Personal Data Processing Policy

1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and establishes the procedures for processing personal data and the measures taken by the website (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator considers respect for human and civil rights and freedoms when processing personal data, including the protection of privacy and personal and family confidentiality, to be its principal objective and a condition of its activities.
1.2. This policy of the Operator concerning the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website.
2. Key terms used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computing equipment.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where processing is necessary to clarify personal data.
2.3. Website means a collection of graphic and informational materials, computer programs and databases that make those materials accessible on the internet at a network address.
2.4. Personal data information system means the personal data contained in databases together with the information technologies and technical facilities that enable their processing.
2.5. Anonymisation of personal data means actions that make it impossible, without additional information, to determine whether personal data belong to a particular User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data, with or without automated means, including collection, recording, organisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymisation, blocking, deletion and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of processing, the personal data to be processed and the actions (operations) performed on personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website.
2.9. Personal data authorised by the personal data subject for dissemination means personal data to which the personal data subject has granted access to an unlimited number of persons by consenting to the processing of personal data authorised for dissemination, in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data authorised for dissemination).
2.10. User means any visitor to the website.
2.11. Provision of personal data means actions aimed at disclosing personal data to a particular person or a defined group of persons.
2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an undefined group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in the mass media, their placement in information and telecommunications networks or the provision of access to personal data by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in personal data being irretrievably destroyed, making it impossible to subsequently restore the content of the personal data in a personal data information system, and/or the destruction of physical media containing personal data.
3. Principal rights and duties of the Operator
3.1. The Operator has the right to:
– obtain accurate information and/or documents containing personal data from the personal data subject;
– continue processing personal data without the consent of the personal data subject if that subject withdraws consent, where grounds specified in the Personal Data Law apply;
– independently determine the composition and scope of the measures necessary and sufficient to fulfil the duties imposed by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator must:
– provide the personal data subject, at their request, with information concerning the processing of their personal data;
– organise the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
– respond to enquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide the authorised body for the protection of the rights of personal data subjects with the necessary information at that body’s request within 30 days of receiving the request;
– publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
– take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision and dissemination, as well as against other unlawful actions involving personal data;
– cease the transfer (dissemination, provision, access) and processing of personal data and destroy personal data in the manner and circumstances specified in the Personal Data Law;
– fulfil other duties specified in the Personal Data Law.
4. Principal rights and duties of personal data subjects
4.1. Personal data subjects have the right to:
– obtain information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator must provide the information to the personal data subject in an accessible form, and it must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The scope of the information and the procedure for obtaining it are established by the Personal Data Law;
– require the Operator to clarify, block or destroy their personal data if the data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take the measures provided for by law to protect their rights;
– require prior consent as a condition for processing personal data for the purpose of promoting goods, work and services on the market;
– withdraw consent to the processing of personal data;
– appeal unlawful actions or omissions by the Operator in processing their personal data to the authorised body for the protection of the rights of personal data subjects or through the courts;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects must:
– provide the Operator with accurate information about themselves;
– notify the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, are liable in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User
5.1. Surname, first name and patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. The website also collects and processes anonymised visitor data, including cookies, through web analytics services such as Yandex Metrica, Google Analytics and others.
5.5. The data listed above are collectively referred to as Personal Data throughout this Policy.
5.6. The Operator does not process special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data authorised for dissemination that fall within the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions established by Article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data authorised for dissemination is given separately from other consents to the processing of their personal data. The conditions established, in particular, by Article 10.1 of the Personal Data Law must be observed. Requirements for the content of such consent are established by the authorised body for the protection of the rights of personal data subjects.
5.8.1 The User provides consent to the processing of personal data authorised for dissemination directly to the Operator.
5.8.2 No later than three working days after receiving that consent from the User, the Operator must publish information about the conditions of processing and about any prohibitions and conditions concerning the processing by an unlimited number of persons of personal data authorised for dissemination.
5.8.3 The transfer (dissemination, provision, access) of personal data authorised by the personal data subject for dissemination must cease at any time at the request of the personal data subject. This request must include the personal data subject’s surname, first name, patronymic (if any) and contact details (telephone number, email address or postal address), as well as a list of the personal data whose processing must cease. The personal data specified in this request may be processed only by the Operator to whom the request is addressed.
5.8.4 Consent to the processing of personal data authorised for dissemination ceases to apply when the Operator receives the request specified in clause 5.8.3 of this Personal Data Processing Policy.
6. Principles of personal data processing
6.1. Personal data are processed lawfully and fairly.
6.2. The processing of personal data is limited to achieving specific, predetermined and lawful purposes. The processing of personal data that is incompatible with the purposes for which the data were collected is not permitted.
6.3. Databases containing personal data processed for mutually incompatible purposes must not be combined.
6.4. Only personal data that serve the purposes of their processing may be processed.
6.5. The content and volume of the personal data processed must correspond to the stated purposes of processing. The processing of personal data in excess of what is necessary for the stated purposes is not permitted.
6.6. When personal data are processed, their accuracy and sufficiency, and where necessary their relevance to the purposes of processing, must be ensured. The Operator takes the necessary measures and/or ensures that such measures are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data are stored in a form that allows the personal data subject to be identified for no longer than is required by the purposes of processing, unless the retention period is established by a federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Personal data being processed are destroyed or anonymised once the purposes of processing have been achieved or are no longer necessary, unless otherwise provided by federal law.
7. Purposes of personal data processing
7.1. The purposes of processing the User’s personal data are:
– informing the User by sending emails;
– concluding, performing and terminating civil-law contracts;
– providing the User with access to services, information and/or materials available on the website.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may always opt out of receiving informational messages by emailing the Operator at the email address with the subject line “Opt out of notifications about new products and services and special offers”.
7.3. Anonymised User data collected through web analytics services are used to gather information about Users’ actions on the website and to improve the quality of the website and its content.
8. Legal grounds for processing personal data
8.1. The legal grounds on which the Operator processes personal data are:
– list the regulatory legal acts governing relations connected with your activities; for example, if your activities involve information technology, particularly website creation, you may specify here Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and the Protection of Information”;
– the Operator’s constitutional documents;
– contracts concluded between the Operator and the personal data subject;
– federal laws and other regulatory legal acts concerning personal data protection;
– Users’ consent to the processing of their personal data and to the processing of personal data authorised for dissemination.
8.2. The Operator processes the User’s personal data only when the User independently enters and/or submits those data through special forms on the website or sends them to the Operator by email. By completing the relevant forms and/or sending their personal data to the Operator, the User expresses their agreement with this Policy.
8.3. The Operator processes anonymised data about the User if this is permitted by the User’s browser settings, with the storage of cookies and the use of JavaScript enabled.
8.4. The personal data subject independently decides whether to provide their personal data and gives consent freely, of their own will and in their own interests.
9. Conditions for personal data processing
9.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official that must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary to perform a contract to which the personal data subject is a party, beneficiary or guarantor, or to conclude a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve purposes of public importance, provided that the rights and freedoms of the personal data subject are not infringed.
9.6. Personal data to which the personal data subject has granted access to an unlimited number of persons, or to which access has been granted at their request, are processed (hereinafter referred to as publicly available personal data).
9.7. Personal data that must be published or mandatorily disclosed in accordance with federal law are processed.
10. Procedures for collecting, storing, transferring and otherwise processing personal data
The security of personal data processed by the Operator is ensured through the implementation of the legal, organisational and technical measures necessary to comply fully with the requirements of current legislation concerning personal data protection.
10.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorised persons from accessing them.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where required to comply with current legislation or where the personal data subject has consented to the Operator transferring the data to a third party in order to fulfil obligations under a civil-law contract.
10.3. If inaccuracies are identified in their personal data, the User may update the data by sending a notification to the Operator’s email address with the subject line “Personal data update”.
10.4. The duration of personal data processing is determined by the achievement of the purposes for which the data were collected, unless a different period is provided for by a contract or by current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator’s email address with the subject line “Withdrawal of consent to the processing of personal data”.
10.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently familiarise themselves with those documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
10.6. Prohibitions imposed by the personal data subject on the transfer (other than the provision of access), processing or conditions of processing (other than obtaining access) of personal data authorised for dissemination do not apply where personal data are processed in the interests of the state, society or other public interests defined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data when processing them.
10.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than is required by the purposes of processing, unless the retention period is established by a federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
10.9. The processing of personal data may cease when the purposes of processing have been achieved, when the personal data subject’s consent expires or is withdrawn, or when unlawful processing of personal data is identified.
11. Actions performed by the Operator on the personal data received
11.1. The Operator collects, records, organises, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), anonymises, blocks, deletes and destroys personal data.
11.2. The Operator carries out automated processing of personal data, with or without receiving and/or transferring the information obtained over information and telecommunications networks.
12. Cross-border transfer of personal data
12.1. Before beginning a cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data are to be transferred provides reliable protection for the rights of personal data subjects.
12.2. Personal data may be transferred across borders to foreign states that do not meet the above requirements only where the personal data subject has given written consent to the cross-border transfer of their personal data and/or where a contract to which the personal data subject is a party is being performed.
13. Confidentiality of personal data
The Operator and other persons who obtain access to personal data must not disclose the data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final provisions
14.1. The User may obtain explanations on any questions concerning the processing of their personal data by contacting the Operator by email.
14.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the internet at /en/privacy-policy.html.