PRIVACY POLICY

This Privacy Policy has been developed by Limited Liability Company “PRODUCTION 54” (INN 7802885760, OGRN 1207800152185, 194100, Saint Petersburg, Aleksandra Matrosova St., Building 4, Block 2, Letter L, Premises 3-N, Office 42, phone: +7 (931) 971-00-54) (hereinafter — the “Company,” OOO “PRODUCTION 54”) in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data,” for the purpose of ensuring the protection of the rights and freedoms of individuals when their personal data is processed, including the protection of the rights to privacy, personal, and family confidentiality.

This Privacy Policy applies to all personal data that the Company processes. For the purposes of this Privacy Policy, the Company also administers the Website.

Use of the services of the website https://fiftyfourms.com/ (hereinafter — the “Website”) constitutes the User’s unconditional consent to this Policy and to the terms for processing their personal information set forth herein. If the User does not agree with these terms, they must refrain from using the services.

1. Terms.

1.1. Personal data is any information relating directly or indirectly to a specific or identifiable natural person (personal data subject). Such information may include, in particular: full name, year, month, date, and place of birth, address, information about family, social or property status, information about education, profession, income, telephone number, as well as other information that, taken together, allows for the identification of the personal data subject.

1.2. Processing of Personal Data refers to any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

1.3. Personal Data Subject refers to a natural person whose personal data is processed.

1.4. Operator refers to a person who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and who determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data. For the purposes of this Policy, the Company, when processing personal data, acts as the Operator unless otherwise specified in the Policy.

1.5. Processor refers to any person who, under an agreement with the Operator, processes personal data on behalf of the Operator and/or in the Operator’s interests when processing personal data. The Operator is liable to the personal data subject for the actions or omissions of the Processor. The Processor is liable to the Operator.

1.6. Other terms used in this Policy shall be interpreted in accordance with the meanings established by the applicable laws of the Russian Federation, unless this Policy expressly provides otherwise.

2. General provisions.

2.1. A User of the Website is any person who has accessed the Website, regardless of whether that person has created an account on the Website.

2.2. For the purposes of this Privacy Policy, the User’s personal information includes:

2.2.1. Personal information that the User provides about themselves when registering (creating an account) or while using the Services, including the User’s personal data. Information that is required in order for the Services to function is specifically marked as mandatory.

2.2.2. Data automatically transmitted to the Website’s services during their use by means of the software installed on the User’s device, including the IP address, cookie data, information about the User’s browser (or other software used to access the services), technical specifications of the User’s hardware and software, date and time of access to the services, geolocation, addresses of requested pages, and other similar information.

2.2.3. This Privacy Policy applies only to the website https://fiftyfourms.com/. The website https://fiftyfourms.com/ does not control and is not responsible for third-party websites that the User may access via links available on https://fiftyfourms.com/. Users who follow links to other websites are advised to review the personal data processing policies posted on those websites.

3. Purposes of the users’ personal data processing.

3.1. The Website collects and stores only the personal information that is necessary for the provision of services or for the performance of agreements and contracts with the User, except in cases where applicable law requires mandatory retention of personal information for a period established by law.

If the Website receives a notification from the User withdrawing their consent to the processing of personal data, the Website shall cease processing the User’s personal data within a period not exceeding 30 calendar days from the date of receipt of such notification.

A notification withdrawing consent to the processing of personal data shall be sent to the following email address: [email protected], with the subject line “Withdrawal of Consent to Personal Data Processing”.

3.2. The Website processes the User’s personal information for the following purposes:

3.2.1. Ensuring compliance with the Constitution of the Russian Federation, Federal Law No. 152-FZ “On Personal Data,” subordinate regulations, other laws of the Russian Federation that define cases and conditions of personal data processing, as well as the guidelines and methodological documents of the Government of the Russian Federation, the Ministry of Digital Development, Communications and Mass Media of Russia, Roskomnadzor, and other regulatory legal acts of the Russian Federation.

3.2.2. Performing the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation, in accordance with federal laws and the Operator’s internal regulations governing relations connected with the Operator’s activities.

3.2.3. Identifying the User registered on the Website for the conclusion, performance, and termination of civil-law contracts with individuals, including contracts concluded remotely via the Website.

3.2.4. Providing the User with access to personalized resources of the Website.

3.2.5. Establishing feedback with the User, including sending notifications and inquiries related to the use of the Website, the provision of services, as well as processing the User’s requests and submissions.

3.2.6. Analyzing visits to the Operator’s Website using web analytics services to improve the quality of the Website and its content.

The Website collects users’ IP addresses for the purposes of traffic analysis and cybersecurity threat prevention. Google Analytics is used to analyze visitor behavior. IP addresses are anonymized, and data is not transferred to third parties. The User may disable cookie collection in their browser settings.

3.2.7. Sending marketing and informational messages about new products and services, special offers, promotions, and various events via postal mailings, email newsletters, news digests, SMS messages, push notifications, phone calls, or through messaging services, including WhatsApp.

3.2.8. Providing the User with effective customer and technical support in case of issues related to using the Website.

3.2.9. Conducting advertising activities with the User’s consent.

4. Terms and conditions for processing users' personal information and transferring it to third parties.

4.1. Personal data is processed with the consent of the personal data subjects, and also without such consent in cases provided for by the legislation of the Russian Federation.

4.2. The Operator carries out both automated and non-automated processing of personal data.

4.3. Access to personal data processing is granted to OOO “PRODUCTION 54” and to employees of the Operator whose job duties include the processing of personal data.

4.4. The Website stores Users’ personal information in accordance with the internal regulations of the respective services.

4.5. The User’s personal information remains confidential, except in cases where the User voluntarily provides information about themselves for public access to an unlimited number of persons. When using certain services, the User agrees that some of their personal information becomes publicly accessible.

4.6. The Website may transfer the User’s personal information to third parties in the following cases:

4.6.1. The User has consented to such actions.

4.6.2. The transfer is necessary for the User’s use of a particular service or for the performance of a specific agreement or contract with the User.

4.6.3. The transfer is required under Russian or other applicable legislation as part of a legally established procedure.

4.6.4. The transfer of personal data to investigative authorities, the Federal Tax Service, the Social Fund of Russia, and other authorized executive bodies and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.

4.6.5. In the event of the sale of the Website, all obligations to comply with this Policy with respect to the received personal information shall pass to the purchaser.

4.7. Conditions for processing users’ personal information via messaging applications, including WhatsApp:

The first message sent to the personal data subject shall include a request for informed consent to receive messages. The personal data subject may accept or decline.

The Company undertakes to use the data only within the scope of the consent and in compliance with personal data protection legislation.

The personal data subject may unsubscribe at any time by sending the word “Unsubscribe” in the messenger or by sending an email to [email protected] with the subject line “Unsubscribe from Mailing.”

After receiving the unsubscribe request, the Company will stop sending messages within a reasonable time.

4.8. The User’s personal data is processed for an unlimited period of time by the following methods: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data, including within personal data information systems, with or without the use of automation tools.

The processing of Users’ personal data is carried out in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”.

4.9. The Company does not transfer data to third parties and applies technical and organizational security measures to protect the personal information of the personal data subject from unlawful or accidental access, destruction, alteration, blocking, copying, or dissemination, including message encryption and restricted employee access.

4.10. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer is intended provides reliable protection of the rights of personal data subjects.

4.11. Cross-border transfer of personal data to foreign states that do not meet the above requirements may be carried out only if the personal data subject has provided written consent for the cross-border transfer of their personal data and/or if such transfer is necessary for the performance of a contract to which the personal data subject is a party.

4.12. Postal organizations and courier services delivering goods purchased by Users may request personal data from the User necessary for User identification (including passport details). The relationships concerning the provision and processing of such personal data arise directly between the Users and the entities requesting the data.

5. Responsibilities of the Parties.

5.1. The User shall:

5.1.1. Provide the personal data required to use the Website, namely:

Last name, first name, patronymic (middle name);

Email address;

Contact phone number.

5.1.2. Update and supplement the provided personal data in the event of any changes.

5.2. The Website Administration shall:

5.2.1. Use the received information solely for the purposes specified in this Privacy Policy.

5.2.2. Ensure the confidentiality of the information, not disclose it without the User’s prior written consent, and not sell, exchange, publish, or otherwise disclose the User’s personal data, except as provided in this Privacy Policy.

5.2.3. Take legal, organizational, and technical measures to protect the User’s personal data during processing from unauthorized, unlawful, or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions involving personal data, in accordance with the standard procedures used in business practice for protecting such information.

5.2.4. Block the personal data relating to the relevant User upon the User’s request or the request of their legal representative, or upon the request of the authorized personal data protection authority, for the duration of the verification in cases where inaccurate personal data or unlawful actions are detected.

5.2.5. Delete the personal data upon receiving the corresponding request from the User, their legal representative, or the authorized personal data protection authority, or in cases where the personal data is found to be inaccurate.

6. Responsibilities of the Parties.

6.1. The Operator who fails to fulfill its obligations shall be liable for losses incurred by the User due to unlawful use of personal data, in accordance with the legislation of the Russian Federation.

6.2. In the event of loss or disclosure of confidential information, the Operator shall not be liable if such confidential information:

6.2.1. Became publicly available prior to its loss or disclosure.

6.2.2. Was received from a third party before being obtained by the Operator.

6.2.3. Was disclosed with the User’s consent.

6.3. The User is solely responsible for any consequences resulting from providing inaccurate and/or incomplete personal data.

7. Dispute Resolution.

7.1. Before filing a lawsuit regarding disputes arising from the relationship between the Website User and the Operator, the submission of a claim (pre-trial complaint) is mandatory.

7.2. The recipient of the claim shall, within 30 calendar days from the date of receiving the claim, provide the claimant with a written notice of the results of the claim’s review.

7.3. If no agreement is reached, the dispute shall be submitted to a court for consideration in accordance with the applicable legislation of the Russian Federation.

7.4. This Privacy Policy and the relations between the User and the Operator are governed by the applicable legislation of the Russian Federation.

8. Additional Provisions.

8.1. This Privacy Policy constitutes an internal regulatory act of OOO «PRODUCTION 54».

8.2. The current version of the Privacy Policy is published at: https://fiftyfourms.com/policy

8.2. The Operator is entitled to make amendments to this Privacy Policy without obtaining the User’s consent.

8.3. The new version of the Privacy Policy enters into force upon its publication on the Website, unless otherwise provided by the new version of the Privacy Policy.

8.4. Any suggestions or questions regarding this Privacy Policy shall be communicated to the Operator at the following address: [email protected]

8.5. The new version of the Privacy Policy enters into force upon its publication on the Website’s resources, unless otherwise provided by the new version of the Privacy Policy.