Personal data processing policy
Edition of
This is an English translation provided for convenience. In case of any discrepancy, the Russian version of this document prevails.
IWhy this Policy has been developed and adopted:
This Personal Data Privacy Policy (hereinafter, the “Policy”) has been developed in pursuance of the requirements of clause 2, part 1, Article 18.1 of Federal Law No. 152-FZ “On Personal Data” of 27.07.2006 (hereinafter, the “Personal Data Law”).
The terms and definitions set out in Appendix No. 1 apply in this Policy.
The Policy is a public document and, in pursuance of the requirements of the Personal Data Law, is published in open access on the Internet information and telecommunications network on the Sites (the list of the Company’s current sites is set out in Appendix No. 2, hereinafter, the “Sites”).
IIScope of this Policy:
All information that you provide to us on our Sites (the list of the Company’s current sites is set out in Appendix No. 2), as well as by the telephone numbers and e-mail addresses indicated on the Company’s Sites, is stored, protected and processed by us in accordance with this Policy.
This Privacy Policy applies only to the Sites listed in Appendix No. 2 and does not control and is not responsible for third-party sites that you may access via links available on the Sites listed in Appendix No. 2.
IIIPurpose of this Policy:
We respect personal privacy and value our customers; therefore, when you use our sites, we store, protect and process your Personal Information in strict compliance with Russian legislation.
In this regard, this Policy has been adopted to explain the following:
1. Why and how we process your Personal Information;
2. What tools you can use to reduce the amount of Personal Information about you collected by the Company;
3. What your rights and obligations are in connection with the processing of Personal Information;
4. What the Company’s obligations are under this Policy.
IVWho processes your Personal Information:
The Company (the Operator): Individual Entrepreneur Alexey Petrovich Chugunov (TIN (INN): 744811962106, OGRN: 315745600038722).
VWhat Personal Information the Company processes:
The Company may collect the following categories of Personal Information about you while you use our sites:
1. Personal Information that may be provided only by you: first name, last name, patronymic, telephone number, e-mail (address).
2. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), browser identifier data, information about hardware and software, Wi-Fi network data), geolocation information, as well as the date and time of access to the sites.
3. Information about your activity on our Sites (for example, the history of search queries for the company’s services, the history of pages viewed on our Sites).
4. Other information about you that is necessary for processing in accordance with the terms governing the use of specific Sites, “Yandex.Metrica”.
VIWhat purposes we pursue in processing your Personal Information:
The content and scope of the personal data processed correspond to the processing purposes stated below. We do not collect data for the purpose of compiling a user “profile” to an extent that could significantly affect your rights and freedoms. Nor do we purposefully collect sensitive personal information (such as racial origin, political opinions, health information). We are not entitled to process your Personal Information without sufficient legal grounds.
Accordingly, the Company processes your Personal Information only for the following purposes:
Purpose of processing the personal information of the Site user | Scope and list of personal data that may be processed | Category of personal data subject | Methods of processing personal data | Periods of processing and storage of personal information |
|---|---|---|---|---|
Promotion of works and services on the market on the Internet information and telecommunications network, including providing users with access to the Site and improving the usability of the Site (displaying the most relevant search results and providing more personalized information, providing the User with access to the Site’s resources on the Internet information and telecommunications network) | 1. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), | User of the Site on the Internet information and telecommunications network | Automated; without transfer over the internal network of the legal entity; with transfer over the Internet | Until the purpose for which it was collected is achieved or one of the following events occurs: withdrawal of consent to the processing of personal data or termination of the activities of the legal entity (operator) |
To ensure the protection and security of the User on the Site, including to prevent fraud, computer attacks and other abuse, as well as to investigate the above-mentioned cases | 1. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), | User of the Site on the Internet information and telecommunications network | Automated; without transfer over the internal network of the legal entity; with transfer over the Internet | Until the purpose for which it was collected is achieved or one of the following events occurs: withdrawal of consent to the processing of personal data or termination of the activities of the legal entity (operator) |
Review and recording of information, in particular questions, suggestions, complaints, claims, requests, feedback and other information received from the User by any of the following means: | 1. First name, last name, patronymic. 2. telephone number. 3. e-mail (address). 4. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), browser identifier data, information about hardware and software, Wi-Fi network data), geolocation information, as well as the date and time of access to the Site. 5. Information about your activity on the Site (for example, search query history). 6. Other personal data specified in the request. | User of the Site on the Internet information and telecommunications network | Automated; without transfer over the internal network of the legal entity; with transfer over the Internet | Until the purpose for which it was collected is achieved or one of the following events occurs: withdrawal of consent to the processing of personal data or termination of the activities of the legal entity (operator) |
To provide you with effective customer and technical support in the event of problems related to the use of the Site, telephony or online chat, and to improve the quality of operation and service of the Sites and telephony operators | 1. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), | User of the Site on the Internet information and telecommunications network | Automated; without transfer over the internal network of the legal entity; with transfer over the Internet | Until the purpose for which it was collected is achieved or one of the following events occurs: withdrawal of consent to the processing of personal data or termination of the activities of the legal entity (operator) |
VIIHow we protect your Personal Information:
In most cases, your Personal Information is processed automatically without access to it by any of the Company’s employees.
Where access to your Personal Information must be granted to Company employees who need it to perform their tasks, such access is granted strictly in accordance with the purposes specified in Section VI of this Policy.
To protect data and ensure its confidentiality, all Company employees comply with internal rules and procedures regarding the processing of Personal Information and follow all technical and organizational security measures in place to protect your Personal Information.
The Company has implemented sufficient technical and organizational measures to protect Personal Information against unauthorized, accidental or unlawful disclosure or access, loss, alteration, misuse, destruction, and other unlawful forms of processing. These security measures have been implemented taking into account the state of the art, the cost of their implementation, and the risks associated with the processing and the nature of the Personal Information.
VIIITo whom we may transfer your Personal Information:
For the purposes of the Company’s performance of its obligations under the user agreement and to improve the usability of the Site for you (solely for the purposes set out in this paragraph), your Personal Information may be transferred, with your consent, to third parties, including YANDEX LLC, which provides the Yandex.Metrica web analytics service.
To law enforcement authorities for the purpose of protecting the rights and legitimate interests of the Company in cases where you disrupt the functional operation of the Sites by gaining unlawful access.
IXWhat is meant by processing of Personal Information, and where your Personal Information is stored and processed:
Processing of your Personal Information includes, among other things: collection; recording; systematization; accumulation; storage; clarification (updating, modification); retrieval; use; transfer (dissemination, provision, access); depersonalization; blocking; deletion; destruction.
The Operator does not carry out cross-border transfers of personal data. The database containing your personal information is located in the territory of the Russian Federation.
XHow long we store your Personal Information:
We will store your Personal Information for as long as necessary to achieve the purpose for which it was collected or to comply with the requirements of laws and regulations.
If you wish any of your Personal Information to be deleted from our database, you may submit a written request to the Company (at the address specified in Section IV).
Your Personal Information being processed is subject to destruction or depersonalization upon achievement of the processing purposes or if the need to achieve those purposes ceases, unless otherwise provided by federal law.
XIYour rights and the procedure for giving your consent to this Policy:
You have the right to:
1. access the information that our Company stores about you;
2. demand the deletion of your Personal Information or part of it, and withdraw your consent to the processing of your personal information (the procedure is set out below);
3. if you believe that any information our Company stores about you is incorrect or incomplete, you may notify us and the Company will correct your Personal Information itself.
In cases provided for by Russian legislation, you may also have other rights not listed above.
The Company may use the Personal Information you have provided only where you agree to such provision and to this Policy of the Company.
Your consent may be obtained in two ways:
1. Orally, for example, when communicating by telephone or via e-mail addresses.
2. Electronically, by continuing to use the Site and ticking a “checkbox” or clicking a button of similar meaning on the relevant Site of the Company, for example, the “Got it” button (the text of your Consent is set out in Appendix No. 3).
XIIProcedure for withdrawing consent to processing and deleting your personal information:
To withdraw your consent to the processing of personal information and to have your personal information deleted, please contact us by the means listed below:
— in writing to the relevant Individual Entrepreneur A. P. Chugunov;
— by sending a message to the e-mail address indicated on the Sites (info@born2battle.net).
When sending a written request, you must specify: information confirming the fact that Individual Entrepreneur A. P. Chugunov processes your Personal Information, so that we can identify you, satisfy your withdrawal of consent to the processing of personal information and delete all information.
XIIIADDITIONAL TERMS
We do not verify the accuracy of the Personal Information you provide; in our activities, we proceed on the basis that you provide accurate and sufficient personal data and keep this information up to date.
You personally bear full responsibility for the consequences of providing inaccurate or invalid personal data.
We may amend this Policy at our discretion, including, but not limited to, where the relevant amendments are related to changes in legislation, as well as where the relevant amendments are related to changes in the operation of the Sites.
We undertake not to make material changes, or impose additional burdens or restrictions on your rights established by this Policy, without notifying you. In such a case, you will additionally be informed of such changes by means of an appropriate notice on the Sites (for example, via a pop-up window or banner) before such changes take effect, or such notice may be sent to you through other communication channels (for example, by e-mail, if you have provided us with your contact details).
The new version of the Policy is published on the Internet information and telecommunications network on each of the Sites (see Appendix No. 2 to the Policy).
All suggestions or questions regarding this Policy in respect of the processing of personal data should be submitted via the feedback form on the website https://born2battle.net or by the telephone number and e-mail address indicated on the Sites.
Appendix No. 1 to the Personal Data Privacy Policy of Individual Entrepreneur A. P. Chugunov
Terms and Definitions
1. Automated processing of personal data means the processing of personal data by means of computer equipment;
2. Biometric personal data means information that characterizes the physiological and biological features of a person on the basis of which his or her identity can be established;
3. Blocking of personal data means the temporary suspension of the processing of personal data (except where the processing is necessary to clarify the personal data);
4. Personal data information system means the totality of personal data contained in databases and the information technologies and technical means ensuring their processing;
5. Depersonalization of personal data means actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belong to a specific personal data Subject;
6. Operator means a person who, independently or jointly with other persons, organizes and (or) carries out the processing of personal data.
7. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
8. Personal data/Personal Information:
8.1any information relating directly or indirectly to an identified or identifiable personal data Subject (User) that such Subject provides about himself or herself in the course of using the Sites and their services, including the User’s personal data (information mandatory for the provision of the Services is specially marked); other information is provided by the User at his or her discretion;
8.2data that is automatically transmitted to the Site’s services in the course of their use by means of software installed on the User’s device, including the IP address, cookie data, information about the User’s browser (or other program used to access the services), technical characteristics of the hardware and software used by the User, the date and time of access to the services, the addresses of the requested pages and other similar information;
8.3other information about the User, the processing of which is provided for by the Site Use Agreement or determined by applicable legislation.
9. Provision of personal data means actions aimed at disclosing personal data to a certain person or a certain group of persons;
10. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including the publication of personal data in the mass media, posting on information and telecommunications networks, or providing access to personal data in any other way;
11. Personal data subject (Subject/User) means the natural person to whom the relevant personal data relate, a visitor to the Company’s Site.
12. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign natural person or a foreign legal entity;
13. Destruction of personal data means any actions as a result of which personal data are irreversibly destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and (or) as a result of which the tangible media of personal data are destroyed.
14. Cookies are small pieces of data sent by a web server that are received and processed by the device you use to access the Sites. Cookies store and send back to the Sites information that helps you work with the Sites and allows us to remember your preferences over time, for example, browser settings and the language in which you prefer to view the Site, which will be useful on your next visit to the Operator’s Sites, or to recognize your account. Cookies can be disabled in your browser settings. By continuing to use the Site without changing the settings, you consent to the use of your cookies.
15. IP address means, for the purposes of this Privacy Policy, the unique network address of a node in a computer network built on the IP protocol.
Appendix No. 2 to the Personal Data Privacy Policy of Individual Entrepreneur A. P. Chugunov
Sites and services through which the Operator may collect personal data in the course of their use by Subjects.
1. Corporate website of B2BT LLC — https://born2battle.net
hereinafter, collectively and/or individually (as applicable to the relevant site), the “Site”.
Appendix No. 3 to the Personal Data Privacy Policy of Individual Entrepreneur A. P. Chugunov
Consent to the Processing of Personal Data
By using the Site of Individual Entrepreneur A. P. Chugunov on the Internet information and telecommunications network, contacting Individual Entrepreneur A. P. Chugunov using the contact details indicated on the Site of Individual Entrepreneur A. P. Chugunov, or filling in feedback forms on the Site of Individual Entrepreneur A. P. Chugunov, I provide my personal data and give my consent to the processing of my personal data by the Operator, Individual Entrepreneur A. P. Chugunov, TIN (INN):, OGRN:, address:, in accordance with the Personal Data Privacy Policy of Individual Entrepreneur A. P. Chugunov, as well as by companies providing services for the proper operation and maintenance of the Site of Individual Entrepreneur A. P. Chugunov, for the following purposes:
Purpose of processing the personal information of the Site user | Scope and list of personal data that may be processed | Methods of processing personal data | Periods of processing and storage of personal information |
|---|---|---|---|
Promotion of works and services on the market on the Internet information and telecommunications network, including providing users with access to the Site and improving the usability of the Site (displaying the most relevant search results and providing more personalized information, providing the User with access to the Site’s resources on the Internet information and telecommunications network) | 1. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), | Automated; without transfer over the internal network of the legal entity; with transfer over the Internet | Until the purpose for which it was collected is achieved or one of the following events occurs: withdrawal of consent to the processing of personal data or termination of the activities of the legal entity (operator) |
To ensure the protection and security of the User on the Site, including to prevent fraud, computer attacks and other abuse, as well as to investigate the above-mentioned cases | 1. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), | Automated; without transfer over the internal network of the legal entity; with transfer over the Internet | Until the purpose for which it was collected is achieved or one of the following events occurs: withdrawal of consent to the processing of personal data or termination of the activities of the legal entity (operator) |
Review and recording of information, in particular questions, suggestions, complaints, claims, requests, feedback and other information received from the User by any of the following means: c. the feedback form posted on the Site. Including establishing feedback with the User and identifying the User, including sending responses to requests concerning the use of the Site. | 1. First name, last name, patronymic. 2. telephone number. 3. e-mail (address). 4. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), browser identifier data, information about hardware and software, Wi-Fi network data), geolocation information, as well as the date and time of access to the Site. 5. Information about your activity on the Site (for example, search query history). 6. Other personal data specified in the request. | Automated; without transfer over the internal network of the legal entity; with transfer over the Internet | Until the purpose for which it was collected is achieved or one of the following events occurs: withdrawal of consent to the processing of personal data or termination of the activities of the legal entity (operator) |
To provide you with effective customer and technical support in the event of problems related to the use of the Site or telephony, and to improve the quality of operation and service of the Sites and telephony operators | 1. Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags), 3. First name, last name. 4. telephone number. | Automated; without transfer over the internal network of the legal entity; with transfer over the Internet | Until the purpose for which it was collected is achieved or one of the following events occurs: withdrawal of consent to the processing of personal data or termination of the activities of the legal entity (operator) |
I give my consent to Individual Entrepreneur A. P. Chugunov, including persons acting on his behalf, to carry out automated processing, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), depersonalization, blocking, deletion and destruction, of the following personal data:
Name (nickname)
E-mail (address)
Contents of cookies
Information about my activity on the Site
Electronic data (HTTP headers, IP address, cookies, web beacons (pixel tags)
Browser identifier data, information about hardware and software, Wi-Fi network data, geolocation information, as well as the date and time of my access to the Site
Other personal data specified in my request to the Operator
Other information about me that is necessary for processing in accordance with the terms governing the use of the Site, “Yandex.Metrica”.
My consent is valid until the date of its withdrawal by sending a written application to Individual Entrepreneur A. P. Chugunov in accordance with the Personal Data Privacy Policy of Individual Entrepreneur A. P. Chugunov.
Data Processing in Connection with Payments
When a Born2Battle PRO subscription is taken out or a clan treasury is topped up, the Operator processes: the account identifier, the e-mail address (for sending the fiscal receipt), payment information (amount, date, type, status, the payment identifier assigned by the payment service), information about the clan for which the payment is made, and the comment on the treasury top-up.
The User enters bank card details on the page of the payment service of NCO YooMoney LLC (YooKassa); the Operator neither receives nor stores them. For auto-renewal, the Operator stores only the identifier of the saved payment method issued by the payment service and its short description (card type and the last four digits).
Purposes of processing: performance of the contract (the subscription offer), sending fiscal receipts (Federal Law No. 54-FZ), accounting and tax records, refunds, and handling of requests. Payment information is stored for the period established by accounting legislation [at least 5 years].
Transfer of data: to the YooKassa payment service and to the fiscal data operator, to the extent necessary to process the payment and generate the receipt.
Change history
- Edition 4
- Edition 3
- Edition 2
- Edition 1