• CONDE NAST JSC Websites Users Personal Data Processing Policy

CONDE NAST JSC (hereinafter referred to as CONDE NAST, the Company or We) seeks to keep your personal data confidential and to ensure your positive impression of visiting our websites1. This document describes the personal data processing methods which CONDE NAST applies with respect to all users of its websites.

Visiting any of our websites, you thereby agree, absolutely and unreservedly, with this Policy, and give to CONDE NAST the consent to perform all and any actions with the personal data that you provide while using our websites, including their collection, systematization, accumulation, storage, adjustment (update, amendment), use, blocking, removal, under the terms and conditions set out in this Policy.

Also, you, thereby, give the consent to CONDE NAST to process your personal data by adding them in the CONDE NAST’s lists and electronic databases according to the terms and conditions set out in this Policy. Your consent to personal data processing is effective from the moment you provide personal data at our website and during the whole period of your using the CONDE NAST websites. The terms and conditions of withdrawing the consent are set out in section 4 of this Policy.

Personal data collection, processing, storage and transfer are performed in accordance with the requirements of Federal Law On Personal Data dated 27.07.2006 No.152-FZ and in compliance with necessary requirements on data protection set out in RF Government Ordinance dated 01.11.2012 No.1119 On approval of the requirements to the protection of personal data when they are being processed in personal data information systems.

In accordance with subclause 2 of Article 3 of Federal Law dated 27 July 2006 No.152-FZ On Personal Data, the Company is an operator, i.e., a legal entity which independently arranges and (or) performs personal data processing, as well as determines the purposes of personal data processing, the composition of personal data to be processed, the actions (operations) made to personal data. The Company does not process personal data on behalf of another operator.

An important condition of fulfilling the purposes of the Company’s operations is to ensure the protection of the rights and liberties of man and citizen – the personal data subject – when processing their personal data.

The Company has developed and put into effect the documents which set an order for personal data processing and protection and ensure the compliance with the requirements of Federal Law dated 27 July 2006 No.152-FZ On Personal Data and applicable laws and regulations.

According to the Approved personal data processing purposes and composition of personal data being processed, we do not collect, process or store biometric and special personal data. If the website visitors provide voluntary special or biometric personal data, CONDE NAST will not take into account these data during their processing.

The Company reserves the right to make amendments, from time to time, to the provisions and the terms and conditions of this Policy. Communications about such amendments will be placed on this page. The use of our websites means your consent to all amendments to these provisions and terms and conditions. Please, check regularly this page to get to know an updated version of the Policy.

1. Your Personal Data Collection

1.1. Collecting any personal data at any of our websites, CONDE NAST necessarily informs what this information is needed for.

1.2. Personal data represent any information relating, directly or indirectly, to a certain or defined individual (personal data subject).

These data may include, among other, name, email address, mail or location address, occupation and other information necessary for provision of services, delivery of goods or performance of other operations upon your demand, as well as for fulfilment of the obligations under an agreement entered into with you, e.g., competition rules.

1.3. Having provided us with your personal data, you will be able to:

  • make notes in the forum and comments in the blogs;
  • subscribe to our newsletter;
  • participate in contests and other special programs;
  • participate in surveys, tests and quizzes2;
  • get access to the website closed sections, lectures and webinars;
  • use personal space at the website (a personal account/profile);
  • obtain information about the personal data operator;
  • purchase services and products offered at our website.

2. The Principles and the Terms and Conditions of Personal Data Processing

2.1. The Company, being an operator, processes personal data of the following personal data subjects:

  • applicants to a job in the Company;
  • employees of the Company;
  • family members of the employees of the Company;
  • former employees of the Company;
  • individuals under civil contracts and contractors’ representatives;
  • visitors of the Company;
  • visitors of the websites of the Company.

2.2. The Company processes personal data in compliance with the following principles:

  • personal data processing is performed on a lawful and fair basis;
  • only those of your personal data are processed and only for those purposes that are indicated when they are collected, as well as for the purposes of the compliance with effective legislation and fulfilment of agreements entered into with you;
  • when processed, your personal data are guaranteed to be in their minimum sufficient composition, and their content and volume correspond to the announced personal data processing purposes;
  • when processed, the personal data are guaranteed to be accurate, sufficient, and, if necessary, updated with regard to the purposes of the personal data processing;
  • your personal data are stored no longer than required for the purposes of personal data processing indicated at their collection, as well as for the purpose of the compliance with effective legislation requirements, and fulfilment of agreements entered into with you;
  • we do not combine the databases containing your personal data that are processed for conflicting purposes.

2.3. We use your personal data only for the purposes that are indicated when they are collected, as well as for the purposes of the compliance with effective legislation requirements, and fulfilment of agreements entered into with you. We do not use your personal data for other purposes without your consent.

2.4. We can use your personal data for such purposes as:

  • preparation for entering, entering, fulfilment and termination of agreements for the purchase of services and goods offered at our website;
  • collection and analysis of the website visitors’ data.

These purposes are realized when:

  • creating users’ personal profiles;
  • getting feedback from you for the purposes of providing information or service;
  • responding to your requests to the website support service;
  • holding contests, draws and other advertising actions at CONDE NAST websites;
  • holding surveys and opinion polls for improving the quality of services, including by means of calls. The participation in any survey is voluntary only;
  • providing you with information (including advertising mailouts and newsletters) and services in accordance with your requests and preferences;
  • providing you the opportunity to communicate with other registered users at CONDE NAST websites;
  • fulfilling the obligations under agreements.

2.5. The timeline for personal data processing is determined taking into account:

  • the purposes set for personal data processing;
  • the timelines of the agreements with the personal data subjects, and the personal data subjects’ consents to their personal data processing;
  • the timelines determined by Rosarkhiv Order dated 20.12.2019 No.236 On approval of the List of standard management archive documents created in the course of the activities of state bodies, local government bodies and organizations, with indication of the timeline of their storage;
  • the documents storage timelines set by internal regulations of the Company.

2.6. The personal data allowed to be distributed by their subject may only be processed subject to a separate consent for such personal data processing. In this consent the Company determines the volume of personal data to be processed, describes the terms and conditions of their processing and provides you the opportunity to set bans, and terms and conditions regarding the transfer of your personal data.

3. Update and Termination of Personal Data Processing

3.1. We shall need your help in order to ensure the accuracy and up-to-datedness of the information provided by you.

3.2. We shall appreciate your updating your personal data as they change. The CONDE NAST websites users can update their personal data independently through editing the user’s profile.

3.3. The Company terminates the personal data processing in the following cases:

  • the purpose of your personal data processing has been achieved;
  • the timeline for personal data processing stipulated by federal laws, the agreement or the consent of the personal data subject to their personal data processing has expired;
  • if the personal data subject withdraws their consent to their personal data processing, in cases not conflicting with the requirements of federal laws.

4. The Consent to Personal Data Processing and Withdrawal of the Consent

4.1. The consent of website users to the processing of their personal data obtained by the Company at our websites, as well as through the use of Cookies, is given by means of confirming (pressing the button “OK” in a pop-up box) the acceptance of this Policy terms and conditions.

4.2. The withdrawal of the consents to processing of the website users’ personal data is made by means of sending a letter to the address: 125009, Moscow, B. Dmitrovka St., 11, bld.7 (for paper letters), or an electronic letter to the email address: privacy@cnhelp.ru.

4.3. When withdrawing the consent to your personal data processing (exclusive of personal data distribution), please make sure that, apart from the information on the withdrawn consent to personal data processing, the withdrawal contains the details specified in cl. 3 of Art. 14 of Federal Law dated 27 July 2006 No.152-FZ On Personal Data, in particular:

  • your passport (or other identity document) number, its date of issuance and the issuing body;
  • information confirming that you are with the Company in a relationship related to personal data processing (e.g., payment details of the orders for our services provided to you, etc.);
  • your signature.

4.4. When withdrawing the consent to your personal data processing, please check, that, apart from the requirements to stop the distribution of your personal data, the withdrawal contains the details specified in part 14 of Art. 10.1 of Federal Law dated 27 July 2006 No.152-FZ On Personal Data, in particular:

  • first name, surname, patronymic (if any);
  • contact details (telephone number, e-mail or mail address);
  • list of the personal data which processing must be terminated.

4.5. The Company reserves the right to continue your personal data processing after receiving your claim to withdraw your consent only in case of having updated purposes of the personal data processing specified at their collection, or performing requirements of the RF effective legislation.

4.6. If you wish to refuse of the mailouts sent to your address, you can do it using the opt out instruction sited in the letters that you receive.

4.7. Your refusal of mailouts is not a ground for the Company to terminate the processing of your personal data. If you also wish to withdraw your consent to personal data processing, you need to send to our address a claim according to the terms and conditions set out in this section.

5. Provision of Your Personal Data to Third Parties

5.1. We may transfer your personal data (including Cookies) to third parties for marketing purposes.

5.2. We may transfer your personal data to companies affiliated with CONDE NAST or being a member of the CONDE NAST Publishing House Group, for processing and storage.

5.3. We also may transfer your personal data to authorized agencies or subcontractors for performing a required service or obligations under the agreements made with you. For example, sending to you an award won in one of our contests, we must provide your name and the address of the transport company or the sponsor handing the award. We provide to third parties the minimum personal data necessary only for the provision of a required service or the fulfilment of obligations.

5.4. When necessary, we can use your personal data and other information to respond to the requests of state bodies, summons, court orders and rulings.

5.5. We may collect and provide the information at our disposal to third parties for investigation, prevention and termination of any unlawful deeds and violations of the terms and conditions of the use of the CONDE NAST websites, or in other situations envisaged by law.

5.6. When roaming at the CONDE NAST websites, you may be redirected to other websites containing informational or functional resources provided by third parties. Usually, it is done in case of holding special events, e.g., contests, surveys or opinion polls.

5.7. The use of your data will be ruled by this CONDE NAST Policy, only if the information is collected on behalf of CONDE NAST.

5.8. In case of providing information at other websites (e.g., when transiting to them from a CONDE NAST website), the personal data privacy and protection policies approved by their owners will be applied. We accept no responsibility for the content of such websites and the personal data policy adopted by their owners. We suggest that you get familiar with the data privacy and protection policy at such third-party websites (as well as at any other websites).

5.9. The Company, having received a respective consent from you, may engage for the processing of your personal data another person on a contractual basis. When transferring your personal data to such a person, the Company requires from them the compliance with personal data processing principles and rules consistent with this Policy, to ensure the data confidentiality and to realize protection measures.

5.10. The Company transfers your personal data in the following volume, for the following purposes and to the following third parties:

  • Full name, the user’s login, date of birth, email address, contact telephone number, mail address are provided to Tempoline Logistica LLC (INN 9701069871, legal address: 105066, Moscow, Olkhovskaya St., 16, bld. 5-5а, attic room А) for the purposes of the organization and control of printed magazines delivery;
  • Email address, full name, date of birth, the unique Cookies value, delivery address, the name and price of the goods are provided to MINDBOX LLC (INN 7713688880, legal address: 125124, Moscow, Pravdy St., 26, floor 12, premises XXX) for the purposes of creating personalized advertisement, arranging and providing newsletters;
  • Surname, first name, patronymic, email address, contact telephone number, mail address, date of birth, IP-address, device identifier, OS type and version, browser type and version, connection speed (connection to the website), the sequence of transitions between webpages, the sequence of the user’s actions on the webpage (website), Cookies are transferred to Yandex LLC (INN 7736207543, legal address: 119021, Moscow, L’va Tolstogo St., 16 (Yandex.Metrica), Mediascope JSC (INN 7714117913, legal address: 125319, Moscow, Bolshoi Koptevskiy drive, 6, (TNS Mediascope), Rambler Internet Holding LLC (INN 7725243282, legal address: 117105, Moscow, Varshavskoye highway, 9, bld. 1, prem. А, room part 22, (Rambler), Rambler Group LLC (INN 7707375342, legal address: 117105, Moscow, Varshavskoye highway, 9, bld. 1, prem. D, room 5 (Livejournal), VKontakte LLC (INN 7842349892, legal address: 191024, Sankt-Peterburg, Khersonskaya St., 12-14, liter А, prem. 1-N, (VK), Mail.RU LLC (INN 7743001840, legal address: 125167, Moscow, Leningradskiy avenue, 39, bld. 79), Google LLC (INN 7704582421, legal address: 115035, Moscow, Balchug St., 7), IP Klimenko German Sergeevich (INN 770200186525, legal address: 121151, Moscow, Kutuzovskiy avenue, 22, Klimenko and Co. office, (LiveInternet), for the purposes of forming recommendations, collecting summarized analytics.

6. Use of Personal Data for Other Purposes

6.1. In order to use your personal data for any other purpose aside from those listed in this Policy, we request your confirmation.

7. Your Personal Data Security

7.1. CONDE NAST uses security technologies, procedures and arrangements to protect your personal data from unauthorized access, use or public disclosure.

7.2. We intent to protect your personal data, but we cannot guarantee security of the data you transfer.

7.3. We recommend taking all measures to protect your personal data when working in the Internet. Change passwords frequently, use word-numeric combinations for the passwords and use a protected browser.

7.4. The Company fulfils all necessary personal data protection requirements stipulated in Federal Law dated 27 July 2006 No.152-FZ On Personal Data and regulatory acts adopted in accordance therewith.

7.5. As arrangements on the processing and protection of your personal data, CONDE NAST:

  • has appointed a person responsible for the arrangement of personal data processing;
  • has published and issued the Personal Data Processing Policy and local acts on personal data processing and security;
  • performs internal control procedures and audits the compliance of personal data processing with personal data legislation requirements;
  • assesses the harm that may be done to the personal data subject;
  • familiarizes the employees with local acts on personal data and holds trainings for the employees;
  • has taken measures aimed at the security of personal data when they are processed automatedly;
  • has determined the threats to the security of personal data when they are processed in the personal data information systems;
  • applies, in accordance with the determined protection levels of personal data processing information systems, organizational and technical arrangements ensuring the personal data security;
  • applies necessary information protection measures;
  • assess the effectiveness of the arrangements taken to ensure personal data security;
  • accounts for personal data medium facilities;
  • has organized a non-authorized personal data access detection procedure;
  • has organized a restoration procedure for personal data that have been modified or destroyed due to non-authorized access;
  • has established the rules of access to the personal data processed in personal data information systems, registers and records the actions made with personal data in them;
  • controls the measures taken to ensure personal data security and the personal data information systems protection level.

8. Cookies and Other Technologies

  • 8.1. Cookies and other technologies may be used at CONDE NAST websites. At the Company’s website there may be used its own technical and marketing Cookies. Cookies are used to form recommendations, create personalized advertisement and collect summarized analytics, as well as unique Cookies values are used to form users’ profiles. Using these tools, we can better understand the user needs and necessities and improve the level of our services and the effectiveness of using our websites. Most of our websites can be used even if Cookies are turned off in the browser. However, some websites may not allow to perform certain operations, if Cookies are turned off and you do not provide your consent to use them. You always can refuse of using Cookies through the settings of your browser.
  • 8.2. We use third-party services to monitor the traffic, statistic researches, advertisements and other operations at the CONDE NAST websites. In particular, we use Yandex.Metrica and Google Analytics services for the purposes of remarketing and forming reports on demographic stats and interest categories. To find out how our partners use Cookies, please read their privacy policies at their websites. If you don’t want that the information about your activities at the CONDE NAST websites be provided to Yandex.Metrica and Google Analytics, you can install a Google Analytics blocker or use an advertisement refusal tool NAI (Network Advertising Initiative). However, we reserve the right to use other web-stats collection tools.
  • 8.3. Upon permission of CONDE NAST, these and other third parties can use Cookies, the CONDE NAST websites access history logs, web-counters and other monitoring technologies for the compilation of anonymous aggregated stats on the CONDE NAST websites users.
  • 8.4. We also reserve the right to include web-counters in HTML newsletters to count the number of opened emails (articles, links, etc.).

9. Data Storage

9.1. CONDE NAST stores your personal data from the moment you provide them and over the whole period of your using the CONDE NAST websites, but no longer than it is necessary for the purpose of their collection or as required by effective laws and regulations.

9.2. The Company processes personal data using the databases located at the territory of the Russian Federation.

10. Children Personal Data Privacy

10.1. CONDE NAST does not collect personal data of persons under 14 years old.

10.2. If we find out that our systems have got data of an under 14-year-old child, such information shall be deleted immediately.

10.3. CONDE NAST strictly recommends to control the use of websites by children.

11. Consent with this Policy Provisions

11.1. A CONDE NAST website user, providing own personal data, thereby, agrees with this Policy provisions.

12. The Rights of the Subjects Whose Personal Data Are Processed by the Company

12.1. The personal data subject is entitled to get the information related to the processing of their personal data, including information which contains:

  • confirmation of the fact of personal data processing by the Company;
  • legal grounds and the purposes of personal data processing;
  • information on the methods of personal data processing applied by the Company;
  • names and locations of the Company, information on the persons (exclusive of the Company’s employees) who have access to the personal data or to whom the personal data may be disclosed under an agreement with the Company or under laws;
  • processed personal data related to a respective personal data subject, the source of their obtaining;
  • timelines of personal data processing, including their storage;
  • information on the transfer made or a supposed transboundary transfer of data;
  • name or surname, first name, patronymic and address of the person processing the personal data on behalf of the operator.

12.2. The personal data subject is entitled to require that the Company clarify their personal data, block or destroy them, if the personal data are incomplete, outdated, imprecise, unlawfully obtained or unnecessary for the announced purpose of processing.

12.3. The personal data subject is entitled to set out in the consent to processing the personal data allowed by such subject for distribution, terms and conditions of and bans on their distribution. The personal data subject is entitled to address to the Company a request to stop the transfer of (distribution, provision, access to) their personal data, previously allowed for distribution.

12.4. The personal data subject is entitled to withdraw their consent to personal data processing. The terms and conditions of the withdrawal of the consent are set out in section 4 of this Policy.

12.5. To exercise the said powers, the personal data subject can send a written request (by a registered letter with return receipt requested) to the address: 125009, Moscow, Bolshaya Dmitrovka St., 11, bld. 7, or to email address privacy@cnhelp.ru (for e-letters). When sending a request, please make sure that it complies with the terms and conditions specified in clauses 4.3 and 4.4 of this Policy.

13. Corporate Details

13.1. CONDE NAST JSC details: INN 7709244433.
Mail address: 125009, Moscow, Bolshaya Dmitrovka St., 11, bld. 7.
The email address for e-letters on the matters of the personal data processing and security: privacy@cnhelp.ru.

1 Including, without limitation, the following websites: www.condenast.ru, www.vogue.ru, www.tatler.ru, www.gq.ru, www.glamour.ru, www.admagazine.ru, www.cndd.ru, www.condenaststore.ru, as well as other websites of CONDE NAST JSC.
2 Quiz is a short online opinion poll, upon having completed which you are shown the result.