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Personal data processing policy

This is a translation for your convenience: if it differs from the Russian version of this page, the Russian version prevails.

1. General provisions

  • This Policy sets out the procedure for processing personal data and the measures for ensuring its security, in order to protect the rights and freedoms of individuals and citizens when their personal data is processed.
  • The Company's personal data processing policy has been developed in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
  • This Policy is a public document that reflects the Company's views on processing information containing citizens' personal data. The Policy is published on the Company's corporate website in accordance with Part 2 of Article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
  • The Policy is binding on all Company employees who have access to information containing personal data, and on persons working with information belonging to the Company under agreements and contracts.
  • The Policy applies to all personal data of data subjects processed in the Company's information system using automated means.
  • The Company and other persons who have gained access to personal data must keep it confidential, namely not disclose (provide) it to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by federal law.

2. Principles and conditions of personal data processing

  • The Company processes personal data on the basis of the following principles:
    • lawfulness and fairness;
    • limiting the processing of personal data to the achievement of specific, predefined and legitimate purposes;
    • not processing personal data in a way incompatible with the purposes for which it was collected;
    • not merging databases containing personal data processed for purposes incompatible with each other;
    • processing only the personal data that meets the purposes of processing;
    • keeping the content and volume of processed personal data in line with the stated purposes of processing;
    • not processing personal data that is excessive for the stated purposes of processing;
    • ensuring that personal data is accurate, sufficient and up to date for the purposes of processing;
    • destroying or anonymizing personal data once the purposes of processing have been achieved or are no longer needed, or if the Company cannot remedy violations involving personal data, unless otherwise provided by federal law.
  • The Company processes personal data only with the consent of the personal data subject to the processing of their personal data.
  • The Company does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, health or intimate life.
  • The Company may entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of an agreement with that person. A person processing personal data on behalf of the Company must comply with the principles and rules for processing personal data set out in Federal Law No. 152-FZ.

3. Rights of the personal data subject

  • The personal data subject decides to provide their personal data and consents to its processing freely, of their own will and in their own interest. Consent to the processing of personal data may be given by the personal data subject or their representative in any form that allows its receipt to be confirmed, unless otherwise established by federal law.
  • The personal data subject has the right to receive information about the processing of their personal data, unless this right is limited in accordance with federal laws. The personal data subject may require the Company to correct, block or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and may take measures provided for by law to protect their rights.
  • Processing of personal data for the purpose of promoting goods, works and services on the market through direct contact with a potential consumer by means of communication, and for the purpose of political campaigning, is allowed only with the prior consent of the personal data subject. Such processing is deemed to be carried out without the prior consent of the personal data subject unless the Company proves that such consent was obtained.
  • The Company must immediately stop processing the personal data of the personal data subject for the above purposes at their request.

4. Ensuring the security of personal data

  • The goals of information security are to minimize the damage from information security threats and to improve the Company's business reputation and corporate culture.
  • Information is an important asset of the Company, and protecting it is the duty of every employee authorized to process it.
  • Protecting information containing personal data means preserving its confidentiality, integrity and availability.
  • The security of personal data processed by the Company is ensured by legal, organizational, technical and software measures that are necessary and sufficient to meet the requirements of federal legislation on personal data protection.
  • Access to information containing personal data is granted only to persons who need it to perform their job or contractual duties, and only to the minimum extent necessary.
  • For each information resource, a responsible person is appointed who is in charge of granting access to it and of the effective operation of information protection measures.
  • The Company has developed and approved a set of documents on personal data protection.
  • The Company reviews its personal data protection measures every year.

5. Use of cookies and tracking technologies

  • The Company's website uses cookies and similar technologies (localStorage) to run the service, save user preferences and analyze how the site is used.
  • Analytics cookies (Google Analytics, Yandex Metrica) are loaded only with the user's explicit consent, given through the cookie banner on the first visit to the site.
  • Details on the types of cookies used, their purposes and how to manage them are available in the Cookie Policy.

6. Final provisions

  • Other rights and obligations of the Company as a personal data operator are determined by the legislation of the Russian Federation on personal data.
  • Company officials found guilty of violating the rules on the processing and protection of personal data bear personal liability in the manner established by federal laws.