regulations.

8.4. In particular, the Operator is guided by Standard contractual terms approved by the European Commission to ensure an adequate level of protection of your Personal information transmitted to Russia.

8.5. If you are located in a territory where your consent is required for the transfer of your Personal information to another jurisdiction, then by using the Services, you give the Operator your explicit and unambiguous consent to such transfer or storage or processing of information in other specified jurisdictions, including Russia.

9. How long do we store your Personal information

9.1. The Operator stores your Personal information for as long as it is necessary to achieve the purpose for which it was collected, or to comply with legal and regulatory requirements.

9.2. If you want any of your Personal information to be deleted from the Operator's databases, you can send a notification to the Operator.

10. Your rights

10.1. The rights you have

10.1.1. If required by applicable law, you have the right to access your Personal information processed by the Operator in accordance with the Policy.

10.1.2. If you believe that any information that the Operator stores about you is incorrect or incomplete and it is provided for by applicable law, you have the right to: request the deletion of your Personal Information, or part of it, and withdraw your consent to the processing of your Personal information; require restrictions on the processing of your Personal information; request a copy of the Standard contractual terms that allow the transfer of Your Personal information to Russia; object to the processing of your Personal information, if required by applicable law.

10.1.3. The Operator will fulfil these requests in accordance with applicable law.

10.1.4. In cases provided for by applicable law, you may also have other rights not specified above.

10.2. How can you exercise your rights

10.2.1. To exercise the rights listed above, contact the Operator using the details in the Policy section 12.

10.2.2. If you are not satisfied with how the Operator processes your Personal information, please let us know and we will consider your claim. If you are not satisfied with the Operator's response, you have the right to file a complaint with the competent authority.

11. Policy Update

11.1. This Policy may be changed. The Operator has the right to make changes at its discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable legislation, as well as when the relevant changes are related to changes in the operation of the Services.

11.2. The Operator is obliged not to make any significant changes, impose any additional encumbrances or limitations on your rights established by the Policy without your notice. You will be notified of such changes. Relevant notifications may be displayed on the Services (for example, via a pop-up window or banner) before such changes come into force, or may be sent to you via other communication channels (for example, by email if you have provided us with your contact information).

12. Operator's Details

IP Rychagov Anton Vladimirovich;
TIN: 342702189428
PSRN: 320344300072616


Russian Central Bank Identifier Code: 044525999; Correspondent account: 30101810845250000999

Paypal: oniclayorder@gmail.com
E-mail: oniclaystore@gmail.com