Date of publication: May 2020

1.    General Provisions

1.1. This Privacy Policy (hereinafter referred to as the “Privacy Policy”) is developed on the basis of the current legislation of the Russian Federation, including the Federal Law “On Personal Data” dated July 26, 2006 No. 152-FZ, and other legislative and regulatory acts.

1.2. This Privacy Policy applies to all information that the website www.skylight.aero (hereinafter referred to as the Website) located on the domain name www.skylight.aero can collect about the user (hereinafter referred to as the User) while using the Website.

1.3. Use of the Website means the User’s unconditional consent to this Privacy Policy and the conditions for personal data processing specified in it; in case of disagreement with these conditions, the User should refrain from using the Website.

1.4. Being the operator of personal data (hereinafter referred to as Personal Data), SkyLight Limited Liability Company (hereinafter referred to as the Operator) carries out all necessary measures related to the protection of Personal Data in accordance with the legislation of the Russian Federation.

1.5. This Privacy Policy applies only to the Website. The Operator does not control and is not responsible for third-party websites to which the User can click on the links available on the Website. On such websites, the User’s other Personal data may be collected or requested, and other actions may be performed.

1.6. The Operator does not verify the accuracy of the Personal Data provided by the User and does not monitor the capacity of the User. Use by the User of the services of the Website means acceptance of this Privacy Policy and the conditions for the processing of Personal Data.

1.7. In case of disagreement with the terms of the Privacy Policy, the User must stop using the services of the Website.

2. Adopted Terms

2.1. The following terms are used in this Privacy Policy:

2.1.1. “The Operator” - a state body, municipal body, legal or natural person, organizing and (or) carrying out the processing of Personal data, as well as determining the goals and content of Personal data processing.

2.1.2. “Personal data” - any information relating directly or indirectly to a specific or determinable natural person (subject of Personal data).

By providing your Personal Data to the Operator, the User agrees that the Personal Data is provided on a voluntary basis. Within the framework of this Policy, “Personal Data” means:

-   personal information that the user provides about himself when registering (creating an account) or in the process of using the Website;

-    data that is automatically transmitted by the Website in the process of using it due to the software installed on the user's device, including the IP address, information from cookies, information about the user's browser (or other program that accesses the Website), access time, address of the requested page;

-    date and time of access to the Webite;

-    information about the User’s activity when using the Website (for example, the history of search queries);

-    geolocation information;

-    other information necessary for data processing in accordance with the purposes of Personal data processing.

2.1.3. “Processing of Personal Data” - any action (operation) or a set of actions (operations) performed using / without using automation tools with Personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), search, extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data.

2.1.4. “Automated Personal Data Processing” - processing of Personal Data using computer technology.

2.1.5. “Dissemination of Personal Data” - actions aimed at the disclosure of Personal Data to an indefinite number of persons.

2.1.6. “Submission of Personal Data” - actions aimed at the disclosure of Personal Data to a specific person or a certain circle of persons.

2.1.7. “Blocking of Personal Data” - temporary termination of the processing of Personal Data (unless the processing is necessary to clarify Personal Data).

2.1.8. “Destruction of Personal Data” means actions that make it impossible to restore the content of Personal Data in the Personal Data information system and (or) as a result of which material carriers of Personal Data are destroyed.

2.1.9. “Anonymization of Personal Data” means actions that make it impossible to determine the ownership of Personal Data to a specific subject of Personal Data without using additional information.

2.1.10. “Personal Data Information System” - a set of personal data contained in databases and providing their processing, information technology and technical means.

2.1.11. “Confidentiality of Personal Data” - a requirement necessary to comply with for the Operator or other person who has gained access to Personal Data not to allow the dissemination of Personal Data without the consent of the subject of Personal Data or other legal grounds.

3. Privacy Policy Subject

3.1. This Privacy Policy establishes the Operator’s obligations not to disclose and to ensure the protection regime of the Personal Data Confidentiality that the User provides at the Operator’s request when registering on the Site.

3.2. The User confirms that, by clicking on the submit button of the completed form on the Website, he agrees to the processing of Personal Data. Putting a checkmark opposite the text “I have read the Privacy Policy and agree to the processing of Personal Data” confirms the capacity of the User and his freedom of expression. Personal data authorized for processing under this Privacy Policy: last name, first name, patronymic of the User; User’s telephone number; email address and other Personal data that is voluntarily provided by the User.

3.3. The Operator protects data that is automatically transmitted when visiting webpages: IP address; information from cookies; information about the browser; access time; referrer (address of the previous page).

3.4. Any other personal information not specified above is subject to reliable storage and non-distribution, with the exception of cases provided by the legislation of the Russian Federation and this Privacy Policy.

4. Personal Data Storage and Processing

4.1. Personal data is stored in the Russian Federation.

4.2. Personal data is stored for as long as necessary to achieve the purpose for which it was collected, or to comply with the requirements of the legislation of the Russian Federation.

4.3. The User’s personal data may be transferred by the Operator to counterparties in order to improve the quality of service. Separate information in cases stipulated by law may be transferred to law enforcement authorities upon their legitimate, reasonable and motivated requests.

5. Purposes of Personal Data Collection

5.1. The Operator may use the User’s personal data in order to:

5.1.1. Identification of the User registered on the Website for its further authorization.

5.1.2. Fulfillment of the Operator's contractual obligations to the User, including ensuring the operation of the Website and the services provided on the Website.

5.1.3. Conducting marketing research, establishing feedback with the User including sending notifications, requests regarding the use of the Website, processing requests and applications from the User.

5.1.4. Determining the location of the User to ensure security, prevent fraud.

5.1.5. Confirmations of the accuracy and completeness of the Personal Data provided by the User.

5.1.6. Creation, with the consent of the User, of an account for the use of parts of the Website.

5.1.7. User’s notifications by email.

5.1.8. Providing the User with effective technical support in case of problems associated with the use of the Website.

5.1.9. Providing with the consent of the User of special offers, newsletters and other information on behalf of the Website.

5.2. Detailed information about third parties involved in the processing of Personal Data (name, address and purpose of Personal Data transferring) can be provided to the User upon his request. A written request can be sent to the following address: 123112, Moscow, Presnenskaya embankment, house 8, building 1, floor 15, room 11f or to the email address: info@skylight.aero in the form of an electronic document signed by electronic signature in accordance with the legislation of the Russian Federation.

6. Methods and Terms for Personal Data Processing

6.1. The Operator can perform the following actions with the User’s Personal Data: collection, recording, systematization, structuring, accumulation, storage, refinement (updating, modification, processing), search, selection, extraction, use, examination, disclosure through transmission (distribution, provision, mailing or another way of providing access), grouping or combining, selecting, depersonalizing, blocking, deleting, erasing or destroying, as well as perform any other actions provided for applicable law using automation equipment, including information and telecommunication networks, or without using such equipment, if the processing of Personal Data without using such equipment corresponds to the nature of the actions performed with Personal Data using automation equipment, that is, it allows in accordance with a given algorithm to carry out search for Personal data recorded on a physical medium and contained in card catalogue or other systematic collections of Personal Data, and / or access to such Personal Data.

6.2. The User has the right to request the Operator to receive information regarding the processing or refinement of his Personal Data, restricting the processing of Personal Data, blocking or destroying (in the event that the Personal Data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated processing purpose). The request must contain the number of the main document proving the identity of the User or his representative, information on the date of issue of the specified document and the authority that issued it, information confirming the User’s relations with the Operator, or information that otherwise confirms the fact that the Operator processed Personal Data, the signature of the User or his representative. A written request can be sent to the address: 123112, Moscow, Presnenskaya embankment, house 8, building 1, floor 15, room 11f or to the email address: info@skylight.aero in the form of an electronic document and signed by electronic signature in accordance with the legislation of the Russian Federation. As part of the request received, the Operator takes appropriate measures and sends a response to the request within the time period established by the legislation of the Russian Federation.

6.3. Storage of Personal Data is carried out no longer than it is required by the purposes of Personal Data processing, if the storage period of Personal Data is not established by the legislation of the Russian Federation. Personal data is stored on the territory of the Russian Federation.

6.4. The processed Personal Data is subject to destruction or depersonalization upon achievement of the processing goals or in case of withdrawal of consent to the processing of Personal Data by the User, unless otherwise provided by the legislation of the Russian Federation.

7. Transfer of Personal Data

7.1. The User’s personal data may be transferred to authorized bodies of state power of the Russian Federation on the grounds and according to the procedure established by the legislation of the Russian Federation.

7.2. The Operator takes the necessary organizational and technical measures to protect the User’s Personal Data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution and other illegal actions of third parties.

7.3. Personal Data is not transferred to third parties, unless this transfer is necessary to fulfill obligations in accordance with the purposes specified in this Privacy Policy. The Operator has the right to entrust the processing of Personal Data to another person with the consent of the subject of Personal Data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. A person who processes Personal Data on behalf of the Operator is obliged to comply with the principles and rules for the Personal Data processing provided for by Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data” and this Privacy Policy.

8. Responsibility of the Parties

8.1. The Operator that has not fulfilled its obligations is liable for losses incurred by the User in connection with the unlawful use of Personal Data in accordance with the legislation of the Russian Federation, with the exception of cases provided for in paragraphs 7.1., 7.2. and 8.2. of this Privacy Policy.

8.2. In the event of loss or disclosure of Personal Data, the Operator shall not be liable if the Personal Data:

8.2.1. Became public property before their loss or disclosure.

8.2.2. Was received from a third party before it was received by the Operator.

8.2.3. Was disclosed with the consent of the User.

8.3. The Operator is not responsible for any direct or indirect losses resulting from:

- use or impossibility to use the Website, or separate services provided by the Website;

- unauthorized access to the communications of the User;

- statements or behavior of a third party on the Website.

9. Dispute Resolution

9.1. Before applying to the court with a claim for disputes arising from the relationship between the User and the Operator, it is mandatory to comply with the claim procedure for resolving the dispute.

9.2. The receiver of the claim within 30 calendar days from the date of receipt of the claim in writing or electronically notifies the party that sent the claim about the results of its consideration.

9.3. If the agreement is not reached, the dispute will be referred to the Moscow Arbitration Court.

9.4. The current legislation of the Russian Federation is applied to this Privacy Policy and the relationship between the User and the Operator.

10. Additional Terms and Conditions

10.1. The Operator has the right to make changes to this Privacy Policy without the consent of the User. The new version of the Privacy Policy comes into force from the date of its posting on the Website. The current edition is always on the webpage at www.skylight.aero.

10.2. All suggestions or questions regarding this Privacy Policy should be sent to the following address: 123112, Moscow, Presnenskaya embankment, house 8, building 1, floor 15, room 11f.

The User confirms that he is familiar with all the points of this Agreement and unconditionally accepts them.