1. General provisions
This personal data processing policy complies with the requirements of the Federal Law of 27.07.2006. No. 152-FZ “Concerning personal data” (hereinafter – Personal Data Law) and regulates the procedure of personal data processing and measures to ensure personal data security taken by the Operator: Innovative Pipe Solutions Limited Liability Company (PSRN 5077746425257, TIN/TRRC 7707622256/504201001).
1.1. The essential aim of the Operator and the main requirement for the performance of its activities is to observe human and civil rights and freedoms in the course of personal data processing, including rights to privacy, personal and family secrets.
1.2. This personal data processing policy of the Operator (hereinafter – Policy) applies to any and all information which may be obtained by the Operator concerning visitors of the website https://www.ntt.su/.
2. Terms and definitions
2.1. Automated Personal Data Processing: personal data processing by means of computer hardware.
2.2. Personal Data Blocking: temporary suspension of personal data processing (except for cases when processing is required to validate personal data).
2.3. Website: total of graphic and informational materials and software for computers and databases ensuring their availability on the Internet at the web address https://www.ntt.su/.
2.4. Personal Data Information System: total of personal data recorded in databases and information technologies and hardware performing utilized for their processing.
2.5. Cookie: a file containing a small data set sent by the web server and stored on User computers without any alteration or processing. Cookies enable the website to identify computers of its Users and demonstrate the website https://www.ntt.su/ in accordance with User preferences.
2.6. Depersonalization of Personal Data: actions rendering it impossible to link personal data to specific Users or other personal data subjects without the use of any additional information.
2.7. Personal Data Processing: any action (operation) or a set of actions (operations) involving personal data, performed with the use of automation equipment or without the use of such equipment, including collection, recording, systematization, accumulation, storage, validation (updating, alteration), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
2.8. Operator: a state or municipal authority, legal entity or natural person, independently or jointly with others organizing and (or) performing personal data processing, and also determining the aims of personal data processing, the composition of personal data to be processed and the actions (operations) performed with personal data.
2.9. Personal Data: any information, directly or indirectly to a specific or identifiable User of the website https://www.ntt.su/.
2.10. Personal Data, Approved for Public Disclosure by the Personal Data Subject: personal data, access of an indefinite number of persons to which has been approved by the personal data subject by means of a consent for processing of the personal data approved by the personal data subject for public disclosure in accordance with the Personal Data Law (hereinafter – personal data approved for public disclosure).
2.11. User: any visitor of the website https://www.ntt.su/.
2.12. Provision of Personal Data: actions aimed at disclosure of personal data to specific persons or groups.
2.13. Public Disclosure of Personal Data: any actions aimed at disclosure of personal data to an indefinite number of persons (distribution of personal data) or at familiarization of an indefinite number of persons with personal data, including publication of personal data in mass media, publishing in information and communication networks or provision of access to personal data by any other methods.
2.14. International Personal Data Transfer: transfer of personal data to the territory of a foreign state to a public authority of a foreign state, a foreign natural person or legal entity.
2.15. Destruction of Personal Data: any actions resulting in irreversible destruction of personal data rendering it impossible to restore the contents of the personal data within an information system containing such personal data and (or) destruction of physical carriers of personal data.
3. Rights and Obligations of the Operator
3.1. The Operator shall have the right to:
– receive from personal data subjects true information and/or authentic documents containing personal data;
– in case of revocation of a consent for personal data processing by a personal data subject, the Operator shall have the right to continue processing of relevant personal data without consent of the personal data subject in case of existing grounds specified in the Personal Data Law;
– independently determine the composition and list of measures, required and sufficient to ensure the fulfillment of the obligations established by the Personal Data Law or regulatory enactments thereunder unless the Personal Data Law or other federal laws prescribe otherwise.
3.2. The Operator shall:
– at the request of a personal data subject, provide them with information concerning processing of their personal data;
– organize personal data processing according to the procedure established by the effective legislation of the Russian Federation;
– respond to queries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– communicate to competent authorities for the protection of personal data subjects as requested by such authorities the required information within 30 days from the date of receipt of the relevant request;
– publish this Personal Data Processing Policy or otherwise ensure unlimited access to it;
– take legal, organizational and technical measures for the protection of personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, transfer or disclosure of personal data and other illegal actions involving personal data;
– stop transfer (distribution, disclosure, access) of personal data, stop processing and destroy personal data according to the established procedure in cases stipulated by the Personal Data Law;
– fulfill any other obligations stipulated by the Personal Data Law.
4. Rights and obligations of personal data subjects:
4.1. Personal data subjects shall have the right to:
– receive information concerning processing of their personal data except for cases stipulated by federal laws. The information shall be provided to personal data subjects by the Operator in easily accessible form and shall not contain personal data related to other personal data subjects except for cases when there are legal grounds for disclosure of such personal data. The list of such information and the procedure of its provision are stipulated by the Personal Data Law;
– demand validation of their personal data by the Operator, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, illegally obtained or unnecessary for the declared aim of their processing, and also take measures in accordance with the legislation for the protection of their rights;
– set forth the condition of prior approval concerning personal data processing performed with the aim of marketing of goods, works and services;
– revoke their consent for personal data processing;
– appeal against decisions made exclusively on the grounds of automated personal data processing;
– appeal to competent authorities for the protection of rights of personal data subjects or in courts against unlawful actions or inaction of the Operator in the course of processing of their personal data;
– exercise any other rights established by the Law of the Russian Federation.
4.2. Subjects shall exercise their rights by means of:
- sending relevant requests to the address of the Operator: info@ntt.su, specifying therein the details of the document identifying the Subject and/or representative of the Subject (document type, series and number, issuing authority and date of issue), full name of the Subject and/or representative of the Subject, information concerning their interaction with the Operator through which the Operator obtained personal data of the Subject.
- sending a relevant request by email to the email address info@ntt.su, in such case, the request shall be in form of an electronic document signed in accordance with the Law of the Russian Federation concerning electronic signatures.
- calling the following phone number: +7-499-940-14-04.
4.3. Personal Data Subjects shall:
– provide true information about themselves to the Operator;
– inform the Operator of any amendments (updates, changes) to their personal data.
4.4. Persons providing the Operator with false information about themselves or information concerning other personal data subjects without consent of the latter shall be liable in accordance with the Law of the Russian Federation.
5. The Operator may process:
5.1. Full name and patronym.
5.2. Email address.
5.3. Phone numbers.
5.4. Additionally, the website collects and processes depersonalized personal data concerning visitors (including cookie files) using internet statistics services (Yandex Metrics, etc.).
The information collected by means of cookie files do not fall into any specialized categories and are not deemed as biometric data within the context of articles 10-11 of the Federal Law 152-FZ and are processed by an automated method.
In such case, data processing shall be performed on the grounds of a consent for personal data processing provided by Users of the website by means of implicative actions: continuing to use the website https://www.ntt.su/.
In case a Subject does not want the Operator to collect their data using cookie files, they may disable their collection in their browser settings. Subjects can learn more about doing so at the following addresses:
(https://browser.yandex.ru/help/personal-data-protection/cookies.html);
(https://support.google.com/accounts/answer/61416?hl=ru&co=GENIE.Platform%3DDesktop).
5.5. The Operator shall not process specialized categories of personal data related to racial or national origin, political views, religious or philosophical convictions or intimacies.
5.6. Processing of personal data allowed for distribution belonging to specialized categories of personal data specified in pt. 1 of art. 10 of the Personal Data Law shall be permitted as long as the restrictions and conditions specified in art. 10.1 of the Personal Data Law are observed.
5.7. Consent of the User for processing of personal data allowed for distribution shall be documented separately from other consents for personal data processing.
6. Principles of personal data processing:
6.1. Personal data processing is performed on a legal and equitable basis.
6.2. Personal data processing is limited to the achievement of specific, predetermined and legal aims. Personal data processing inconsistent with the aims of personal data collection is not allowed.
6.3. It is not allowed to merge databases containing personal data processing of which is performed with aims incompatible with one another.
6.4. Exclusively personal data consistent with the aims of their processing can be processed.
6.5. Composition and volume of processed personal data shall correspond with the declared aims of processing. Excessiveness of processed personal data in relation to the declared aims is not allowed.
6.6. In the course of personal data processing, their accuracy, sufficiency, and in some cases, their relevance to the personal data processing aims shall be observed. The Operator shall take necessary measures and/or ensure their adoption for deletion or validation of incomplete or inaccurate data.
6.7. Personal data shall be stored in a form allowing identification of personal data subjects and no longer than required for the aims of personal data processing, unless the storage term of such personal data is stipulated by a federal law or an agreement to which the personal data subject is a beneficiary or surety. Processed personal data are destroyed or anonymized upon achievement of the aims of their processing or in case the achievement of such aims is no longer required, unless a federal law stipulates otherwise.
7. Aims:
7.1. The aim of processing of User personal data:
– informing Users by means of sending emails;
– execution, fulfillment and termination of civil contracts;
– providing Users with access to services, information and/or materials located on the website https://www.ntt.su/.
7.2. Additionally, the Operator shall have the right to send to Subjects notifications of new products and services of advertising nature, special offers, promotions and various events and activities. The subject can at all times refuse to receive informational messages by sending an email to the Operator to the email address info@ntt.su marked as “Refusal from notifications of new products and services and special offers”.
7.3. Anonymized User data collected by means of internet statistics services serve for collection of information concerning actions performed by Users on the website, improvement of quality of the website and its contents.
8. Grounds for personal data processing:
8.1. Legal grounds for personal data processing by the Operator are as follows:
– Federal Law “On Information, Information Technologies and the Protection of Information” of 27.07.2006 No. 149-FZ;
– instruments of incorporation of the Operator and local regulations of the Operator;
– agreements and other contractual documents executed between the Operator and personal data subjects;
– federal laws and other regulations in the field of personal data protection;
– consents of Users with the Policy for processing of their personal data and personal data allowed for distribution.
8.2. The Operator shall process personal data of the User exclusively in case they are typed in and/or sent by Users themselves via special forms located on the website https://www.ntt.su/ or sent to the Operator by email. By filling in the relevant forms and/or sending their personal data to the Operator, Users acknowledge their agreement with this Policy.
8.3. The Operator processes anonymized data on Users in cases when it is allowed by browser settings of Users (saving cookies and the use of JavaScript technology are enabled).
8.4. Personal Data Subjects independently decide whether to provide their personal data and give their consent of their own free will and volition and in their own interests.
9. Conditions of personal data processing.
9.1. Personal data processing is performed on the grounds of a consent of the subject of personal data for processing of their personal data.
9.2. Personal data processing is required for the achievement of the aims stipulated by international agreements of the Russian Federation or its laws and also for the performance of functions, powers and responsibilities assigned to the Operator by legislation of the Russian Federation.
9.3. Personal data processing is required for administration of justice, enforcement of court rulings and resolutions of any other authorities or officials enforceable under legislation of the Russian Federation concerning enforcement procedures.
9.4. Personal data processing is required for the performance of agreements to which personal data subjects are parties, beneficiaries or sureties, and also for execution of agreements at the initiative of personal data subjects or agreements to which personal data subjects are beneficiaries or sureties.
9.5. Personal data processing is required for exercise of rights and lawful interests of the Operator or third parties, or for the achievement of socially beneficial aims, provided that it does not violate rights and freedoms of personal data subjects.
9.6. Personal data processing of data subject to publication or mandatory disclosure under a federal law.
10. Procedure of personal data processing.
Safety of the personal data processed by the Operator is ensured through implementation of legal, organizational and technical measures required for complete fulfillment of the requirements of the effective legislation in the field of personal data protection.
10.1. The Operator shall ensure safety of personal data and take all available measures to prevent access of unauthorized persons to personal data.
10.2. Personal data of Users shall never, under no circumstances be disclosed to third parties, except for cases when it is required for the compliance with the effective legislation or if a personal data subject has given their consent to the Operator for the disclosure of their personal data to a third party for the fulfillment of obligations under a civil contract.
10.3. In case of discovery of inaccuracies in personal data, Users may update them independently by sending a notice to the Operator to the email address of the Operator info@ntt.su marked as “Personal data update”.
10.4. The term of personal data processing is determined by the achievement of the aims for which the personal data have been collected, unless a different term is stipulated by the agreement or the effective legislation.
Users may revoke their consent for personal data processing at all times by sending a notice to the Operator by email to the email address of the Operator info@ntt.su marked as “Revocation of consent for personal data processing”.
10.5. All information collected by third-party services, including payment systems, communications and other service providers, is stored and processed by the said persons (Operators) in accordance with their respective User Agreement and Confidentiality Policy. Personal data subjects and/or Users shall independently and timely familiarize themselves with said documents. The Operator shall not be liable for actions of third parties, including service providers specified in this clause.
10.6. Prohibitions of transfer (except for provision of access) and processing or conditions of processing (except for reception of access) of personal data allowed for distribution imposed by personal data subjects shall be ineffective in case of personal data processing in state, social or other public interests established by the legislation of the Russian Federation.
10.7. In the course of personal data processing, the Operator shall ensure confidentiality of personal data.
10.8. The Operator shall store personal data in a form allowing identification of personal data subjects, for no longer, than required by the aims of processing of relevant personal data, unless the term of storage of such personal data is stipulated by a federal law of an agreement to which a personal data subject is party, beneficiary or surety.
10.9. The conditions for termination of personal data processing include the achievement of the aims of personal data processing, expiration of the consent provided by the relevant personal data subject or revocation of such consent by the personal data subject, and also discovery of unlawful personal data processing.
11. The list of actions of the Operator in the course of personal data processing.
11.1. The Operator performs collection, recording, systematization, accumulation, storage, validation (updating, alteration), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
11.2. The Operator performs automated personal data processing with acquisition and/or transfer of the acquired information via information and communication networks or without it.
12. International personal data transfer.
12.1. Before commencement of international personal data transfer, the Operator shall make sure that the foreign state to whose territory personal data are to be transferred ensures reliable protection of rights of personal data subjects.
12.2. International personal data transfers to the territories of foreign states incompliant with the said requirements may be performed exclusively against a written consent of personal data subjects for international transfer of their personal data and/or for the fulfillment of an agreement to which a personal data subject is a party.
13. Confidentiality.
The Operator and other persons gaining access to personal data shall not disclose to third parties or distribute personal data without consent of personal data subjects unless a federal law stipulates otherwise.
14. Final provisions.
14.1. A User can get clarifications on any matters related to processing of their personal data by contacting the Operator at the email address info@ntt.su.
14.2. The form “Consent for data processing including the use of Cookies” is an integral part of this regulation.