1. Information about the document

1.1. This Website is provided to users (including visitors) in accordance with this document, which defines the following Conditions for processing the Website data:
1.1.1. Privacy Policy – the Operator's policy on the organization of processing and ensuring the security of personal data;
1.1.2. Monitoring notification – notification of the specifics of data processing through the Website and the use of monitoring technologies.
1.2. The Operator has the right, at his/her sole discretion and without any special notification to the User, to periodically make changes to the Document by publishing changes/updates to it on the Website indicating the date on which the new version of the Document will enter into force. Continued use of the Website after the publication of a new version of the Document means the User's consent to the changes made. Accordingly, each time the User visits the Website, he/she undertakes to familiarize himself/herself with the current version of the Document and independently check the terms of this Document for changes.
1.3. This version of the Document has been approved by the Operator and is current and effective from July 01, 2024.
1.4. Additional terms (rules) published on the Website (hereinafter referred to as "Additional Terms") may apply to certain functionality or information (content) posted on the Website, such as the purchase and sale of products (goods, works, services), offers. By participating in any event on the Website governed by Additional Terms, the User agrees to comply with them along with the Document.
1.5. In case of any questions or problems regarding the Document or the Website, the User can contact the Operator using the data specified in the "Contact us" section of the Site.
1.6. The following abbreviations are used in this document:

Section I.
Privacy Policy

2.1. The Operator considers its most important tasks to comply with the principles of legality, fairness and confidentiality in the processing of PD, as well as ensuring the safety of their processing.
2.2. This Policy on the organization of processing and ensuring the safety of PD:
2.2.1. developed in order to implement the requirements of the current legislation of the RF in the field of PD processing and protection;
2.2.2. discloses the methods and principles of PD processing by the Operator, the rights and obligations of the Operator when processing PD, the rights of Users (PD subjects), and also includes a list of measures applied by the Operator to ensure the safety of PD during their processing;
2.2.3. it is a publicly available document declaring the conceptual foundations of the Operator's activities in the processing and protection of PD.

2. General provisions of the Policy

3. Principles, objectives and
content of PD processing

3.1. The Operator in its activities ensures compliance with the principles of PD processing specified in Art. 5 152-FZ.
3.2. The Operator performs the following targeted PD processing in accordance with the current legislation of the RF on PD:

3.3. The Operator has established the following conditions for the termination of PD processing in relation to the purposes of PD processing specified in paragraphs 3.2.1-3.2.2 of the Policy:
3.3.1. achieving the goals of PD processing and the maximum retention period of PD;
3.3.2. loss of the need to achieve the goals of PD processing;
3.3.3. provision by the PD subject or his/her legal representative of information confirming that PD is illegally obtained or is not necessary for the stated purpose of processing;
3.3.4. inability to ensure the legality of PD processing;
3.3.5. withdrawal by the PD subject of consent to PD processing, if the preservation of PD is no longer required for the purposes of PD processing;
3.3.6. the requirement of the PD subject to the Operator to stop processing PD, except in cases provided for by law;
3.3.7. expiration of the limitation period for legal relations within the framework of which PD processing is carried out or was carried out;
3.3.8. liquidation or reorganization of the Operator;
3.4. The Operator can process PD using automation tools by performing such actions as collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction.

4. Features of PD processing

4.1. When collecting PD, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of PD of citizens of the RF using databases located on the territory of the RF, except for cases expressly provided for by the current legislation of the RF on PD.
4.2. The Operator may carry out cross-border transfer of PD if there are appropriate legal grounds.
4.3. The Operator may create publicly available PD sources and (or) distribute PD only with the consent of the PD subject or on the basis of the requirements of the current legislation of the RF.
4.4. The Operator may send (subject to reasonable restrictions on the frequency and number of directions, at any time and without prior warning) to PD subjects information materials about the news and activities of the Operator, if there is appropriate consent from PD subjects. Information materials can be sent to PD subjects through those communication channels (contact information) that PD subjects have provided to the Operator. PD subjects have the right at any time to refuse to receive the Operator's materials following the instructions specified in the received materials, or by sending an appropriate request to the Operator.
4.5. The Operator does not make decisions that generate legal consequences for PD subjects or otherwise affect their rights and legitimate interests based solely on automated processing of their PD.
4.6. If the User transfers PD of other individuals to the Operator for the intended purposes, the User thereby certifies and guarantees the legality of such transfer of PD in accordance with the requirements of applicable law, as well as proper notification of these persons about such transfer of their PD to the Operator, if required by applicable law. The User, no later than 5 (five) business days from the date of receipt of the request from the Operator, provides the Operator with information and (or) documents confirming either the fact of obtaining the consent of the specified persons to transfer their PD from the User to the Operator, or the existence of other legal grounds for such transfer of PD and the fact of proper notification of the specified persons about their transfer PD. The composition and content of the provided information and (or) documents are determined taking into account the requirements of applicable legislation, as well as with respect for the rights and legitimate interests of these persons, the User and other persons.

5. Measures for the proper
organization of processing and
ensuring the safety of PD

5.1. When processing PD, the Operator takes all necessary legal, organizational and technical measures to protect them from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions in relation to them. Ensuring the safety of PD is achieved, in particular, in the following ways (taking into account their applicability, depending on the method and characteristics of PD processing):
5.1.1. appointment of a responsible person for the organization of PD processing;
5.1.2. by issuing documents defining the Operator's policy regarding PD processing, local acts on PD processing, defining for each purpose of PD processing the categories and list of PD being processed, the categories of subjects whose PD is being processed, methods, terms of their processing and storage, the procedure for destroying PD when achieving the goals of their processing or upon the occurrence of other legitimate grounds, as well as local acts establishing procedures aimed at preventing and detecting violations of the legislation of the RF, eliminating the consequences of such violations;
5.1.3. implementation of internal control and (or) audit of compliance of PD processing with the requirements of 152-FZ and regulatory legal acts adopted in accordance with it, requirements for PD protection, local acts of the Operator;
5.1.4. assessment of the harm that may be caused to PD subjects in case of violation of 152-FZ, the ratio of the specified harm and the measures taken by the Operator aimed at ensuring the fulfillment of obligations provided for by 152-FZ;
5.1.5. familiarization of persons directly engaged in PD processing for the purposes provided by the Operator with the provisions of the legislation of the RF on PD, including requirements for PD protection, local acts of the Operator regarding PD processing and (or) training of these persons;
5.1.6. identification of security threats to PD that may arise during their processing in the PDIS;
5.1.7. the application of organizational and (or) technical measures to ensure the safety of PD during their processing, including in PDIS, necessary to ensure the constant confidentiality, integrity, accessibility and stability of processes and (or) systems related to PD processing;
5.1.8. the use of information security tools that have passed the compliance assessment procedure in accordance with the established procedure, when the use of such tools is necessary to neutralize current threats to the security of PD and information technologies used in PDIS;
5.1.9. assessment of the effectiveness of the measures taken to ensure the safety of PD before commissioning of the PDIS;
5.1.10. determining the storage locations of PD material media, as well as ensuring the accounting and safety of PD material media;
5.1.11. by detecting the facts of unauthorized access to PD and taking appropriate measures, including measures to detect, prevent and eliminate the consequences of computer attacks on PDIS related to PD processing, and to respond to computer incidents in them;
5.1.12. restoration of PD modified or destroyed due to unauthorized access to them;
5.1.13. control over the measures taken to ensure the safety of PD and the level of protection of PDIS;
5.1.14. by establishing a list of persons involved in the processing of PD, including in the PDIS, and restricting access to PDIS for other persons;
5.1.15. the organization of the security regime of the premises in which PD processing is carried out and (or) the software and hardware used for PD processing are located;
5.1.16. establishing rules for access to PD processed in PDIS, as well as ensuring registration and accounting of all actions performed with PD in PDIS.
5.2. In case of establishing the fact of illegal or accidental transfer (provision, distribution, access) of PD, which resulted in violation of the rights of PD subjects, the Operator, in accordance with the procedure provided for by law and within the appropriate time frame, notifies the authorized body for the protection of the rights of PD subjects about this fact.
5.3. The Operator may ensure connection to the GosSOPKA and inform the federal executive authority authorized in the field of security, represented by the NCICC, about computer incidents that led to the illegal transfer (provision, distribution, access) of PD.

6. The rights of PD subjects

6.1. The PD subject has the right to receive information about the processing of his PD by the Operator.
6.2. The PD subject has the right to require the Operator to clarify these PD, block or destroy them if they are incomplete, outdated, inaccurate, illegally obtained or cannot be recognized as necessary for the stated purpose of processing, as well as to take the prescribed measures legal measures to protect their rights.
6.3. The right of a PD subject to access to his PD may be restricted in accordance with federal laws, including if the PD subject's access to his PD violates the rights and legitimate interests of third parties.
6.4. The PD subject has the right at any time, in full or in any part, to revoke the consent previously provided to the Operator for PD processing and (or) to contact the Operator with a request to terminate PD processing, except in cases where PD processing is provided for in paragraphs 2-11 of Part 1 of Article 6, Part 2 Articles 10 and part 2 of Article 11 152-FZ. The rights specified in this paragraph may be exercised by sending an application to the Operator.
6.5. In order to realize and protect their rights and legitimate interests, the PD subject or his representatives have the right to contact the Operator in any way convenient and possible for them (including by e-mail info@tme).
6.6. The Operator considers any appeals and complaints from PD subjects, thoroughly investigates the facts of violations and takes all necessary measures to eliminate them immediately, punish the perpetrators and resolve disputes and conflict situations in a pre-trial manner.
6.7. The PD subject has the right to appeal against the actions or omissions of the Operator by contacting the authorized body for the protection of the rights of PD subjects.
6.8. The PD subject has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.

7. The person responsible for
the organization of PD processing

7.1. The rights, obligations and legal responsibility of the person responsible for the organization of PD processing are established by art.22.1 152-FZ and local acts of the Operator in the field of PD processing and protection.
7.2. The appointment of the person responsible for the organization of PD processing and his release from these duties is carried out by a decision of the meeting of the founders of the Operator. When appointing a person responsible for organizing the processing of PD, the powers, competencies and personal qualities of the person are taken into account, designed to allow him to properly and fully exercise his rights and fulfill his duties.
7.3. The person responsible for the organization of PD processing:
7.3.1. organizes the implementation of internal control over the Operator's compliance with the legislation of the RF on PD, including requirements for the protection of PD;
7.3.2. ensures that the persons who process PD for the purposes provided by the Operator are informed of the provisions of the legislation of the RF on PD, local acts of the Operator on PD processing, requirements for PD protection;
7.3.3. exercises control over the reception and processing of appeals and requests from PD subjects or their representatives.

9. Procedure for approving and
making changes to the Policy

9.1. The Policy is approved and put into effect by the decision of the Operator and is valid until its cancellation.
9.2. The Operator has the right to make changes to the Policy as necessary (hereinafter referred to as "Changes"). The changes are approved by the decision of the Operator. In this case, the amended version of the Policy is published on the Website with an indication of the start date of its validity.
9.3. PD subjects are obliged to independently monitor Changes. Visiting/using the Website by PD subjects after the start of the amended version of the Policy means that such PD subjects become familiar with the provisions of the amended version of the Policy.
9.4. The Policy is reviewed as necessary, but at least once every three years from the date of the previous review of the Policy.
9.5. The Policy may be reviewed earlier than the deadline specified in clause 9.4 of the Policy, as changes are made:
9.5.1. to the regulatory legal acts of the RF in the field of PD;
9.5.2. in the order of the Operator's organization of processing and ensuring the safety of PD.

10. Responsibility

10.1. The founders of the Operator and participants in its activities, as well as other persons guilty of violating the norms governing the processing and protection of PD, bear responsibility provided for by the legislation of the RF.

Section II.
Notification of monitoring

11.1. While visiting the Website and using its functionality, it is possible to passively collect and further process technical information[1] from user devices using various technologies and methods. This is necessary due to the peculiarities of the functioning of the Internet and access to information resources (websites) hosted on this network. This Notification describes the rules for collecting and further processing technical information in relation to the Website.
11.2. Technical information (data on user devices and on the use of the Website) can be obtained by the Operator using various methods, including, but not limited to, cookies, web beacons, scripts and other tracking and targeting tools (hereinafter referred to as "cookies"). To organize the receipt (collection) of information, both the technical capabilities of the Website and the functionality of third-party Internet services can be used (for more information, see section "15. Description and blocking of cookies"), provided to the Operator by third parties and intended for evaluating traffic and (or) analyzing the use of Websites.
11.3. The Operator has the right to change the list of third-party Internet services used without notifying the User. Third-party Internet services do not and do not have the ability to compare the information independently obtained (collected) by them during the visit of the Website and the use of its functionality by the User with the PD received (collected) by the Operator using the technical capabilities of the Website and (or) indicated by the User in the appropriate web forms on the Website and allowing identification (recognition) of the User. The storage and further processing of information received by third-party Internet services is provided by these services on their own computing capacities, for the territorial placement of which the Operator is not responsible.
11.3.1. The collection of technical information and its further use is necessary for safe and productive interaction with the User through the Website, personalization of the user experience by providing products, functions, features and offers adapted to user needs, preferences and interests, as well as analysis, performance management and improvement of user interaction.
11.4. Users can refuse to accept authentication cookies of the Website using the settings of their Internet browser. However, this may lead to some inconveniences when using the Website (for example, the need for Users to regularly go through the authentication procedure on the Website).
11.5. The Website is not intended for persons under the age of 18, and the Operator requires that such persons do not provide their personal data through the Website. If the Operator reveals the fact that juveniles or minors have provided their PD through the Website, the Operator will destroy the specified PD or ensure their destruction within a period not exceeding ten working days from the date of detection of such a fact.
11.6. The Notification does not regulate the procedure for processing and protecting PD in relation to any other websites or web objects (including, but not limited to, any mobile applications) accessible through the Website or to which the Website contains a link. The presence or inclusion of a link to any such website or object on the Website does not imply any guarantees or assurances on the part of the Operator.

[1] For example, the IP address of the user's device, the time of the visit, the pages viewed, the downloaded files, the type and version of the Internet browser, authentication cookies.

11. General provisions of the
Notification

12. Legality of the
use of cookies

12.1. According to the legislation, in order to save cookies on user devices, it is necessary to have proper permission (for example, the Operator's agreement with the User and/or the User's consent, when necessary), providing the User with clear and complete information about how cookies are used on the Website.
12.2. In order to comply with legal requirements, the Operator has taken the following measures:
12.2.1. listed cookies and other monitoring technologies used on the Website, explained the purposes of their use, and also provided information about the validity period of such files and who places them – the Operator or third parties;
12.2.2. analyzed how the use of cookies, taking into account their specifics, can affect the rights and interests of the User;
12.2.3. provided clear and complete information about cookies on the Website, and also outlined the specifics of using each of them, taking into account the nature of their impact on the rights and interests of Website users as subjects of PD (see the section "Types of cookies used on the Website");
12.2.4. implemented ways to provide legal grounds, including the User's permission, for the use of cookies on the Website, taking into account the specifics of their use and the nature of their impact on the rights and interests of the User.

13. Permissions for
the use of cookies

13.1. The requirements for ways to ensure the legal basis for the use of cookies may change from time to time. For example, obtaining the User's explicit permission to use cookies is the most legally reliable mechanism for legalizing the use of cookies, but this method may adversely affect the quality of User interaction with the Website, as well as the ability of Websites to legitimately collect technical information about the use of the Website. Alternatively, there are ways to obtain the User's implicit permission, which is implied if the User has not refused to use cookies after he has been provided with clear and understandable information about them, as well as the ability to easily configure the appropriate settings of his user device (see the section "Types of cookies used on the Website"). This allows the User to accept or reject cookies used by the Website.
13.2. The choice of the method of providing legal grounds for the use of cookies depends on the impact of the cookie on the rights and interests of the User, taking into account the following factors:
13.2.1. who provides the cookie (the operator or a third party);
13.2.2. what kind of data is collected by the cookie;
13.2.3. what purposes does it serve;
13.2.4. how long is it stored;
13.2.5. what is the nature of the Website through which the file is provided.
13.3. A three-level approach is used for cookies that require the User's permission:

13.4. Cookies used on the Website are characterized by a low or medium degree of privacy impact, therefore they can be used on the basis of the User's implied permission. The evaluation and analysis of the types of cookies used on the Website are given in the section "Types of cookies used on the Website", which contains information about the purpose, expiration dates and how to refuse cookies (see the column "How to block").
13.5. Taking into account the fact that the Website can store a large number of cookies on user devices, these files are grouped into categories (for example, advertising or analytical). This makes it easier to inform about cookies and makes the relevant information clearer to the User.

14. The procedure for approving
and making changes

14.1. it is approved and put into effect by the decision of the Operator and is valid until its cancellation.
14.2. The Operator has the right to make changes to the Notification as necessary (hereinafter referred to as "Changes"). The changes are approved by the decision of the Operator. In this case, the amended version of the Notification is published on the Website with an indication of the start date of its validity.

15. Description and blocking
of cookies