Privacy policy and personal data processing policy


1. General terms

1.1. This User Agreement (hereinafter – the Agreement) is a public offer and defines the terms and conditions of use of materials, services, and website (hereinafter Site). The site is legally owned by AROSA LLC (INN: 7719701745) and was created for the purpose of acquaintance of the interested party (User), with assortment of products, activities of AROSA LLC, filling of various forms of questionnaires (for vacancies, loyalty programs, promotions, contests, etc.).

1.2. This Agreement is valid for all information that AROSA LLC can get about the user during his use of the Site functionality, services, programs and products of AROSA LLC (hereinafter - Services). All existing services and applications on the Site, as well as any development and/or addition of new ones, shall be subject to this Agreement.

2. Terms and concepts used in this Agreement

2.1. AROSA LLC is a legal entity established in accordance with the legislation of the Russian Federation, carrying out its activities in accordance with the requirements of the current legislation.

User - any visitor to the Site (hereinafter referred to as User).

The right to use the Materials – the right of AROSA LLC to carry out the following actions: to publish, reproduce, communicate to the public, publicly show, recycle, disseminate Personal Information or any part thereof on any media in any material form and by any means, including the Internet.

Site - Information and Services Web site at the following electronic address: http:/

Confidential information – information that is designated by the user himself as information of special value to the User and which by default should not be known to third parties.

3. Right to use Materials/Images/Information

3.1. The use of content, as well as any other elements of the Site is possible only within the framework of the proposed functionality. No elements of the Site content, as well as any content placed on the Site, belonging to the legal right of AROSA LLC, may not be used in any other way without the prior permission of AROSA LLC. By the use is meant, inter alia: reproduction, copying, processing, distribution on any basis, display in a frame, etc. Exceptions are cases directly provided by the legislation of the Russian Federation.

3.2. The User is prohibited from reproducing, distributing, processing for commercial or non-commercial purposes elements of the Site that are subject to copyrights in the absence of permission from the respective copyright holders to perform these actions.

3.3. From the moment of filling in the feedback form on the Site, the User grants AROSA LLC the right to use the Materials and Images on the territory of all countries of the world (when sending them) for the entire period of the exclusive right, and also expresses its full and unconditional consent to the use of AROSA LLC images for the purpose of disclosure and further use of AROSA LLC. The means of using Personal Information including but not limited to: reproduction in any material form, disclosure, public display, processing, distribution on any media and by any means, including the Internet, or the use of Personal Information in any other way, in whole or in fragments..

3.4. AROSA LLC has the right at any time at its own discretion and without explanation of reasons without prior notification to restrict/close access to the User on the Site.

3.5. The User is personally responsible for the materials and images that the User provides to AROSA LLC under this Agreement.

3.6. If the Image of a citizen is received or used in violation of the current legislation of the Russian Federation, the User, the Image Copyright Holder shall have the right to request the removal of this image, appending documents and materials, confirming the fact that the applicant has exclusive and other rights, as well as documents confirming the illegal use of data and information by AROSA LLC.

3.7. Persons who have committed unlawful actions bear responsibility in accordance with the legislation of the Russian Federation.

4. Warranty and Liability of the User

4.1. Accepting the terms of this Agreement, the User declares and guarantees that he is the author of the Materials/copyright holder of the Images and/or is duly authorized by the respective authors/copyright holders to provide AROSA LLC the right to use the Materials/Images that have all necessary permissions from the authors of the Materials and the persons depicted on the photographs to grant the right to use the Materials/Images to AROSA LLC, and that the User has no obligations to third parties that prevent and/or make it impossible for the legitimate use of confidential information.

4.2. The User shall guarantee that he is the proper copyright holder of the materials and images or has obtained permission from his copyright holder and from the Image Citizen to disclose and use the image by the means and under the conditions specified in this Agreement, In the event of the death of the depicted person, the right holder shall have the consent of his children, the surviving spouse, and in their absence, the consent of the parents.

4.3. The materials and images transmitted by the User shall not: violate the current legislation of the Russian Federation and the legally protected interests of third parties; contribute to the incitement of religious, racial or ethnic discord; Be obscene or offensive, contain violent scenes, advertise drugs, be pornographic and violate the rights of minors; violate the copyright and related rights of third parties; contain explicit commercial advertising of a trademark on the goods, which are not goods of AROSA LLC.

4.4. The user should not use the Site to:
committing actions that lead to disruptions of the normal operation of the Site. downloading materials that are illegal, malicious, threatening, containing viruses or other computer codes, files or programs designed to disrupt, destroy or restrict the functionality of any computer or telecommunications equipment, or programmes for unauthorized access;
upload photos that offend morality, defamation, copyright infringement, propagandizing hatred and/or discrimination of people on racial, ethnic, sexual, Social and other grounds for violating and/or harming the rights of minors in any form.

4.5. The User is independently responsible and considers AROSA LLC free from damages/damages on claims of third parties, put forward in respect of Materials/Images and their contents. In case of claims against AROSA LLC regarding materials/images or Personal data and their content by any third parties, the User undertakes to settle such claims and/or claims independently and at his own expense and to compensate LLC AROSA Damages due to full claims.

4.6. The User undertakes to compensate the property losses of AROSA LLC in accordance with the procedure established by the legislation of the Russian Federation in the amount of the sums directed to compensation of losses incurred by third parties whose intellectual rights have been violated and/or the right provided by Article. 152.1 The Civil Code of the Russian Federation, as well as the User undertakes to reimburse the court expenses, as well as the expenses aimed at the preparation, conduct of court cases, including the involvement of consultants (lawyers, experts) including those in leading positions in their field of professional activity, as well as in the amount of sums directed to the execution of court decisions, sums aimed at the payment of sanctions, penalties and fines under the relevant contracts.

4.7. The User has no right to transfer, sell, publish, move, reproduce, modify or modify materials of the Site or to use them in any other similar way, either partially or in general, except with the written permission of AROSA LLC to these actions.

4.8. The User is independently responsible to third parties for his actions connected with the use of the Site, including, if such actions will lead to violation of the rights and legitimate interests of third parties, as well as for compliance with the legislation when using the Site.

4.9 AROSA LLC has the right to take non-proscribed measures to protect its own intellectual rights in relation to the Site/Services.

4.10. The validity of this Agreement in respect of the User’s warranties and liability shall be indefinite.

5. Completing the Feedback Form on the Site

5.1. When completing the feedback form, the User undertakes to provide reliable and complete information about himself on the issues proposed in the form and to keep this information up to date. If the User provides incorrect information or AROSA LLC has reason to believe that the information provided by the User is incomplete or unreliable, AROSA LLC has the right at its discretion to block the User and refuse the User to use their services (or their individual functions).

5.2. In case when the data indicated when filling in the feedback form do not allow identification of the user, AROSA LLC have the right to refuse the User access to the services of the Site or leave the information provided by the User without consideration.

5.3.The User is independently responsible for all actions (as well as their consequences) within or using the services of the Site, including cases of voluntary transfer of data by the User for the use of the Site to third parties on any terms (including treaties or agreements). In this case, all actions within the framework of or with the use of the services of the User’s Site are considered to have been carried out by the User himself, except for the cases when the User, in accordance with the procedure provided in para. 5.5. This Agreement, notified AROSA LLC about unauthorized access to the services of the Site or about any violation (suspicion of violation) of confidentiality of its means of access to its data.

5.5. The User shall immediately notify AROSA LLC of any unauthorized (not authorized by the User) access to the services of the Site using the User’s feedback form and/or any violation (suspected infringement) the privacy of their means of accessing the Site.

5.6. AROSA LLC has the right to ban access to certain services of the Site without explaining the reasons, including in case of violation by the User of the terms of the Agreement or the current legislation of the Russian Federation.

5.7. The User has the right at any moment to withdraw the data sent by AROSA LLC by sending the official written request by Russian Post to the legal address indicated in register of legal entities (EGRUL).

6. Change of User's personal information

6.1. The User has the right at any moment to change(update, complement)the personal information provided to them or part thereof, and to indicate the parameters of its confidentiality by sending an official written request by by Russian Post to the legal address indicated in register of legal entities (EGRUL).

7. Confirmation of the Agreement

7.1. The User shall guarantee that he has the necessary legal capacity and capacity, as well as all rights and powers necessary and sufficient to conclude and execute the Agreement in accordance with its terms.

7.2. This Agreement shall enter into force from the moment of User’s expression of consent to its terms in the following order: Starting to use the Service/Site separate functions, the User shall be deemed to have accepted the terms of the Agreement in full, without any reservations and exceptions. If the User does not agree with any of the Terms of the Agreement, the User may not use the Service/Site.

7.3. In case AROSA LLC has made any changes to the Agreement in the order stipulated by this Agreement, with which the User does not agree, it shall immediately stop using the Service/Site.

7.4.Completion of the feedback form on the Site by the User means the consent of the latter to receive information about special offers, about new goods and promotions on telecommunication networks and by mail (including but not limited to: SMS-mailings, e-mail-mailings) and processing of their personal data through the collection, recording, systematization, stockpiling, storage, clarification, extraction and use of automated means, including information and telecommunications networks, or without the use of such means in order to organize the sending of special offers, information about new products and promotions, processing of requests and appeals.

7.5. AROSA LLC makes commercially reasonable efforts to ensure the operation of the Site around the clock, but does not guarantee the absence of interruptions related to technical failures, maintenance work, and does not guarantee full or partial functionality of the Site’s services.

7.6. In order to collect statistical data and identify the User AROSA LLC has the right to install and save information about IP-addresses of access of Users.

8. Modification of the Confidentiality Agreement

8.1.The agreement may be amended by AROS» LLC without any special notice of the User, the new version of the Agreement shall enter into force from the moment of its placement on the Internet, unless the new version of the Agreement provides otherwise. If, after such changes enter into force, the User continues to work with the Site, the User confirms his acceptance of the changes. If at any time the User is no longer able to comply with the terms of the Agreement, the User shall immediately cease using such Agreement.


1. General terms

The operator’s policy regarding the processing and security of personal data (hereinafter - Policy) of the users of the website (hereinafter - Site) is developed in accordance with the Federal Law of 27.07.2006. 152-FZ About personal data (hereinafter - FZ-152). This Policy defines the order of processing of personal data and measures to ensure the security of personal data in «AROSA» LLC (hereinafter - Operator or Compan») for the purpose of protection of human and civil rights and freedoms when processing personal data, including protection of the rights to privacy, personal and family privacy.

The Policy uses the following basic terms:

Personal data (PD) - any information relating to a directly or indirectly defined or defined individual (hereinafter referred to as a subject of personal data or User);

User - any visitor to the Site;

automated processing of PD - processing of PD using computer tools;

PD processing - any action (transaction) or set of actions (transactions) performed using or without means of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change)Removal, use, transfer (distribution, provision, access), depersonalization, blocking, disposal, destruction of PD;

operator - public authority, municipal body, legal or individual person, independently or jointly with other persons organizing and (or) carrying out PD processing, as well as determining the purpose of PD processing, the composition of PD to be processed, actions (operations) committed with personal data.

2. Principles and conditions of PD processing

The website policy defines the principles of handling collected personal data and implies their encryption based on:
▸  The rule of law and equitable bases;
▸  Restricting PD processing to specific, predefined and legitimate purposes;
▸  Prevent PD processing that is incompatible with the purpose of PD collection;
▸  Prevent the consolidation of databases containing personal data that are processed for incompatible purposes
▸  processing only those PD that meet the purpose of their processing;
▸  Compliance of content and volume of processing of PD with the declared purposes of processing
▸  Avoidance of treatment of PD excessive in relation to the stated purposes of their processing;
▸  оensuring the accuracy, sufficiency and relevance of PD in relation to the purposes of PD processing;
▸  The destruction or anonymization of the PD upon the achievement of its processing objectives or in the event of the loss of the need to achieve these objectives, if the Operator cannot eliminate the violations of the PD, unless otherwise provided by federal law.

3. The procedure and conditions for processing PD

The company receives personal data from subjects of personal data in the following ways: Provision of personal data directly by the subject, including filling in various forms of questionnaires (for posted vacancies, for participation in loyalty programs, promotions, competitions, etc.) on the Company’s website. Personal data provided through the Company’s websites are automatically processed and transferred to the Company’s general mailing address database. When registering on the site the visitor is notified of the need to familiarize with the policy of processing personal data accepted in the Company. Registration of persons who have not given consent to the processing of personal data is not allowed. Obtaining personal data from other operators of personal data with the consent of the subjects in order to participate in general loyalty programs and other actions. When transferring your personal data to the Company, users should bear in mind that the processing of personal data is not limited to the period of performance of the sales contract, as personal data is stored in the company’s accounting records (invoices, order forms, claims) and kept indefinitely. In the client database, PD is stored until the end of the processing purpose (notification of consumers about novelties, promotions, loyalty programs and other activities of the Company) or until the client withdraws its consent to processing. Personal data whose processing (storage) period has expired shall be destroyed, unless otherwise provided by the Law. After termination of processing, PD may be stored only after they have been depersonalized. Users independently determine the amount of PD transferred to the company when completing the questionnaire, on the Company’s website.

4. Rights of the subject of the PD

4.1. The PD entity decides to grant the PD and consents to its processing freely, by its will and in its interest. Consent to the processing of the PD may be given by the PD entity or its representative in any form that may confirm the receipt of the PD, unless otherwise provided by federal law. 4.2. The User has the right:
▸  To receive from the Company any information on the procedure for processing their PD, i.e. information on the existence of PD, legal grounds, objectives and methods of processing;
▸  Require the Company to clarify, block or destroy its PD if it is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
▸  Withdraw at any time its consent to PD processing.

5. The Company while processing PD provides:

▸  providing the User, upon request, with information relating to the processing of its PD within 30 (thirty) calendar days from the date of receipt of the request;
▸  blocking or stopping PD processing at the request of the User;;
▸  destruction of the PD when the purpose of treatment is achieved;
The user can obtain clarification on the issues of processing of his PD or withdraw his consent to processing by sending an official written request to the legal address specified in EUGRL on the date of sending the corresponding application.

6. Objectives for the PD processing

The company uses PD for the following purposes:
▸  execution of contracts of purchase and sale and rendering of services, including those concluded remotely, delivery of goods, return of goods
▸  provision of information on goods/services, promotions and special offers, analysis of quality of service provided by the Company
▸  maintaining a bonus account and fulfilling other obligations of the Company under loyalty programs.
▸  Establishing feedback with the User, including sending notifications, requests regarding the use of the Site.

The Company may send advertising and information messages to the User. If the User does not wish to receive mailings, he notifies the Company by clicking at the bottom of the "Unsubscribe from mailing list". The Company shall not disclose the personal data of the User, except to provide their agents, delivery services and other third parties, to the extent necessary for performance of obligations to the User.

7. Securing PD

The Company recognizes and takes seriously its duty to protect personal data, which you trust AROSA LLC, from loss, misuse and unauthorized access. Company AROSA LLC uses many security technologies and organizational procedures that help to protect your data. For example, the Company uses access control, firewalls, secure servers and encryption of various types of personal data, such as financial information and other private information. In order to protect personal data AROSA LLC: • Stores the information carriers containing personal data in special strictly controlled and protected premises; • Controls access to personal data and allows, before processing, only employees who have signed a confidentiality agreement; • Protects information from failures and incorrect operation of hardware and malicious software; • Applies secure transfer protocols and encryption to ensure the security and anonymity of personal data; • It uses antivirus and data protection tools.

8. Final provisions

Other rights and obligations of the Operator in connection with the processing of personal data shall be determined by the legislation of the Russian Federation in the field of personal data. The Operator is not responsible for the information provided by the User on the Site in the public domain. The Operator shall not be liable to the User for any loss or damage incurred by the User as a result of the deletion, failure or impossibility of keeping any content and other communication data contained on or transmitted through the Site.

9. Changing Present Policy

This Policy may be changed or terminated unilaterally by the Operator without prior notice to the User. The new version of the Policy shall enter into force from the moment of its posting on the Operator’s Website, unless otherwise provided by the new version of the Policy. The fact that personal data are sent by the User indicates the unconditional acceptance of the provisions of this Policy. The latest version of the Policy is available online at: