Privacy Policy and Data Processing

1. General Provisions

This Privacy and Data Processing Policy (hereinafter referred to as the "Policy") has been drawn up in accordance with the requirements of the legislation of the Russian Federation and defines the procedure for processing data (including personal data) and the measures to ensure data security taken by ООО «МОЛНИЯ», registration number 1384403828 (hereinafter referred to as the "Operator"). The Operator's most important goal and condition for carrying out its activities is to respect the rights and freedoms of man and citizen when processing their Data, including the protection of the rights to inviolability of private life, personal and family secrecy. The Policy applies to all information that the Operator may obtain about visitors to the website https://молния.москва, https://молния.москва/ch, https://молния.москва/eng

2. Basic Concepts Used in the Policy

2.1. Automated Processing of Data — processing of Data using computer technology.
2.2. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network addresses https://молния.москва, https://молния.москва/ch, https://молния.москва/eng, https://молния.москва/privacypolicy_ru, https://молния.москва/privacypolicy_ch, https://молния.москва/privacypolicy_eng
2.3. Processing of Data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with Data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction of Data.
2.4. Operator – ООО «МОЛНИЯ», registration number 1384403828,
carrying out the processing of Data.
2.5. Data — any information relating directly or indirectly to a specific or identifiable User of the Website (including personal data, where applicable).
2.6. User — any visitor to the Website.
2.7. Blocking of Data — temporary suspension of the processing of Data (except in cases where processing is necessary to clarify the Data).
2.8. Depersonalization of Data — actions as a result of which it is impossible to determine, without the use of additional information, the belonging of Data to a specific User.
2.9. Recording of Data — actions aimed at entering User Data into a storage device.
2.10. Provision of Data — actions aimed at disclosing Data to a specific person or a specific circle of persons.
2.11. Dissemination of Data — any actions aimed at disclosing Data to an indefinite circle of persons (transfer of Data) or at familiarizing an unlimited circle of persons with the Data, including the publication of Data in the mass media, placement in information and telecommunication networks, or provision of access to Data in any other way.
2.12. Destruction of Data — any actions as a result of which Data is irreversibly destroyed with the impossibility of further restoration of the content of the Data in the Data information system and/or the material carriers of the Data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
– receive from the User reliable information and/or documents containing Data;
– in the event of the User's withdrawal of consent to the processing of Data, the Operator has the right to continue processing Data without the User's consent if there are legal grounds;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the relevant regulatory legal acts.
3.2. The Operator is obliged to:
– provide the User, upon their request, with information concerning the processing of their Data;
– organize the processing of Data in the manner established by the current legislation of the Russian Federation;
– respond to appeals and requests from Users and their legal representatives in accordance with the requirements of the legislation of the Russian Federation;
– publish or otherwise ensure unrestricted access to this Policy regarding the processing of Data;
– take legal, organizational and technical measures to protect Data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of Data, as well as from other unlawful actions in relation to Data;
– stop the transfer (dissemination, provision, access) of Data, stop processing and destroy Data in the manner and in the cases provided for by the legislation of the Russian Federation;
– fulfill other obligations provided for by the legislation of the Russian Federation.

4. Basic Rights and Obligations of Users

4.1. The User has the right to:
– receive information concerning the processing of their Data, except in cases provided for by the legislation of the Russian Federation. Information is provided to the User by the Operator in an accessible form, and it must not contain Data relating to other Users, except in cases where there are legal grounds for disclosing such Data. The list of information and the procedure for obtaining it are established by the legislation of the Russian Federation;
– demand from the Operator the clarification of their Data, its blocking or destruction if the Data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
– put forward a condition of prior consent when processing Data for the purposes of promoting goods, works and services on the market;
– withdraw consent to the processing of Data;
– appeal to the authorized body or in court against unlawful actions or inaction of the Operator when processing their Data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
– provide the Operator with reliable information about themselves;
– notify the Operator of the clarification (updating, modification) of their Data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another User without the latter's consent, bear responsibility in accordance with the legislation of the Russian Federation.

5. User Data and Its Processing

5.1. The Operator processes the following User Data:
5.1.1. Name;
5.1.2. Email address;
5.2. The above data are hereinafter referred to in the text of the Policy by the general concept of Data.
5.3. The Operator does not process special categories of Data relating to racial or national affiliation, political views, religious or philosophical beliefs, or intimate life.
5.4. The Operator processes Data in the following ways:
– Automated processing of Data with or without transmission of the received information via information and telecommunication networks;
5.5. Data processing is carried out by the Operator subject to obtaining the User's consent (hereinafter referred to as "Consent"), except for cases established by the legislation of the Russian Federation when Data processing may be carried out without such Consent.
5.6. The User makes the decision to provide their Data and gives their Consent freely, by their own will and in their own interest.
5.7. Transfer of Data to third parties may be carried out if there is and on the basis of a data processing agreement, as well as the User's consent, unless otherwise provided by the legislation of the Russian Federation. The person processing Data on behalf of the Operator is obliged to comply with the principles and rules of Data processing provided for by the legislation of the Russian Federation and this Policy.
5.8. The Website collects and processes depersonalized data about visitors (including "cookie" files) using Internet statistics services, provided that this is permitted in the User's browser settings (cookie saving and JavaScript technology are enabled).
5.9. The User has the right to contact the Operator on any issues related to the processing of Data, including to exercise the rights granted to the User, by email at wujieyu@lcaiwu.com. The request must specify data allowing identification of the person who applied; this information will be used exclusively to exercise the User's rights in relation to the processing of their Data. If a User's representative contacts the Operator, the latter must provide the Operator with a document confirming the authority to represent the User's interests (a power of attorney or other documents confirming the authority).

6. Principles of Data Processing

6.1. Data processing is carried out on a lawful and fair basis.
6.2. Data processing is limited to the achievement of specific, predetermined and lawful purposes. Data processing incompatible with the purposes of Data collection is not allowed.
6.3. Combining databases containing Data whose processing is carried out for purposes incompatible with each other is not allowed.
6.4. Only Data that meets the purposes of their processing is subject to processing.
6.5. The content and volume of the processed Data correspond to the stated purposes of processing. Redundancy of the processed Data in relation to the stated purposes of their processing is not allowed.
6.6. When processing Data, the accuracy of the Data, its sufficiency, and, where necessary, its relevance to the purposes of Data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Storage of Data is carried out in a form that allows determining the User, no longer than required by the purposes of Data processing, unless the storage period of Data is established by federal law or a contract to which the User is a party, a beneficiary or a guarantor. The processed Data is destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of Data Processing

7.1. Purpose of processing User Data:
– informing the User by sending emails;
– conclusion, performance and termination of civil law contracts;
– providing the User with access to services, information and/or materials contained on the Website;

8. Legal Grounds for Data Processing

8.1. The legal grounds for Data processing by the Operator are:
• The Constitution of the Russian Federation;
• The Civil Code of the Russian Federation;
• Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection";
• Federal Law No. 126-FZ "On Communications";
• Federal Law No. 152-FZ "On Personal Data";
• Decree of the President of the Russian Federation No. 188 of March 6, 1997 "On Approval of the List of Confidential Information";
• Resolution of the Government of the Russian Federation No. 1119 of November 1, 2012 "On Approval of Requirements for the Protection of Personal Data during Their Processing in Personal Data Information Systems";
• Order of Roskomnadzor No. 996 of September 5, 2013 "On Approval of Requirements and Methods for Depersonalization of Data";
• Order of the Federal Service for Technical and Export Control of Russia No. 21 of February 18, 2013 "On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data during Their Processing in Personal Data Information Systems";
• The Operator's constituent documents;
• The User's consent to the processing of Data;
• Other regulatory acts providing for cases when consent to the processing of Data is not required by law.
8.2. The Operator processes User Data only if it is filled in and/or sent by the User independently through special forms located on the website https://молния.москва, https://молния.москва/ch, https://молния.москва/eng or sent to the Operator by email. By filling in the relevant forms and/or sending their Data to the Operator, the User expresses their consent to this Policy.
8.3. The Data subject independently makes the decision to provide their Data and gives consent freely, by their own will and in their own interest.

9. Conditions of Data Processing

9.1. Data processing is carried out with the User's consent to the processing of their Data.
9.2. Data processing is necessary for the performance of a contract to which the User is a party, a beneficiary or a guarantor, as well as for the conclusion of a contract at the User's initiative or a contract under which the User will be a beneficiary or a guarantor.
9.3. Data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the User are not violated.

10. Procedure for Collection, Storage, Transfer and Other Types of Data Processing

The security of Data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of Data protection.
10.1. The Operator ensures the safety of Data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. User Data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or if the User has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract.
10.3. In case of detection of inaccuracies in the Data, the User can update them independently by sending a notification to the Operator's email address wujieyu@lcaiwu.com with the note "Data Update".
10.4. The period of Data processing is determined by the achievement of the purposes for which the Data was collected, unless another period is provided for by a contract or current legislation. The User may at any time withdraw their consent to the processing of Data by sending a notification to the Operator via email to the Operator's email address wujieyu@lcaiwu.com with the note "Withdrawal of Consent to Data Processing".
10.5. The Operator stores Data in a form that allows determining the User, no longer than required by the purposes of Data processing, unless the storage period of Data is established by federal law or a contract to which the User is a party, a beneficiary or a guarantor.
10.6. The condition for terminating Data processing may be the achievement of the purposes of Data processing, the expiration of the User's consent, or the User's withdrawal of consent, as well as the detection of unlawful processing of Data.

11. List of Actions Performed by the Operator with the Received Data

11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of Data.
11.2. The Operator carries out automated processing of Data with the receipt and/or transmission of the received information via information and telecommunication networks.

12. Confidentiality of Data

12.1. The Operator and other persons who have gained access to the Data are obliged not to disclose to third parties or disseminate Data without the User's consent, unless otherwise provided by the legislation of the Russian Federation.

13. Final Provisions

13.1. This document will reflect any changes to the Operator's Data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
13.2. The current version of the Policy is freely available on the Internet at

https://молния.москва/privacypolicy_ru, https://молния.москва/privacypolicy_ch, https://молния.москва/privacypolicy_eng