Website Privacy Notice
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1. About this document
This Website Privacy Notice («Notice») describes how and why we, Ozon Holdings PLC («We», «Us» or «Ozon»), collect, store, use, share and otherwise process your personal information when you visit or use https://ir.ozon.com/ («Website»). Further references in this Notice to «you» or «your» are references to any individual visiting or using the Website.
Please note that the Website is not intended for minors (under the age of 18) so We will not process any personal information related to them.
This Notice is designed to help you better understand the way We handle your personal information on the Website, what your privacy-related rights are and how you can control processing of your personal information in general.
When carrying out the activities described in this Notice, We act as the sole data controller. It means that We alone determine the exact purposes and means of processing of your personal information.
This Notice is drawn up in English, and any translation of it is made for reference only, meaning that the English version of the Notice will always prevail over any translation into other languages.
2. About processing of your personal information
This section’s purpose is to show you how and why exactly We process your personal information.
Personal information is any data relating to you either directly or indirectly and allowing to identify you as an individual. As it involves multitude of specific data about you (e.g. name, ID number, place where you live, telephone number, etc.) that are considered non-public and confidential by nature, you should be able to know and control how others use such data.
2.1 Direct data collection
Primarily We obtain personal information directly from you and not from other sources. Therefore, you are free to decide whether you want to share your personal information with Us or not. You are not obliged to provide Us with any personal information.
If you do share such information with Us, We will use it as described in the table below:
Category
Description
Purpose of processing
Storage period
Legal basis
for processing
Collected directly from you when you fill out the «Subscribe» form on the Website to sign up for investor news and alerts
Contact details
First name, last name and email
To properly address you and send you via email the specific types of investor news and alerts you decide to subscribe to (by choosing the respective options on the Website)
Until you decide to unsubscribe from investor news and alerts
Your consent (by clicking the «Subscribe» button on the Website)
Additional information on our current and/or potential investors
Country you are from and company you work for or are affiliated with
We use this information in an aggregated and/or statistical form for Ozon’s internal analytical purposes so We could build a profile of our current and/or potential investors and further improve our understanding of investors’ needs and interests
Until you decide to unsubscribe from investor news and alerts
Your consent (by clicking the «Subscribe» button on the Website)
Collected directly from you when you contact Us via the feedback form on the Website
Contact details
First name, last name and email
To properly address you and respond to the comments or questions you send Us
Until you object to this processing
Our legitimate interests, namely proper communication with you because We cannot answer without knowing the exact addressee
Any other personal information you submit to Us as a part of your feedback
To respond to your comments or questions when they also contain personal information
Until you object to this processing
Our legitimate interests, namely proper communication with you because such personal information is a part of your feedback and We need to process it to answer you substantively
Collected directly from you when you visit the «Convertible Bonds» section on the Website
Information on whether you are from the United States, Canada, South Africa, Australia or Japan
To ensure that no resident of these countries will receive the information contained in this section
Until you refresh or reopen the page on your device
Our legitimate interests, namely to ensure that We do not offer, solicit to buy or subscribe for, convertible bonds to any person in the specific jurisdictions to whom or in which such offer or solicitation is unlawful
Information on whether you are a qualified investor under applicable securities laws
To ensure that no unqualified investor will receive the information contained in this section
Until you refresh or reopen the page on your device
Our legitimate interests, namely to ensure that We do not offer, solicit to buy or subscribe for, convertible bonds to any unqualified investor to whom such offer or solicitation is unlawful
Collected directly from you when you visit the «Restructuring Documents» section on the Website
Information on whether you are a sanctioned person or from a sanctioned territory under EU and Cyprus sanctions laws
To ensure that no sanctioned person or resident of sanctioned territories under EU and Cyprus sanctions laws will receive the information contained in this section and engage in any transaction with Us
Until you refresh or reopen the page on your device
Legal obligations not to deal with any sanctioned person or resident of sanctioned territories in accordance with EU and Cyprus sanctions laws to which We are subject as a Cyprus legal entity
Information on whether you are a sanctioned person or from a sanctioned territory under applicable non-EU sanctions laws
To ensure that no sanctioned person or resident of sanctioned territories under applicable non-EU sanctions laws will receive the information contained in this section and engage in any transaction with Us
Until you refresh or reopen the page on your device
Our legitimate interests, namely to ensure that We do not deal with any sanctioned person or resident of sanctioned territories in accordance with sanctions laws of non-EU countries where We engage in commercial activity or otherwise operate
Please note that We do not process your personal information for direct marketing purposes and do not rely on automated decision-making.
2.2 Automatic data collection
In some cases (as described in the table below) We obtain your personal information automatically via such data collection technologies as cookies that We use on the Website.
What are cookies? Cookies are small files containing some information and placed on your device (PC, smartphone, etc.) when you browse the web. Therefore, your device may store various cookies.
Why are cookies important? Because they allow a website to recognize users’ devices, preferences, gather statistics on how users interact with that website in order to help to improve online experience or deal with various errors or bugs, which occasionally occur. Naturally, these purposes are not exhaustive and may vary as they depend on a particular website you visit.
As cookies typically include a wealth of data, sometimes enough to potentially identify websites’ users without their permission, you may want to know what cookies are saved in your device.
When you visit the Website, Ozon or its trusted service providers set the following cookies on your device:
Category
Description and
purpose
Storage period
Legal basis for
processing
Technical cookies
These cookies are essential for the operation of the Website.
Technical cookies allow you to navigate through the Website, browse its various sections, fill out the forms and check the boxes there.
We need to use these cookies because without them the Website cannot function properly. Technical Cookies are always active on the Website and cannot be disabled
No longer than 10 years
Our legitimate interests, namely proper functioning of the Website because We want to provide you with constant, uninterruptible and error-free access to the Website and to enable the smooth operation of the Website in general
3. About transfer of your personal information
In the course of the activities described in this Notice We share your personal information with the following categories of recipients:
Ozon’s affiliates and subsidiaries; and
Third-party contractors We, our affiliates or subsidiaries use to maintain the Website, manage your personal information and facilitate communication with you, such as hosting providers, owners of customer data platforms (CDPs), mailing services providers, contact centers, etc.
We always ensure that such recipients adhere to privacy standards at least as protective as in this Notice and are subject to the strictest confidentiality obligations.
If such recipients are located outside the European Economic Area (EEA), We share your personal information only when:
Recipient’s country has an adequate level of privacy protection (no less than in the EEA); or
We use additional protective measures to secure your personal information and mitigate any potential risks associated with this transfer from the EEA. All our contracts with the non-EEA recipients of your personal information always include Standard Contractual Clauses supported by other legal, organizational and technical measures We take. These measures are encryption, pseudonymization, other appropriate security controls, as well as internal policies and procedures necessary to implement best privacy standards, etc. Send Us a request to privacy@ozon.com to receive a copy of these Standard Contractual Clauses or to know more about the other safeguards We use.
4. About your privacy-related rights
This section describes in detail what rights you have and how you can exercise such rights.
Right to
Description
How to exercise
Access
You have the right to know how We process your personal information and ask Us to send you a copy of such information
Refer to this Notice to know about your personal information processing; and
Send Us a request to privacy@ozon.com to receive a copy of your personal information
Rectification
You have the right to ask Us to correct, update or complete your personal information if you believe such information is incorrect, outdated or incomplete
Send Us a request to
privacy@ozon.comErasure
You have the right to ask Us to delete your personal information
Send Us a request to
privacy@ozon.comObjection to processing
You have the right to object to processing of your personal information by Ozon on grounds relating to your particular situation.
This right only applies when legal basis for such processing is Ozon’s legitimate interests (to know more about legal basis refer to the section «About processing of your personal information» above)
Send Us a request to
privacy@ozon.comRestriction of processing
You have the right to ask Us to cease processing of your personal information when:
• You contest accuracy of your personal information — for a time We check accuracy of such information;
• You believe that processing of your personal information is unlawful but you do not want Us to delete such information;
• We want to delete your personal information but you ask Us to keep it for establishment, exercise or defence of legal claims;
• You object to processing — for a time We decide whether We can keep your personal information or not
Send Us a request to
privacy@ozon.comData portability
You have the right to ask Us to prepare a copy of your personal information in electronic form and transmit it to a specific third party to be further used there.
This right only applies when legal basis for processing of your personal information is consent (to know more about legal basis refer to the section «About processing of your personal information» above)
Send Us a request to
privacy@ozon.comWithdraw consent
You have the right to withdraw consent at any time when We rely on it as a legal basis for processing (to know more about legal basis refer to the section «About processing of your personal information» above).
If you decide to exercise this right, We will delete your personal information accordingly
Click the dedicated button (e.g. to «unsubscribe click here») at the bottom of an email for investor news and alerts you receive from Us;
or
send Us a request to privacy@ozon.com
Lodge a complaint
If you believe that We somehow violate your privacy rights, you can address your concerns to the Cyprus Commissioner for Personal Data Protection or your local data protection authority
Send a complaint to the Cyprus Commissioner for Personal Data Protection or your local data protection authority in the form admissible by them
5. Changes to this Notice
We will update this Notice from time to time and its latest effective date will always be indicated at the bottom of this Notice. Even if you frequently visit the Website, We still advise you to consult this page once in a while to see what is changed.
6. Contact Us
Ozon Holdings PLC is a legal entity established and operating under the laws of the Republic of Cyprus with a registered office at Arch. Makariou III, 9th Floor 2-4, Capital Center, Nicosia 1065, Republic of Cyprus.
Our email for all privacy-related issues: privacy@ozon.com
Effective date 16.11.2022
