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Privacy Policy

Updated at 2022-12 -18







1 Controller


Company Name:

PE Abuseva Antonina Vladimirovna

State Registration Number and Date:

278.1274209, 2022-11-03




Ajemyan Street 18, ap45

City/Postal Code:






2 The purpose of processing personal data


Personal data is processed for purposes related to maintaining, managing and developing the customer relationship, offering, supplying and developing services as well as invoicing. Personal data are also processed for the purposes necessitated by resolving any possible complaints and other claims.

Furthermore, personal data are processed in communications directed at customers as well as marketing, in conjunction to which the data are also processed for purposes pertaining to direct marketing and electronic direct marketing.

Customers have the right to refuse direct marketing targeted at them.

The controller processes personal data directly and also utilizes subcontractors working on its behalf in the processing activities.



3 Data content of the file (categories of personal data processed)


As a general rule, the file contains the following personal data on all data subjects:

A.    basic information and contact information for the person: first name, last name, address, telephone number, e-mail address;

B.    information related to the person’s company or other organization and the person’s position or title in the company or organization in question;

C.    direct marketing permissions and bans for the person.


 Regular sources of information

Personal data are collected from the data subjects themselves.

In addition to this, personal data are collected within the framework of the applicable legislation from generally available sources that pertain to fulfilling the relationship between the controller and data subject, and that the controller can use to perform its duties related to maintaining customer relationships.


4 Storage period of personal data

Personal data collected in the file are stored only for as long and to the extent that is necessary in relation to the original or a compatible purpose for which the personal data has been collected.

The need to retain personal data is assessed every five years, and, in any case, data concerning a data subject are removed from the file 10 years after the end of the customer relationship between the data subject in question and the controller has ended, and the obligations and measures related to the customer relationship have been fulfilled. For example, accounting records are kept for five years after the end of a financial period.

The controller shall regularly assess the necessity of storing the data in accordance with its internal code of conduct. Furthermore, the controller shall by all reasonable measures ensure that any personal data that are inaccurate, erroneous or contain obsolete information in terms of the purposes of processing the data are deleted or corrected without delay.


5 Recipients of personal data (recipient groups) and regular data disclosures

Personal data will not be disclosed to third parties. The only exceptions are cases where we send a product to the manufacturer for warranty repair and filing complaints with a delivery service provider for damaged products or other issues with delivery. In these cases we may need to give the customer's information to the manufacturer or delivery service provider.


 6 Transferring data outside the RA

Personal data contained in the file will not be transferred outside the RA.


7 Register protection principles

Materials containing personal data are stored in locked spaces that can only be accessed by the appointed persons with task-based authorisation.

The database containing personal data is on a server which is stored in a locked space that can only be accessed by the appointed persons with task-based authorisation. The server is protected with the appropriate firewall and technical safeguards.

The databases and systems can only be accessed with separately provided personal user IDs and passwords. The controller has restricted access rights and authorisations to information systems and other storage platforms so that the data can only be viewed and processed by persons who are required to do so to ensure the lawful processing of the data. Furthermore, the database and system interactions are registered in the log data of the controller's IT system.

The controller's employees and other persons have undertaken to observe secrecy and keep secret any information they may gain in the context of processing personal data.

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