This Privacy Policy (hereinafter – the "Privacy Policy") applies to all information that McBrothers AG (in the Russian Federation – "Mc Brothers" JSC), the owner of the website https://swissspinesolution.com, may obtain about the User during the use of the website and its files.

1. DEFINITION OF TERMS
1.1. The following terms are used in this Privacy Policy:
1.1.1. "Administration of the website https://swissspinesolution.com" (hereinafter – the "Website Administration") – authorized employees managing the website on behalf of "Mc Brothers" JSC, who organize and/or process personal data and determine the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
1.1.2. "Personal Data" – any information relating to a directly or indirectly identified or identifiable individual (data subject).
1.1.3. "Processing of Personal Data" – any action (operation) or set of actions (operations) performed with personal data, with or without automation tools, including collection, recording, systematization, accumulation, storage, updating, modification, retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data.
1.1.4. "Confidentiality of Personal Data" – a mandatory requirement for the Operator or any other person who has access to personal data to prevent their dissemination without the consent of the data subject or other legal grounds.
1.1.5. "Website User" (hereinafter – the "User") – an individual who has access to the Website via the Internet and uses the Website.
1.1.6. "Cookies" – a small piece of data sent by a web server and stored on the user's computer, which the web client or web browser sends back to the web server in an HTTP request when attempting to open a page of the corresponding website.
1.1.7. "IP Address" – a unique network address of a node in a computer network built using the IP protocol.

2. GENERAL PROVISIONS
2.1. The User’s use of the Website constitutes acceptance of this Privacy Policy and the terms of processing the User’s personal data.
2.2. If the User disagrees with the terms of the Privacy Policy, they must immediately stop using the Website.
2.3. This Privacy Policy applies only to the website https://swissspinesolution.com. The Company does not control and is not responsible for third-party websites that the User may access via links available on the Website.
2.4. The Website Administration does not verify the accuracy of the personal data provided by the User.

3. SUBJECT OF THE PRIVACY POLICY
3.1. This Privacy Policy establishes the obligations of the Website Administration regarding non-disclosure and ensuring the confidentiality of personal data that the User provides upon the Website Administration’s request when submitting inquiries, subscribing to newsletters, requesting a callback, etc.
3.2. Personal data permitted for processing under this Privacy Policy is provided by the User by filling out the relevant forms on the Website and may include:

• 3.2.1. The User’s surname, name, and patronymic;
• 3.2.2. The User’s contact phone number;
• 3.2.3. The User’s email address;
• 3.2.4. The name of the company represented by the User.

3.3. The Website protects data automatically transmitted during the viewing of ad blocks and when visiting pages with a statistical script ("pixel"):

• IP address;
• Information from cookies;
• Browser information (or other program accessing the ad);
• Access time;
• Address of the page containing the ad block;
• Referrer (address of the previous page).

3.3.1. Disabling cookies may result in the inability to access certain Website services.
3.3.2. The Website collects statistics on visitors’ IP addresses. This information is used to identify and resolve technical issues.
3.4. Any other personal information not specified above (e.g., browsing history, browsers and operating systems used, etc.) is securely stored and not disclosed, except as provided in Clauses 5.2 and 5.3 of this Privacy Policy.

4. PURPOSES OF COLLECTING USER PERSONAL DATA
4.1. The Website Administration may use the User’s personal data for the following purposes:

• 4.1.1. Establishing communication with the User, including sending notifications, inquiries, and information related to the use of the Website, service provision, and processing requests.
• 4.1.2. Verifying the accuracy and completeness of the personal data provided by the User.
• 4.1.3. Providing the User with effective customer and technical support in case of issues related to the Website.
• 4.1.4. Providing the User, with their consent, with updates, special offers, pricing information, newsletters, and other information from the Website or the Company’s partners.
• 4.1.5. Conducting advertising activities with the User’s consent.

5. METHODS AND TERMS OF PROCESSING PERSONAL DATA
5.1. The processing of the User’s personal data is carried out without a time limit, by any lawful means, including in personal data information systems with or without automation tools.
5.2. The User agrees that the Website Administration may transfer personal data to third parties (e.g., courier services, postal services, telecom operators) solely for fulfilling the User’s order placed on the Website, including product delivery.
5.3. The User’s personal data may be transferred to authorized state authorities of the Russian Federation only on the grounds and in the manner prescribed by Russian law.
5.4. In case of loss or disclosure of personal data, the Website Administration shall notify the User.
5.5. The Website Administration takes necessary organizational and technical measures to protect the User’s personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, or other unlawful actions by third parties.
5.6. The Website Administration and the User shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

6. OBLIGATIONS OF THE PARTIES
6.1. The User shall:

• 6.1.1. Provide accurate personal data required for using the Website.
• 6.1.2. Update or supplement provided personal data if changes occur.

6.2. The Website Administration shall:

• 6.2.1. Use the obtained information solely for the purposes specified in Clause 4 of this Privacy Policy.
• 6.2.2. Ensure the confidentiality of personal data, not disclosing it without the User’s prior written consent, except as provided in Clauses 5.2 and 5.3.
• 6.2.3. Implement precautions to protect the confidentiality of the User’s personal data in accordance with standard business practices.
• 6.2.4. Block personal data related to the User upon their request or the request of their legal representative or authorized data protection authority for verification in case of inaccurate data or unlawful actions.

7. LIABILITY OF THE PARTIES
7.1. The Website Administration shall be liable for damages incurred by the User due to unlawful use of personal data under Russian law, except as provided in Clauses 5.2, 5.3, and 7.2.
7.2. The Website Administration shall not be liable if the confidential information:

• 7.2.1. Became public before its loss or disclosure.
• 7.2.2. Was received from a third party before its acquisition by the Website Administration.
• 7.2.3. Was disclosed with the User’s consent.

8. DISPUTE RESOLUTION
8.1. Before filing a lawsuit, the parties must attempt to resolve disputes through a written claim (pre-trial settlement).
8.2. The recipient of the claim shall notify the claimant of the results within 30 calendar days of receipt.
8.3. If no agreement is reached, the dispute shall be referred to a court under Russian law.
8.4. This Privacy Policy and the relationship between the User and the Website Administration are governed by Russian law.

9. ADDITIONAL TERMS
9.1. The Website Administration may amend this Privacy Policy without the User’s consent.
9.2. The updated Privacy Policy takes effect upon publication on the Website unless otherwise stated.
9.3. All suggestions or questions regarding this Privacy Policy should be addressed to the Website Administration via the contacts provided on the Website.
9.4. The current Privacy Policy is available at: https://swissspinesolution.com