Privacy Policy regarding the processing of personal data

1. General Provisions

This personal data processing policy has been drafted in accordance with the requirements of Federal Law No. 152‑FZ dated July 27, 2006 “On Personal Data” (hereinafter – the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Limited Liability Company “Vostokpromresurs” (hereinafter – the Operator).

1.1. The Operator’s utmost goal and condition for carrying out its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors to the website перевозкагаз.рф/en.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of personal data processing (except where processing is necessary to clarify personal data).

2.3. Website – a collection of graphical and informational materials, as well as computer programs and databases that ensure their availability on the internet at the network address перевозкагаз.рф/en.

2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.

2.5. Depersonalisation of personal data – actions that make it impossible to determine the ownership of personal data to a specific User or other personal data subject without additional information.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without automation means on personal data, including collection, recording, systematisation, accumulation, storage, updating (refreshing, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, erasure, destruction of personal data.

2.7. Operator – a state body, municipal body, legal entity or individual, independently or jointly with others, organising and/or carrying out the processing of personal data, as well as determining the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.

2.8. Personal data – any information relating directly or indirectly to a specific or determinable User of the website перевозкагаз.рф/en.

2.9. Personal data permitted for dissemination by the personal data subject – personal data to which unlimited access has been granted by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter – personal data permitted for dissemination).

2.10. User – any visitor to the website перевозкагаз.рф/en.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including publication of personal data in the media, placement in information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross‑border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data – any actions that result in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or destruction of the physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right:
- to receive from the personal data subject reliable information and/or documents containing personal data;
- if the personal data subject withdraws consent to the processing of personal data, or sends a request to stop processing personal data, the Operator may continue processing personal data without the subject’s consent if there are grounds specified in the Personal Data Law;
- to independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for 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 is obliged:
- to provide the personal data subject, upon request, with information regarding the processing of his/her personal data;
- to organise the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- to respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- to provide the competent authority for the protection of the rights of personal data subjects with the necessary information within 10 days of receiving such a request from that authority;
- to publish or otherwise provide unrestricted access to this Policy on the processing of personal data;
- to take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful acts in respect of personal data;
- to stop transferring (distributing, providing, accessing) personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- to perform other duties provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right:
- to receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects unless there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- to require the Operator to update, block or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
- to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw consent to the processing of personal data and to submit a request to stop processing personal data;
- to appeal to the competent authority for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged:
- to provide the Operator with reliable information about themselves;
- to inform the Operator of the updating (refreshing, modification) of their personal data.

4.3. Persons who provide the Operator with false 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. Principles of Personal Data Processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. Merging databases containing personal data that are processed for purposes incompatible with each other is not permitted.

5.4. Only personal data that meet the purposes of their processing shall be processed.

5.5. The content and volume of the processed personal data correspond to the stated processing purposes. Redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.

5.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, where necessary, their relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalised upon achievement of the processing purposes or in the event of the loss of the need to achieve those purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: providing the User with access to services, information and/or materials contained on the website.

Personal data:
- surname, first name, patronymic
- email address
- phone numbers

Legal basis:
Federal Law “On Information, Information Technologies and Information Protection” No. 149‑FZ dated July 27, 2006

Types of personal data processing:
- Collection, recording, systematisation, accumulation, storage, destruction and depersonalisation of personal data
- Sending information emails to the email address

7. Conditions for Processing Personal Data

7.1. Personal data is processed with the consent of the personal data subject to the processing of his/her personal data.

7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.

7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing of personal data to which unlimited access has been granted by the personal data subject or at his/her request (hereinafter – publicly available personal data) is carried out.

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured by implementing legal, organisational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorised access to personal data by unauthorised persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.

8.3. If inaccuracies in the personal data are identified, the User may update them independently by sending a notification to the Operator’s email address vostokpromresurs.khv@gmail.com with the subject line “Updating of personal data”.

8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by contract or current legislation.
The User may at any time withdraw his/her consent to the processing of personal data by sending a notification by email to the Operator’s email address vostokpromresurs.khv@gmail.com with the subject line “Withdrawal of consent to personal data processing”.

8.5. All information collected by third‑party services, including payment systems, communication means and other service providers, is stored and processed by those persons (operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should familiarise themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

8.6. Prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing of personal data in state, public and other public interests determined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing, unless the storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor.

8.9. Grounds for terminating the processing of personal data may be: achievement of the purposes of processing, expiration of the period of consent, withdrawal of consent by the personal data subject or a request to stop processing, as well as detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Obtained

9.1. The Operator performs collection, recording, systematisation, accumulation, storage, updating (refreshing, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, erasure and destruction of personal data.

9.2. The Operator performs automated processing of personal data with or without the receipt and/or transmission of the received information over information and telecommunications networks.

10. Cross‑border Transfer of Personal Data

10.1. Before starting cross‑border transfer of personal data, the Operator must notify the competent authority for the protection of the rights of personal data subjects of its intention to carry out cross‑border transfer (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above‑mentioned notification, the Operator must obtain relevant information from foreign government authorities, foreign individuals, foreign legal entities to whom the cross‑border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarification on issues concerning the processing of his/her personal data by contacting the Operator via email at vostokpromresurs.khv@gmail.com.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the internet at перевозкагаз.рф/en-policy.
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