Privacy Policy

Effective date June 27, 2024

1. What is this document about? #

The purpose of the Privacy Policy (the “Policy”) is to explain the procedure and conditions for processing your personal data when you visit websites or use online services that are respectively owned by us or provided by us (hereinafter collectively referred to as the “Ozon Services”).

Unless it contradicts the laws on personal data applicable to our relationship (the “Applicable Laws”), this Policy also constitutes a consent of a personal data subject to processing, including collection, of personal data.

We may update the Policy from time to time without explicitly notifying you thereof, and its current version effective date will always be indicated directly under the heading. We recommend that you review this page from time to time to keep track of possible changes.

2. What are personal data and processing thereof? #

Personal data (personal information, personal data, personal information, etc.) is any information that directly or indirectly relates to you as an individual and a user of the Ozon Services. Although in some cases the Applicable Laws may clarify this concept, thus narrowing or expanding it with respect to certain data categories (for example, with respect to technical information on user devices), we will anyway adhere to the widest possible approach in determining which data should be considered personal.

Processing of personal data means any actions (operations) with personal data, including collection, accumulation, storage, modification, supplementing, use, transfer (distribution, provision, accessing) to third parties, blocking, deletion, and destruction thereof.

At the same time, any specific actions (operations) performed by us with your personal data depend on the Ozon Service used and are communicated to you before processing with the help of relevant legal documents (offers, terms of use, etc.) or user interface elements (for example, a form to fill out inside the Ozon Service means that we carry out collection of your personal data).

3. Who processes your personal data? #

Ozon means a collective name for a group of companies that provide you with the relevant Ozon Services. It means that a specific person (company) on the Ozon side processing your personal data is determined depending on who provides you with a specific Ozon Service.

Unless otherwise explicitly stated in the Policy, the relevant Ozon company is an operator, i.e., a person that independently arranges for and/or processes your personal data, as well as determines purposes of personal data processing, a composition of personal data being processed and specific actions (operations) with such personal data.

You can independently determine who is the operator by referring to the text of the relevant legal document (offer, terms of use, etc.) of such an Ozon Service or user interface, for example, the bottom (“foot”) of our websites contains information regarding which of the Ozon companies is involved in administration thereof.

Ozon ID is a single sign-on technology

In some Ozon Services that provide for user pre-authorization, we use a single sign-on technology, i.e., an Ozon ID, owned by Internet Solutions LLC. It means that when you log in to any Ozon Service using an Ozon ID, your personal data operator is at least Internet Solutions LLC as an Ozon ID owner. The terms of use of the Ozon ID can be reviewed here.

If the corresponding Ozon Service that you log in using your Ozon ID does not belong to Internet Solutions LLC, but to another Ozon company, such another Ozon company will also be the operator of your personal data in terms of providing you with its Ozon Service. The list of Ozon companies using the Ozon ID as an authorization method in their Ozon Services can be reviewed here (see “Affiliates”).

Ozon Services

In particular, unless otherwise explicitly provided for by legal documents or the user interface, the following Ozon companies may act as your personal data operators:

We may from time to time launch new Ozon Services, including offering new marketplaces on the territory of other countries. In this case, Ozon companies from such other countries will act as your personal data operators, unless otherwise explicitly provided by legal documents or the user interface.

Vacancies and other collaboration offers

When you respond to the Ozon vacancies or other Ozon collaboration offers intended for persons located in Russia, your personal data are processed by Internet Solutions LLC as the parent company of Ozon in order to administer the function of staff recruitment and partner selection. At the same time, Internet Solutions LLC has the right to transfer personal data indicated by you when responding to a vacancy or a collaboration offer to that Ozon company that plans to conclude a corresponding contract with you. If such an Ozon company concludes a contract with you, it will also process your personal data.

When you respond to Ozon vacancies or other Ozon collaboration offers intended for persons located outside Russia, your personal data are processed accordingly by those Ozon companies that plan to conclude a corresponding contract with you. Such Ozon companies have the right to transfer personal data provided by you when responding to a vacancy or a collaboration offer to Internet Solutions LLC as the parent company of Ozon, which will process such personal data in order to administer the function of staff recruitment and partner selection.

Independent operators

Please note that Ozon companies are independent operators in relation to each other, i.e., if you send any personal data requirements to Ozon, you should specify which of the operators such requirements are addressed to.

In particular, if your personal data are processed by several operators and you send a corresponding request to only one operator, other operators will not perform any actions in accordance with such a request, since they are not addressed to them. If you want several operators to fulfill your requirements at once, you need to address such requirements to each operator.

To contact the relevant operator, use contacts specified in the personal data processing policy of such an operator (see “Rights of Personal Data Subjects”).

4. How does this Policy relate to other personal data documents? #

The Policy is applied in conjunction with other legal documents of Ozon in the field of personal data (for example, policies regarding processing of personal data, offers containing conditions related to personal data, etc.).

Unless otherwise explicitly provided for in this Policy, other legal documents of Ozon in the field of personal data, or the Applicable Law, the Policy is of a special nature in relation to such legal documents. It means that, as a general rule, this Policy will prevail in the event of contradictions.

All matters not covered by this Policy shall be governed by the relevant legal documents of Ozon in the field of personal data, including policies regarding processing of personal data adopted by the relevant Ozon companies providing the Ozon Services, links to which are indicated in the previous section of the Policy.

5. Who do we share your personal data with? #

Inside Ozon

We share your personal data with Ozon companies when it is necessary to provide you with the Ozon Services, including to improve the user experience and quality of using such Ozon Services. Some functions related to the provision of the Ozon Services to you (for example, in terms of hosting the infrastructure of the Ozon Services or technical support thereof) may also be delegated to individual Ozon companies. It means that such Ozon companies will have access to your personal data when they perform their respective functions.

Beyond Ozon

We transfer your personal data outside Ozon in the following cases:

• as part of conclusion and performance of various contracts with you, including the terms of use of certain Ozon Services;
• to comply with the provisions of laws that apply to the relevant Ozon company and that require it to disclose personal data as part of a certain exchange (for example, at the request of tax authorities or a court);
• according to your consent;
• if there are other legal grounds in accordance with the Applicable Law.

Categories of recipients of your personal data

The persons outside Ozon that we transfer personal data to, depending on the specific circumstances and the Ozon Services used by you, include banks that accept payments on our websites and in mobile applications, postal operators that deliver orders in accordance with their rules, sellers on our marketplaces that we transfer your contact details to for processing and delivery of orders, government agencies requesting personal data within their competence, etc. Such persons do not process personal data on behalf or for the benefit of Ozon, since they have their own purpose and legal grounds for such processing (for example, acquiring banks accept payments in accordance with the requirements of banking laws, and Ozon has no right to interfere in their activities).

When you initiate a chargeback dispute, we will also provide information related to the disputed order and the circumstances surrounding the order to the acquiring bank that processed the transaction. To ensure that comprehensive and objective examination of evidence is possible, as well as to exercise the rights and legitimate interests of Ozon, consumers and sellers, Ozon stores relevant information within the limitation period.

We may also transfer your contact information to our partners (mobile network operators, owners of social networks, messengers providers, as well as other providers of communication channels) — this is necessary for timely sending you information messages through such partners regarding your use of Ozon services. For example, as soon as the order is available for pickup, we will send you a corresponding message about this on the VK social network if you are a VK user.

You have also agreed that we have the right to entrust processing of your personal data to one or more Ozon companies or other third parties under contracts concluded with them. It means that the relevant Ozon company delegates a part of its functions to a certain person that at the same time acts on behalf or for the benefit of such an Ozon company.

In particular, we engage persons outside Ozon on the basis of instructions when we do not have the necessary level of knowledge or resources to achieve the appropriate result (for example, when we need additional computing power to operate the Ozon Services, we can lease dedicated servers from a third party in the absence of our own servers) or when it is more efficient for us in terms of our own labor costs and quality of activity to outsource individual functions. Such persons include, for example, hosting service providers (hosting providers), contact center service providers, agency order pick-up points, and couriers.

If you have agreed to receive advertising, we also have the right to transfer your data to third parties (for example, advertising networks) in order to personalize the advertising sent/shown to you, evaluate the effectiveness of such advertising, improve the user experience and quality of using the Ozon Services.

When it is necessary to protect and/or exercise our rights and legitimate interests, we may use third-party services and involve third parties to verify your personal data by sharing such information with them. In this way, for example, we identify and eliminate financial and legal risks, combat fraudulent or other unfair behavior of users of the Ozon Services and prevent information security threats that may arise in relation to the Ozon Services.

Depending on the specific circumstances and the Ozon Services used by you, we may conduct international transfer of the data, i.e. out of the country you are located in. For example, this is the case when you pay for the orders on our marketplaces with the cards of foreign payment service providers or when when you order delivery outside of the country where you are located in.

6. Where do we get your personal data from? #

Directly from you

When you use the Ozon Services, we primarily receive personal data directly from you and not from other sources. Therefore, you have the right to decide whether you want to share your personal data with us.

For example, you can provide us with access to your location (geolocation) in order to get a more personalized experience of using certain Ozon Services (for example, to determine the order pick-up point closest to you), however, refusal to provide such access does not deprive you of the opportunity to use the corresponding Ozon Service.

You are not obliged to provide us with any personal data if:

• it is not required by law (for example, when we need to identify you as a customer of a credit institution or to communicate your data as a seller on the marketplace to consumers); or
• it is not required to use the Ozon Services for their functional purpose (for example, we need a phone number to authorize a user through the Ozon ID, and your address is for courier delivery of orders).

However, if you decide to provide personal data, then you guarantee to us that such data are accurate, complete, reliable, and up-to-date. Unless otherwise explicitly provided for by the Applicable Law, Ozon does not assume any obligations to you to verify the accuracy, completeness, reliability, and relevance of the data provided.

By providing any third-party personal data, you also guarantee to us that there is a valid consent of such a person to transfer their personal data to Ozon and to subsequent processing thereof by Ozon.

From third parties

If explicitly provided for by legal documents or the user interface, we receive your personal data from third parties.

In particular, in some Ozon Services, users may be offered an option to simplify filling in of their data in various forms and questionnaires by obtaining the required information from a third-party source and without the need for manual filling in thereof. You can always opt out of this option and enter the relevant data yourself.

When you log in to any Ozon Service using your Ozon ID, the relevant Ozon company will receive data contained in the Ozon ID from Internet Solutions LLC to provide you with such an Ozon Service.

If you have agreed to receive advertising, we also have the right to receive your data from other sources in order to personalize the advertising sent/shown to you, evaluate the effectiveness of such advertising, improve the user experience and quality of using such Ozon Services.

When it is necessary to protect and/or exercise our rights and legitimate interests, we may use third-party services and involve third parties to receive your personal data. In this way, for example, we identify and eliminate financial and legal risks, combat fraudulent or other unfair behavior of users of the Ozon Services and prevent information security threats that may arise in relation to the Ozon Services.

By means of metric programs

In some cases, as described below, we receive your personal data automatically using metric programs as part of individual Ozon Services. We use cookies to handle such data.

Cookies are small files containing some information that are uploaded to your device (PC, smartphone, etc.) while browsing a web page. Therefore, your device may store various cookies.

Cookies allow websites (applications) to recognize user devices, identify user preferences, as well as collect statistics on how users interact with websites (applications) to improve the experience of using such a website (an application) or to eliminate various errors or bugs that may occur from time to time. At the same time, the list of purposes for which the use of cookies is necessary is not exhaustive and depends on the specific website (application) visited or otherwise employed by the user.

For the purposes of the Policy, cookies also mean similar technologies such as web trackers, pixels, etc. We never use cookies to establish your identity as a specific user of the Ozon Services.

In particular, we use the following cookies:

You can limit or completely disable installation of cookies by yourself at any time through the settings of your web browser. To learn how to do this, use the following links:

• Internet Explorer
• Microsoft Edge
• Safari
• Google Chrome
• Firefox

Please note that without technical cookies the Ozon Services may not function correctly, and some of their functionality, including basic, may not be available.

If you use our mobile applications to access the Ozon Services, you may, through the user interface of such applications, allow us to collect information about how you use third-party mobile applications installed on your device. We will use the information we receive to analyze your preferences, collect analytics, and for marketing purposes as described in the table above. You can always prevent our mobile applications from accessing such information by selecting the appropriate settings on your device.

Our mobile applications may use third-party code (for example, in the form of external SDKs or libraries) to provide relevant functionality (for example, the ability to make payments in the application, but using third-party services). That being the case, your data will also be processed for this purpose.