Privacy policy

1 INTRODUCTION

1.1 This document hereby determines the policy of JSC Uraltrubprom (hereinafter referred to as the Company) with respect to personal data processing (hereinafter referred to as PDP).

1.2 This Policy was developed as per the existing Russian Federation legislation on personal data.

1.3 This Policy shall apply to all processes of the acquisition, recording, systematization, storage, specification, extraction, use, transmission (distribution, submission and access), depersonalization, blocking, deletion and destruction of personal data using and without using automation means.

1.4. Personal data means shall include but not be limited to: name and surname, phone number, email address, place of work of the personal data subject.

1.5. The Personal Data Operator shall be entitled to use personal data by any legal means directly specified in this Policy, including:

1.5.1. sending promotional mail to the subject

1.5.2. sending informational mail to the subject

1.5.3. sending notifications to the subject

1.5.4. transferring the subject’s personal data to third parties for the purpose of improving the quality of use of the operator’s site

1.5.5. using and transferring to third-party operators the subject’s personal data for the purpose of retargeting and contextual and targeted advertising

1.5.6. using the subject’s personal data to collect statistical data and site traffic metrics, including using and transmitting data to the following operators:

a) Yandex LLC (Privacy Policy https://yandex.ru/legal/confidential/)

b) Google (Privacy Policy https://policies.google.com/privacy?hl=en&gl=ru#intro)

c) Vkontakte (privacy policy https://vk.com/privacy)

d) Facebook (privacy policy https://www.facebook.com/privacy/explanation)

e) Jivosite (Privacy Policy https://www.jivosite.ru/files/personal_data_processing_policy.pdf)


2 PRINCIPLES OF PERSONAL DATA PROCESSING

Personal data shall be processed based on the following principles:

1) Personal data shall be processed on a legal and fair basis;

2) Personal data processing shall be limited to the fulfillment of specific, predetermined and legal purposes. Personal data processing that shall be incompatible with personal data acquisition purposes shall be prohibited;

3) The merging of databases containing personal data that shall be processed for incompatible purposes shall be prohibited;

4) Only personal data that shall be compatible with its processing purposes shall be processed;

5) The content and scope of processed personal data shall meet its declared processing purposes. Processed personal data shall not be redundant with respect to its declared processing purposes;

6) During personal data processing, personal data accuracy, adequacy and, where required, relevance with respect to the declared processing purposes shall be provided for.

7) Personal data shall be stored in a form that shall allow determining the personal data subject not longer than is required for personal data processing purposes, where the period of personal data storage shall not be established by federal law or agreement to which the personal data subject shall be a party, beneficiary or guarantor. Processed personal data shall be subject to destruction or depersonalization upon fulfillment of the processing purposes or in case of loss of necessity to fulfill these purposes, if not otherwise specified by federal law.


3 CONDITIONS OF PERSONAL DATA PROCESSING

3.1 Personal data shall be processed in compliance with the principles and rules established by the Federal Law – Concerning Personal Data. Personal data shall be processed in the following cases:

1) Personal data shall be processed with the consent of the personal data subject to the processing of his / her personal data;

2) Personal data processing shall be required for the fulfillment of purposes provided for a Russian Federation international agreement or law for the fulfillment and execution of the functions, powers and duties imposed on the Operator by the Russian Federation legislation;

3) Personal data processing shall be required for the administration of justice, execution of a court ruling or ruling of another body or official subject to execution as per the Russian Federation legislation on enforcement proceedings;

4) Personal data processing shall be required for the execution of an agreement to which the personal data subject shall be a party, beneficiary or guarantor, as well as for signing an agreement upon the initiative of the personal data subject or an agreement according to which the personal data subject shall be a beneficiary or guarantor;

5) Personal data processing shall be required for the protection of the life, health or other vital interests of the personal data subject, where obtaining the consent of the personal data subject shall be impossible;

6) Personal data processing shall be required for the exercise of the rights and legal interests of the Operator or other third parties, or for the fulfillment of purposes of public importance upon condition that no rights or freedoms of the personal data subject shall be violated;

7) Personal data shall be processed for statistical or other research purposes upon condition of the mandatory depersonalization of personal data. An exception is personal data processing for the purposes of promotion of goods, works and services on the market through direct contact with prospective buyers using various communication tools, as well as for political campaigning;

8) Personal data shall be processed, access to which shall be granted an unlimited number of people by the personal data subject or upon his / her request (hereinafter referred to as personal data made publicly available by the personal data subject);

9) Personal data shall be processed that shall be subject to publication or mandatory disclosure as per federal law.


3.2 The Company may include the subject’ personal data in publicly-available personal data sources upon condition that the Company shall have obtained in writing the subject’s consent to the processing of his / her personal data.

3.3 The Company may process special categories of personal data related to racial or national identity and health status upon condition that the Company shall have obtained in writing the subject’s consent to the processing of his / her personal data.

3.4 The Company shall not process biometric personal data (information that characterizes people’s physiological and biological features that enables establishing the identity of the subjects and is used by the Operator for establishing the identity of the personal data subject).

3.5 The Company shall carry out the trans-border transfer of personal data only to foreign states that provide for the adequate protection of the rights of personal data subjects.

3.6 No solutions entailing legal consequences with respect to the personal data subject or otherwise affecting his / her rights and legal interests shall be taken based on the exclusively automated processing of personal data.

3.7 The Company’s operating license places no prohibition on the transfer of personal data to third parties without the written consent of the personal data subject.

3.8 If no written consent of the personal data subject to the processing of his / her personal data shall be required, the subject’s consent may be granted by the personal data subject or his/her representative in any form allowing to confirm the fact of its granting.

3.9 The Company reserves the right to charge another person with personal data processing with the consent of the subject of personal data, unless otherwise provided for by federal law, based on an agreement that shall be concluded with this person (hereinafter referred as the Operator’s charge). In this agreement, the Company shall bind the person that shall processes personal data under the Company’s instructions to comply with personal data processing principles and rules provided for by this Federal Law.

3.10 Should the Company charge another person with personal data processing, the Company shall bear responsibility with respect to the personal data subject for the said person’s actions. The person processing the personal data upon the Company’s instruction shall be responsible with respect to the Company.

3.11 The Company undertakes and binds other persons who shall obtain access to personal data not to disclose to third parties and not to distribute personal data without the express consent of the personal data subject, unless otherwise provided for by federal law.


4 RESPONSIBILITIES OF THE COMPANY

As per the requirements of Federal Law No. 152-FZ – Concerning Personal Data, the Company hereby undertakes:

• To provide the personal data subject upon his / her request with information relating to the processing of his / her personal data, or to provide refusal on legal grounds.

• Upon request of the personal data subject to specify processed personal data, block or delete the personal data if it is incomplete, obsolete, inaccurate, illegally obtained or not required for the declared purpose of processing.

• To keep a register of requests of personal data subjects in which requests of personal data subjects to obtain personal data and the facts of the provision of personal data based on these requests shall be recorded.

• To notify the personal data subject of personal data processing in the event that the personal data shall have been obtained from parties other than the personal data subject.


The following cases are exceptions:

1. The personal data subject shall have been notified about the processing of his / her personal data by the respective operator;

2. The personal data shall have been obtained by the Company based on a Federal Law or in connection with execution of an agreement to which the personal data subject shall be a party, beneficiary or guarantor;

3. The personal data shall have been made publicly available by the personal data subject or obtained from a publicly available source;

4. The Company shall process personal data for statistical or other research purposes, for carrying out professional journalist activities or scientific, literature or other creative activities, where none of the rights and legal interests of the personal data subject shall be violated;

5. Provision of data included in the Notification of Personal Data Processing to the personal data subject shall violate the rights and legal interests of third parties.

• In the event that the purpose of personal data processing shall have been fulfilled, to immediately stop personal data processing and destroy corresponding personal data within a time period not exceeding thirty days from the date of fulfillment of the purpose of personal data processing, unless otherwise provided for by an agreement to which the personal data subject shall be a party, beneficiary or guarantor, a separate agreement between the Company and the personal data subject or if the Company shall have no right to process personal data without the express consent of the personal data subject on the grounds provided for by No. 152-FZ – Concerning Personal Data or other federal laws.

• In the event that the personal data subject shall withdraw his / her consent to the processing of his / her personal data, to stop the processing of personal data and destroy such personal data within a time period not exceeding thirty days from the date of receipt of such withdrawal, unless otherwise provided for by an agreement between the Company and the personal data subject. The Company shall notify the personal data subject of such destruction of personal data.

• In the event that the subject shall demand to stop the processing of his / her personal data for the purposes of promoting goods, works or services on the market, to immediately stop such processing of personal data.


5 MEASURES FOR ENSURING PERSONAL DATA SAFETY DURING PROCESSING

5.1 When processing personal data, the Company shall take the required legal, organizational and technical measures to protect against unauthorized or accidental access to personal data, the destruction, alteration, blocking, copying, submission and distribution of personal data as well as against other illegal actions with respect to personal data.

5.2 Personal data safety shall be particularly ensured through:

• identification of threats to personal data safety during the processing of personal data in informational systems;

• the use of organizational and technical measures to ensure personal data safety during the processing of personal data in informational systems required for the fulfillment of requirements to personal data protection, the execution of which shall ensure the levels of protection of personal data established by the Government of the Russian Federation;

• use of information security tools that shall have passed the compliance assessment procedure in the established order;

• assessment of the effectiveness of adopted measures for ensuring personal data safety prior to the commissioning of the personal data informational system;

• registration of machine personal data storage media;

• detection of facts of unauthorized access to personal data and adoption of measures;

• restoration of personal data modified or destroyed as a result of unauthorized access to it;

• setting of rules for access to personal data processed in the personal data informational system, as well as ensuring registration and recording of all actions taken with personal data in the personal data informational system;

• supervision over measures taken to ensure personal data safety and the level of protection of personal data informational systems.


6 Use of Cookie Files

The Company’s site uses cookie files related to its performance, effectiveness and analytics.

These files help us understand how visitors interact with our site by providing information about the areas they visit and the time they spend on the site. This information also reveal possible problems in the operation of the online resource, for example, error reports. This will help us improve the site’s performance.


Analytics cookies also help us measure the effectiveness of promotional campaigns and optimize the site content for people who are interested in our ads, analyze information about your page views and visits for the improvement of our site, determine the number of visitors and how they use our site to boost the site’s effectiveness, as well as better understand visitors’ interests.

This type of cookie file cannot be used for your identification.

All information that is collected and analyzed shall remain anonymous.


By visiting this site, you agree to the use of cookie files.


If you have any questions concerning your personal data (deletion, blocking, etc.), please send us an e-mail to info@trubprom.com.