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PRIVACY POLICY

Approved by
“AS GRUPP” LLC
Chief Officer
Gasymova A.R.
02.04.2020

Personal Data Processing and Protection Policy

  1. General provisions

The Policy is a local regulatory act for “AS GRUPP” LLC, registered: 115419, Moscow, 2nd Roshinsky drive, 8, floor 5, room 507 (“the Operator”), the purpose of the policy is to establish relations with personal data  of private persons (clients, web page visitors, loaners, including potential and active), to ensure personal data protection for the following loaners.

The following Policy comes into effect once it has been approved by the  “AS GRUPP” LLC” Chief Officer and remains in effect indefinitely up until the new version of The Policy is approved.

This Policy determines the following purposes:
— determination of data processing sequence;
— provision of the compliance of the  “AS GRUPP” LLC”  LLC data processing in accordance with Russian Federation Federal Law  “On Personal Data”;
— provision of personal data protection.

This Policy determines the following goals:
— determination of personal data processing principles;
— determination of personal data processing conditions and data protection regulations;
— determination of personal data subjects’ rights,  “AS GRUPP” LLC” LLC  rights and obligations in order to process personal data.

This Policy is applied to all operations  performed on  personal data by  “AS GRUPP” LLC” LLC whether or not by automated means including information and telecommunication networks. 

No decisions concerning your rights or interests will be made based only on your personal data automated processing.  

Providing the third parties’ personal data without their consent is prohibited. You are responsible for the consequences caused by failure to adhere to the following actions;.   

  • By browsing our web-page on your computer, mobile device and (or)
  • using mobile application, and (or)
  • filling in web-forms containing your personal data, and (or)
  • registering as a member of a loyalty program, and also by giving your personal data you stated in this Policy.
  1. Terms and conditions

For the purposes of this consent  the following terms are being used:
— personal data (PD) – any information concerning the private person (personal data subject) directly or otherwise;
— PD subject  – private person (client,  “AS GRUPP” LLC” web-page visitor,  “AS GRUPP” LLC” application user,  “AS GRUPP” LLC” goods and services consumer, potential or actual), whose personal data is being processed by  “AS GRUPP” LLC”. In the following document it is a private person intending to order goods, use  “AS GRUPP” LLC” services for personal, family, domestic or other needs not associated with income generated activities, and also to take a survey.  
— PD operator (the Operator) –  “AS GRUPP” LLC”, registered: 115419, Moscow, 2nd Roshinsky drive, 8, floor 5, room 507, OGRN: 1197746261349, TIN: 9725007916, CRTR: 772501001;
— PD processing – any PD action (operation) or the combination of actions (operations),  carried out by automated means as well as non-automated means . PD processing includes collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, use, transmission, anonymization, restriction, erasure, destruction.
— PD processing – is a PD processing with use of computers;
— PD transmission – actions that lead to revealing PD to the indefinite range of third parties;
— PD providing – actions that lead to revealing PD to a specific certain third party or parties;
— PD restriction – temporary PD processing termination (not including cases when the processing is needed to adjust the PD);
— PD destruction – actions that lead to the impossibility  of PD contents restoration in the PD information data system and (or) that are associated with destruction of the PD physical storage device;
— PD anonymization – actions leading to the impossibility  to determine PD accessory to a certain subject without additional information;
— web-page – the following web-page: https://waterful.ru/.

Personal data subject general rights: 
— The subject has the right to access PD related to the following:
— Confirmation of the fact that the Operator processes their personal data;
— Legal grounds and purposes of personal data processing;
— Purposes and methods used by the Operator to process personal data;
— Name and location of the Operator, details of the persons (save Operator employees), who have an access to the personal data or those who may be granted access to personal data on the basis of a contract, entered into with the Bank, or on the basis of the federal law.
— Period for which personal data is being processed, including storage period;
— Company name or full name and address of the party, carrying out personal data processing under the Operator’s order, if processing is ordered or will be ordered to such party;
 — Contact the Operator and file requests;
— Appeal to the actions or the lack of actions conducted by the Operator.
— Retraction of the right to PD processing.

  1. Obligations of the Operator

The Operator undertakes to:
— Provide information related to the processing of their personal data in case of application or receipt of a request from a personal data subject or their representative;
— Notify a personal data subject  on their personal data processing if such data is received not from the personal data subject;
— Explain the personal data subject legal consequences of refusal to provide their personal data;
— Publish or provide unlimited access to the Policy and PD protection requirements data;
— Take necessary legal, organizational or technical measures to protect PD from unlawful or accidental access to it, destruction, adjusting, restriction, copying, providing, transmitting and other wrongful actions towards PD;
— Respond to the PD subject’s, their representatives or authorized rights protection authorities requests and enquiries.

  1. Personal data processing purposes:

 “AS GRUPP” LLC” shall process personal data for the following purposes:
— to conduct marketing research and to contact the subject, including sending notifications, requests and information regarding offered goods, provided services and processing subject’s requests;
— to participate in contests, promotions, events, surveys, research conducted by  “AS GRUPP” LLC”.

When requested by you or  “AS GRUPP” LLC”, your personal data can be processed according to the separately filed consent.

  1. Legal grounds for personal data processing:

This Policy is elaborated in accordance with the requirements of the following regulatory acts:


Constitution of the Russian Federation;
The Russian Federation Federal Law of July 27, 2006 № 149-FZ «On Information, Informational Technologies And The Protection Of Information»;
The Russian Federation Federal Law of July 27, 2006 № 152-FZ “On Personal Data”;
Order of the Government of the Russian Federation of  November 1, 2012 № 1119 “About approval of the Regulations on state regulation of prices for products, delivered according to the state defense order”;
Order of the Government of the Russian Federation of September 15, 2008 № 687 “On Approval of the Statute on Special Aspects of Personal Data Processing Without the Use of Automation Technology”;
Russian FSTEC order №  21 of February 18, 2013 “On approving the composition and contents of organizational and technical means to ensure personal data security during processing in personal data information systems”;

Processing PD size;
Place of residence information;
Contact information (telephone number, email address);
Offered goods and provided services information;

PD processing conditions:

List of the approved actions towards PD:
PD collection;
PD recording;
PD organisation;
PD structuring;
PD storage;
PD adaptation or alteration;
PD retrieval;
PD use;
PD transmission (providing, access);
PD anonymization;
PD restriction;
PD erasure;
PD destruction.

The Operator is able to conduct PD processing whether or not by automated means including information and telecommunication networks.

Signing the Personal Data Processing Consent you agree to the right of  “AS GRUPP” LLC” to provide the access to your PD to  “AS GRUPP” LLC” employees.

In some circumstances we are obligated to disclose the data to law enforcement and other government authorities if it is provided in the laws of Russian Federation.

  1. Personal data confidentiality

 “AS GRUPP” LLC” as the Operator is obliged not to disclose and not to transmit PD to any third parties without PD subject’s consent, if not stated otherwise in the federal laws.

 “AS GRUPP” LLC” is obliged to take necessary legal, organizational or technical measures to protect PD from unlawful or accidental access to it, destruction, adjusting, restriction, copying, providing, transmitting and other wrongful actions towards PD.

  1. Technical data processing

   In order to improve our Web-page and to provide better content for your computer or mobile device, to present you with an opportunity to navigate our Page easily, we also process the information of your IP-address, browser and OS, data provided by cookies and other information.

 This data is automatically provided by the device you open our web-page with and is used only for the purposes of statistics and provided services quality improvement analysis.

  1. Personal data processing consent

You as the personal data subject hereby give  “AS GRUPP” LLC”, located by the address stated in paragraph 1 of this Policy, your consent to process your personal data including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, use, transmission, anonymization, restriction, erasure, destruction whether or not by automated means including information and telecommunication networks.

 “AS GRUPP” LLC” guarantees to respect your following rights:
– to obtain details, relating to processing your personal data stored by  “AS GRUPP” LLC”;

– to erase, to adapt or alter your personal data stored by  “AS GRUPP” LLC”;

– other rights secured by the legislation of the Russian Federation in force.

Personal data processing consent provided by you according to the following Policy has its effect up until you withdraw the following consent under the stated conditions if otherwise not stated  by the legislation of the Russian Federation. 

You as a personal data subject shall have the right to withdraw your consent to personal data processing. If you withdraw your consent to process personal data,  “AS GRUPP” LLC” is obligated to stop processing personal data or to provide such action (if the personal data processing is conducted by the third party, acting under the authority of  “AS GRUPP” LLC”) and if the personal data storage is no longer required for the processing purposes, to destroy personal data or to provide its destruction (if the personal data processing is conducted by the third party, acting under the authority of  “AS GRUPP” LLC”) within the deadline stated by the federal law if otherwise not stated by the contract, the side, beneficiary or guarantor of which you act as, or any other agreement between  “AS GRUPP” LLC” and yourself, or if  “AS GRUPP” LLC” shall not conduct your personal data processing on the grounds, provided by federal law.

You can file your Personal data processing consent withdrawal claim using one of the following options:

Personally file a claim at  “AS GRUPP” LLC” located on the territory of Russian Federation;
Mailing the claim to the following address: 115419, Moscow, 2nd Roshinsky drive, 8, floor 5, room 507;
Emailing electronic version of the claim signed by electronic signature according to the federal law of Russian Federation to the following address: hello@waterful.ru;
Filing the claim through the form on the web-page: waterful.ru

If a personal data subject withdraws their consent to process personal data  “AS GRUPP” LLC” shall have the right to continue processing personal data without the personal data subject’s consent in cases stipulated by the legislation of the Russian Federation in force.

  1. Where and how do we store your data

 “AS GRUPP” LLC” shall, while processing personal data, take necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, disclosure, use, alteration or destruction by any organization or private person.

It is provided by technical, administrative and practical protection measures. First your personal data is being collected and stored on the territory of Russian Federation. After your data can be transmitted to the territory of a foreign country when it is stipulated by the legislation of the Russian Federation in force.

  1. Data renewal

If you find any personal data inaccuracy or you see the necessity to update it (e.g. in cases of changing the name, address etc.), contact us, so we could make the necessary changes.  “AS GRUPP” LLC” is obligated by Russian Federation law to update all your personal data.

You can file your Personal data update claim using one of the following options:

Personally file a claim in any  “AS GRUPP” LLC” office located on the territory of Russian Federation;
Mailing the claim to the following address: 115419, Moscow, 2nd Roshinsky drive, 8, floor 5, room 507;
Emailing electronic version of the claim signed by electronic signature according to the federal law of Russian Federation to the following address: hello@waterful.ru;
Filing the claim through the form on the web-page: waterful.ru

  1. Access to information

If you’d like to obtain the details relating to your personal data processed by  “AS GRUPP” LLC”, we shall provide the requested information in accordance with the laws of the Russian Federation.

To obtain the following information you can approach  “AS GRUPP” LLC” using one of the following options in accordance to requirements stated in tha part 3, section 14 of The Russian Federation Federal Law of July 27, 2006 № 152-FZ “On Personal Data”:


Personally file a claim in any  “AS GRUPP” LLC” office located on the territory of Russian Federation;
Mailing the claim to the following address: 115419, Moscow, 2nd Roshinsky drive, 8, floor 5, room 507;
Emailing electronic version of the claim signed by electronic signature according to the federal law of Russian Federation to the following address: hello@waterful.ru;
Filing the claim through the form on the web-page: waterful.ru

You claim should contain the following information:
Your primary document of identification number, date of issuance and issuing authority;
Confirmation of your relations status with  “AS GRUPP” LLC” or any other confirmation of the fact that the Operator is processing your personal data;
Your signature (e-signature in case of filing the e-claim).

  1. Questions

If you have any questions regarding the following Policy, contact us: 115419, Moscow, 2nd Roshinsky drive, 8, floor 5, room 507, or or the phone +7 495 098 01 08 or via email: hello@waterful.ru; or via form on our web-page: waterful.ru.

Producer: ООО «AS GRUPP»,
115419, Moscow, 2nd Roshinsky drive, 8, floor 5, 507 space
Phone: +7 495 225 57 53
Producer: ООО «AS GRUPP», Russian Federation,Stavropol territory, Petrovskiy area, Suhaya Buyvola village, 400 m west to house № 201 on Krasnaya st.
Phone: +7 495 225 57 53
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