1. Quick overviewon data protection
The information below is intended to give you an overview of whathappens to your personal data when you visit this website. Personal data is anydata that can be used to personally identify you. For detailed information onthe subject of data protection, please refer to our Data Protection Statementset out below.
Data collection on this website
Who is responsible for the data collection on this website?
Data processing on this website is carried out by the website operator. Youcan find the contact details of the website operator in the section “Informationon controller” in this Data Protection Statement.
How do we collect your data?
Your data are collected, partly, when you provide them to us. Forexample, this can be data that you enter in a contact form.
Other data are collected by our IT systems automatically or followingyour consent you give when you visit the website. These are mainly technicaldata (e.g., Internet browser, operating system or time of the page visit). Thedata collection is carried out automatically from the moment you access thiswebsite.
What do we use your data for?
Some data are collected in order to ensure that the website is displayedcorrectly. Other data may be used to analyse your user behaviour.
What rights do you have in respect to your data?
You have the right at any time to obtain, free of charge, informationabout origin, destination and purpose of your personal data stored. You alsohave a right to request correction or deletion of these data. If you gave yourconsent to data processing, you may revoke this consent at any time for thefuture. Under certain conditions, you may request restriction of the processingof your personal data. You also have the right to lodge a complaint with therelevant supervisory authority.
In regards to this, as well as for any questions on the subject of dataprotection, you may contact us at any time.
Analysis tools and third-party tools
When you visit this website, your surfing behaviour may be analysed forstatistical purposes. This analysis is carried out mainly by so-called analysisprograms.
A detailed information on these analysis programs can be found in theData Protection Statement below.
2. Hosting andContent Delivery Networks (CDN)
This website is hosted by an external service provider (“host”). Thepersonal data collected on this website is stored on the host's servers. Thismay include, in particular, IP addresses, contact requests, meta data andcommunication data, contract data, contact data, names, data on websiteaccesses and other data generated via this website.
Deployment of host is carried out for the purpose of fulfillingcontracts with our potential and existing customers (Art. 6(1)(b) of GDPR) andin the interests of secure, fast and efficient provision of our online servicesthrough a professional provider (Art. (6)(1)(f) of GDPR).
Our host will only process your data to the extent necessary to fulfilits service obligations, and will follow our instructions in respect to thesedata.
We use the services of the following host:
· Heroku, Inc. Address: 415 Mission Street, Suite 300, San Francisco, CA 94105
· Mailgun Inc., 112 E Pecan St #1135, San Antonio, TX78205, USA.
· Webflow, Inc. 398 11th Street, 2nd Floor
San Francisco, CA 94103Contract on commissionedprocessing
In order to ensure that data are processed in compliance with the dataprotection legislation, we have concluded a data processing contract with ourhost.
3. General notesand mandatory information
As operator of this website, we take the protection of your personaldata very seriously. We treat your personal data confidentially and inaccordance with the statutory data protection regulations as well as this DataProtection Statement.
While you are using this website, personal data of various kinds arecollected. Personal data is any data that can be used to personally identifyyou. This Data Protection Statement explains what information we collect andhow we use it. It also explains how and for what purpose this is carried out.
We would like to point out that data transmission on the Internet (e.g.,email communication) can have security gaps. Complete protection of dataagainst any access by third parties is therefore not possible.
Information on controller
Controller for data processing on this website is
Potschta Rossii JSC
Telephone: 030-746 83 100
“Controller” means the natural or legal person which, alone or jointlywith others, determines the purposes and means of the processing of personaldata (e.g., names, email addresses etc.).
Unless a more specific storage period is indicated in this DataProtection Statement, your personal data will be stored by us until the purposeof data processing no longer applies. If you assert a justified request fordeletion or revoke your consent to data processing, your data will be deletedexcept the cases where we have other legitimate reasons for storing yourpersonal data (e.g., retention periods required in accordance with fiscal andcommercial law) – in such a case, the data will be deleted once these reasonsno longer apply.
Data protection officer as required by law
Our company designated a data protection officer:
Lawyer[Rechtsanwalt] Lev Lexow
Certified dataprotection officer [Zertifizierter Datenschutzbeauftragter (TÜV Rheinland)]
Lietzenburger Str. 94
Telephone: 030 290 45 45 1
Information on data transfer to the USA
Our website deploys, among others, tools provided by companies based inthe USA. Whenever these tools are active, your personal data may be transferredto the US servers to the respective company. We would like to point out thatthe USA is not a “safe third country” as defined by EU data protectionlegislation. US companies are obliged to disclose personal data to securityagencies without you as a data subject being able to take legal action againstthis. It can therefore not be ruled out that US authorities (e.g., intelligenceservices) process, evaluate and permanently store your data located on USservers for monitoring purposes. We have no influence on these processingactivities.
Revoking your consent to data processing
Many data processing operations require an explicit consent provided byyou. You may at any time revoke a consent that you provided. The legality ofthe data processing carried out prior to such revocation remains unaffected bythe revocation.
Right to object to data collection in specificcases as well as objecting to direct marketing purposes (Art. 21 GDPR)
IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 (1)(E) OR(F) OF GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONALDATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSOAPPLIES TO PROFILING BASED ON THESE PROVISIONS. THE INFORMATION ON WHICH LEGALBASIS THE DATA PROCESSING IS CARRIED OUT CAN BE FOUND IN THIS DATA PROTECTIONSTATEMENT. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESSWE CAN DEMONSTRATE THAT THERE ARE COMPELLING LEGITIMATE GROUNDS FOR THE DATAPROCESSING WHICH OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE DATAPROCESSING IS NECESSARY FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDINGLEGAL CLAIMS (OBJECTION UNDER ARTICLE 21(1) GDPR).
IF YOUR PERSONAL DATA ARE PROCESSED FOR THE PURPOSES OF DIRECTMARKETING, YOU HAVE THE RIGHT TO OBJECT TO SUCH PROCESSING OF YOUR PERSONALDATA AT ANY TIME; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO DIRECTMARKETING PURPOSES. IN THE CASE YOU OBJECT, YOUR PERSONAL DATA WILLSUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSES OF DIRECT MARKETING (OBJECTIONPURSUANT TO ART. 21(2) GDPR).
Complaint with a supervisory authority
In cases of infringement of the GDPR provisions, the data subjectconcerned has the right to lodge a complaint with a supervisory authority, inparticular in the EU Member State of its habitual residence, place of work orplace of the alleged infringement. This right to lodge a complaint is withoutprejudice to any other administrative or judicial remedy.
Right to data portability
In respect to the data that we process automatically on the basis ofyour consent or in performance of the contract, you have the right to havethese data handed over to you or to a third party in a conventional andmachine-readable format. If you request a direct transfer of these data to adifferent controller, this can be done only insofar as it is technicallyfeasible.
SSL or TLS encryption
For security reasons and in order to protect transfer of confidentialcontents such as orders or enquiries sent by you to us as the website operator,this site uses SSL or TLS encryption. You can recognise an encrypted connectionby the fact that the address line of the browser changes from"http://" to "https://" and a lock symbol appears in theaddress line of your browser.
If the SSL or TLS encryption is activated, the data you transfer to uscannot be read by third parties.
Information about personal data, deletion and correction
Within the scope of the applicable statutory provisions, you have theright to receive, free of charge, information about your personal data stored,their origin, recipients and the purpose of the data processing and, whereapplicable, you have the right to rectify or delete this data. In regards tothis, as well as for further questions on the subject of data protection, youmay contact us at any time.
Right to restriction of the data processing
You have the right to request the restriction of the processing of yourpersonal data. In regards to this, you may contact us at any time. The right torestriction of the data processing applies to the following cases:
• Whenever you contest theaccuracy of your personal data stored by us, we usually need time to verifythis. While your objection is being examined, you have the right to request therestriction of the processing of your personal data.
• If your personal data hasbeen processed unlawfully, you may request – instead of erasure of the data –the restriction of data processing.
• If we no longer need yourpersonal data but you need it to exercise, defend or assert legal claims, youhave the right to request – instead of erasure of the data – the restriction ofthe processing of your personal data.
• If you have filed anobjection pursuant to Art. (21)(1) GDPR, then your interests and our interestsneed to be weighed up against each other. As long as it has not beendetermined, whose interests outweigh, you have the right to request therestriction of the processing of your personal data.
• If you have restrictedthe processing of your personal data, such data may only be processed – exceptthe storage of the data – with your consent or for the purpose of assertion,exercise or defence of legal claims, or for the protection of the rights of adifferent natural or legal person, or for reasons of an important publicinterest of the European Union or of an EU Member State.
4. Datacollection on this website
Our webpages use so-called “cookies”. Cookies are small text files andthey do cause any harm to your device. They are either temporarily stored onyour device for the duration of a session (“session cookies”) or storedpermanently on your device (“permanent cookies”). Session cookies are automaticallydeleted at the end of your visit. Permanent cookies remain stored on yourdevice until you delete them yourself or your browser deletes them automatically.
In some cases, third-party cookies can also be stored on your devicewhen you enter our website (“third-party cookies”). They allow us and/or you touse certain services offered by third parties (e.g., cookies for the processingof payment services).
Cookies have different functions. Many cookies are technicallynecessary, as certain website functions would not work without them (e.g., theshopping cart functions or displaying of videos). Certain cookies serve toevaluate user behaviour or display advertising.
Cookies may be necessary to carry out electronic communication processes(“necessary cookies”) or to provide certain functions you wish to see or use(“functional cookies”, e.g., used for the shopping cart function) or tooptimise the website (e.g., cookies used for measuring the web audience), andsuch cookies are stored on the basis of Art. 6(1)(f) of GDPR, unless any otherlegal basis is indicated. The website operator has a legitimate interest in thestorage of cookies in order to ensure technically accurate and optimisedprovision of the services. If it was requested to give a consent for thestorage of cookies, the storage of the relevant cookies is carried outexclusively on the basis of this consent (Art. 6(1)(a) of GDPR); this consentmay be revoked at any time.
You can arrange the settings of your browser in such a way that you areinformed about the possibility of storage of the cookies and only allow them inindividual cases, or you can reject cookies in certain cases or generally, oryou can activate the automatic deletion of cookies upon closing the browser.With cookies disabled, the functionality of this website may be limited.
Insofar as cookies are used by third-party companies or for analysispurposes, we will provide separate information in the framework of this DataProtection Statement, and, where applicable, request your consent.
Server log files
The provider of the webpages automatically collects and storesinformation in so-called server log files, which are automatically transmittedto us by your browser. These data are:
• Browser type and browserversion
• Operating system used
• Referrer URL
• Hostname of the accessingcomputer
• Time of the serverrequest
These data will not be merged with other data sources.
The collection of these data is carried out on the basis of Art. (6)(1)(f)of GDPR. The website operator has a legitimate interest in technically accuratepresentation and optimisation of this website, and for this purpose, the serverlog files must be recorded.
If you send us enquiries via the contact form, your details provided inthe enquiry form, including the contact details given there by you, will bestored for the purpose of the processing of the request and in case of anyfollow-up questions. We will not disclose these data without your consent.
The processing of these data is carried out on the basis of Art. 6(1)(b)of GDPR, insofar as your request is related to the performance of a contract,or the processing is necessary for the implementation of pre-contractualmeasures. In all other cases, the processing is based on our legitimateinterest in effective processing of the queries addressed to us (Art. 6(1)(f)of GDPR), or is based on your consent (Art. 6(1)(a) of GDPR) where it wasrequested.
The data provided by you in the contact form will be stored by us untilyou instruct us to erase them, until you revoke your consent to the storage oruntil the purpose for the data storage no longer applies (e.g., after yourrequest has been completed). Mandatory statutory provisions – in particularretention periods – remain unaffected.
5. Analysis toolsand advertising
Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited,Gordon House, Barrow Street, Dublin 4, Ireland.
Google Tag Manager is a tool that allows us to integrate tracking orstatistics tools and other technologies on our website. Google Tag Manageritself does not create user profiles, does not store cookies and does not carryout independent analyses. It serves only administration and display of thetools integrated through it. However, Google Tag Manager collects data on yourIP address, which can also be transferred to the Google’s parent company in theUnited States.
Deployment of Google Tag Manager is carried out on the basis of Art.(6)(1)(f) of GDPR. The website operator has a legitimate interest in quick anduncomplicated integration and administration of various tools on the operator’swebsite. If a corresponding consent was requested, the processing is carriedout exclusively on the basis of Art. (6)(1)(a) of GDPR; this consent maybe revoked at any time.
6. Email delivery
This website uses the service Mailgun to manage email addresses and sendmessages. The operator is Mailgun Inc., 112 E Pecan St #1135, San Antonio, TX78205, United States.
Mailgun allows us to send, receive and track emails within ourapplications. The email service collects, among others, personal data such asemail addresses, first and last names, usage data and telephone numbers.
The use of the email service is carried out on the basis of Art.(6)(1)(f) of GDPR. We have a legitimate interest in using this email tool inorder to organise and optimise our email delivery. If a corresponding consent wasrequested (e.g., consent to the storage of cookies), the processing is carriedout exclusively on the basis of Art. (6)(1)(a) of GDPR; this consent maybe revoked at any time.
7. Plugins andtools
This website uses the map service Google Maps. The provider is GoogleIreland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
To use the functions of the Google Maps, it is necessary to store yourIP address. This information is usually transmitted to a Google server in theUSA and stored there. The provider of this website has no influence on thisdata transfer.
The use of Google Maps is carried out in the interest of an attractiverepresentation of our services online and for an easy finding of the locationsindicated by us on the website. This constitutes a legitimate interest withinthe meaning of Art. (6)(1)(f) of GDPR. If a corresponding consent wasrequested, the processing is carried out exclusively on the basis ofArt. (6)(1)(a) of GDPR; this consent may be revoked at any time.
The data transmission to the USA is carried out on the basis of the EUCommission’s Standard Contractual Clauses. Please find other details here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.
Package Tracking Tool
This website uses a package tracking tool to registerand track shipments. The provider is Russian Post JSC [АО “Почта России”], 37 Varshavskoyeshosse, 131000 Moscow, Russia.
The Package Tracking Tool allows us to retrieveinformation on shipments by entering respective shipment number. The PackageTracking Tool records, among others, sender, delivery and recipient addressesas well as the full name, the shipment’s journey and the planned COD amount.
The use of this tool is carried out on the basis ofArt. (6)(1)(f) of GDPR. We have a legitimate interest in tracking the shipmentsin order to optimize both our shipping processes and our services. If acorresponding consent was requested (e.g., consent to the storage of cookies),the processing is carried out exclusively on the basis of Art. (6)(1)(a)of GDPR; this consent may be revoked at any time.
8. Our ownservices
Handling of applicants’ data
We offer opportunities to apply for a job in our company (e.g., byemail, post or via online application form). The information below is intendedto inform you about the scope, purpose and use of your personal data collectedduring the application process. We assure you that the collection, processingand use of your data is carried out in accordance with applicable dataprotection legislation and all other legal provisions, and that your data willbe treated strictly confidentially.
Scope and purpose of the data collection
If you send us an application, we process your personal data associatedto it (e.g., contact and communication data, application documents, notes inthe context of interviews etc.) as far as this is necessary to decide on establishmentof an employment relationship. The legal basis for this is Art. 26 of theGerman Federal Data Protection Act [BDSG] (as amended) under German law(initiating an employment relationship), Art. 6 (1)(b) of GDPR(general initiation of the contract) and – if you gave your consent – Art. 6(1)(a) of GDPR. The consent may be revoked at any time. Your personal data willbe disclosed within our company only to persons who are involved in theprocessing of your application.
In the case the application is successful, the data you submitted willbe stored in our data processing systems on the basis of Art. 26 of theGerman Federal Data Protection Act [BDSG] (as amended) and Art. 6(1)(b) ofGDPR for the purpose of carrying out the employment relationship.
Retention period for data
If we are not able to make you a job offer, if you reject our job offeror withdraw your application, we reserve the right to keep the data, which youprovided, on the basis of our legitimate interests (Art. 6(1)(f) of GDPR) forup to 6 months from the end of the application process, rejection or withdrawalof the application. Afterwards, the data will be deleted and physicalapplication documents will be destroyed. The storage serves in particular theevidence purposes in the event of a litigation. If it becomes apparent that thedata will be required after the expiry of the 6-month period (e.g., due to animminent or pending litigation), deletion will only take place, if this purposefor further retention no longer applies.
A longer retention of the data may also take place if you gave acorresponding consent (Art. 6(1)(a) of GDPR) or if statutory retentionrequirements oppose erasure of the data.
Registration in the applicants’ pool
If you are not offered a job offer, there might be a possibility toinclude you in our applicants’ pool. In the case of such registration, alldocuments and information from the application will be transferred to theapplicants’ pool so that you can be contacted for suitable vacancies.
Registration in the applicants’ pool is carried out exclusively on thebasis of your explicit consent (Art. 6(1)(a) of GDPR). Such consentremains voluntary and it bears no relation to the ongoing application process.The data subject concerned may revoke his/her consent at any time. In thiscase, the data will be irrevocably deleted from the applicants’ pool insofar asthere are no other legal reasons for storage of the data.
The data will be irrevocably deleted from the applicants’ pool at thelatest two years after the consent has been provided.