Personal Data Processing Policy of the website
Annex No. 1
This Personal Data Processing Policy of the website https://www.ntt.su/ (hereinafter – Policy) complies with the requirements of the Federal Law of 27.07.2006 No. 152-FZ “Federal Law “Concerning personal data” (hereinafter – Personal Data Law) and describes how NTT Innovative Pipe Solutions Limited Liability Company (hereinafter also NTT LLC, “we”, “us”, “our” and “ours”) processes personal data of Users of the website https://www.ntt.su/.
You may use the following contact details for prompt communication with us concerning personal data processing:
Mail address: 141320, Moscow Region, Sergievo-Posadsky Urban District, Kovrovo village 50, room 2;
E-mail: info@ntt.su,
phone: +7 (495) 151-11-27.
1. Terms you may find in our Policy:
- Personal Data: any information, directly or indirectly related to You enabling Your identification;
- Personal Data Operator: a legal entity or natural person processing personal data. Whenever You access our website, we become the operator of Your personal data;
- Personal Data Processing: performance of any actions involving personal data, including collection, recording, systematization, accumulation, storage, verification (update, alteration), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data;
- Automated Personal Data Processing: personal data processing by means of computer hardware;
- Personal Data Blocking: temporary suspension of personal data processing.
- User: any Visitor of the website https://www.ntt.su/.
- Personal Data Information System: the total of personal data contained in databases and information technologies and hardware utilized for its processing.
2. Your rights concerning personal data processing
2.1. Your rights concerning personal data processing are stipulated in the Personal Data Law, in accordance with which, You have the right:
- for access to personal data;
You have the right to obtain from us accurate information concerning the processing of Your personal data and access to the following information:
a) confirmation of the fact of personal data processing by the Operator;
b) legal substantiation and aims of personal data processing;
c) methods of personal data processing applied by the Operator;
d) name and location of the Operator and details of persons with access to the personal data (except for employees of the Operator);
e) personal data related to You being processed and the source from which it was obtained;
f) terms of personal data processing;
g) the procedure of exercise of Your rights in accordance with the Personal Data Law;
h) business name of the entity or full name of the person responsible for personal data processing;
i) information concerning already performed or planned cross-border data transfer.
- for validation of personal data;
In case any data is inaccurate, incomplete or outdated, You have the right to demand rectification of such data related to You.
- for blocking or destruction of personal data;
You have the right to demand from us to block or destroy personal data in case it is incomplete, outdated, inaccurate, obtained illegally or unnecessary for the declared aim of its processing.
- to appeal against our actions or inaction;
You have the right to object against processing of Your personal data in response to our actions or inaction. For that purpose, You may contact the regional department of the Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roscomnadzor).
- to appeal against decisions taken based on entirely automated personal data processing;
You have the right not to be subjected to decision-making concerning You with legal consequences based on entirely automated data processing. You have the right to contact us to appeal against our actions in case our decisions are taken based on entirely automated data processing, if any.
- for revocation of the consent for personal data processing.
Considering that Your data is processed based on a consent, You have the right to revoke it.
2.2. You can exercise Your rights, including revocation of the provided consent, by one of the following methods:
2.2.1. by sending a request to our address 141320, Moscow Region, Sergievo-Posadsky Urban District, Kovrovo village 50, room 2, specifying the following information:
- details of the document identifying You or Your representative (document type, series and number, issuing authority and date of issue),
- Your full name or the full name of Your representative,
- details of our cooperation with You in the course of which we have obtained Your personal data.
Please, do not forget to sign Your request.
2.2.2. You may send a request by e-mail to the address info@ntt.su, specifying the following information:
- details of the document identifying You and/or Your representative (document type, series and number, issuing authority and date of issue),
- Your full name or the full name of Your representative,
- details of our cooperation with You in the course of which we have obtained Your personal data.
In such case, the request shall be in form of an electronic document signed in accordance with the requirements of the legislation of the Russian Federation concerning electronic signatures.
2.2.3. You may also call us on the phone number +7 (495) 151-11-27.
2.2.4. You may appeal against our actions as a personal data operator with the territorial department of the Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roscomnadzor).
2.3. The right of personal data subjects for access to their personal data may be limited in accordance with federal laws, among other things, in the following cases:
1) personal data processing, including personal data obtained through law enforcement intelligence, counterintelligence and intelligence activities is performed for the purposes of defense of the country, state security and law enforcement;
2) personal data processing is performed by an authority which has detained the personal data subject on suspicion of crime commitment, or has brought charges against the personal data subject under a criminal case, or has applied a pre-trial restriction measure against the personal data subject, except for cases provided for by the criminal procedure legislation of the Russian Federation allowing familiarization of the suspect or the accused with such personal data;
3) personal data processing is performed in accordance with the legislation against legalization (laundering) of profits from illegal activities and financing of terrorism;
4) access of the personal data subject to their personal data violates the rights and lawful interests of any third parties;
5) when personal data processing is performed in cases specified in the legislation of the Russian Federation concerning transport security, for the purposes of stable and safe operation of the transport system, protection of interests of individuals, the society and the state in the field of transport from illegal interference.
3. The exact composition of Your personal data processed by us, the aims of, grounds for and terms of its processing
In this section, You may learn in more detail the exact composition of data processed by us, the aims of personal data processing, where and to whom we transfer personal data if required.
3.1. NTT LLC processes personal data of Users in order to establish contact with them by means of telephone communication (“callback form”). In this process, Users are Personal Data Subjects.
For the achievement of the abovesaid aim, we will collect, record, systematize, accumulate, store, verify (update, alter), extract, use, transfer (provide, grant access), block, delete and destroy personal data.
3.1.1. To enable us to contact You by phone and provide information that interests You, fill in the form “Need advice? Leave an application!” on the website. Please, specify Your phone number in the application.
3.1.2. Personal data processed for the said aim does not fall into any specialized categories and is not considered biometric in accordance with articles 10-11 of the Federal Law 152-FZ, and is processed by an automated method.
3.1.3. In this process, the ground for processing of Your personal data is the Consent for Personal Data Processing (Annex No. 1.1).
3.1.4. All information on such interactions between NTT LLC and Users is stored in Bitrix 24 information system.
3.1.5. In case of such interaction, NTT LLC will destroy Your personal data within 30 days after completion of communication with You in relation to Your problem or from the moment of receipt of revocation of the Consent for Personal Data Processing in accordance with parts 4-5 of article 21 of the Federal Law 152-FZ, whichever occurs first.
3.1.6. In case after our telephone communication we execute an agreement, we will continue processing Your personal data within the scope of the executed agreement.
3.1.7. Upon the achievement of the specified processing aim, Your personal data will be destroyed by means of deletion from Bitrix 24 information system.
3.2. NTT LLC also processes personal data of Users for the purposes of processing Applications for Quotations containing full information on relevant products and services, left by Users on the website via the “Leave an application” form. In this process, Users are Personal Data Subjects.
For the achievement of the abovesaid aim, we will collect, record, systematize, accumulate, store, verify (update, alter), extract, use, transfer (provide, grant access), block, delete and destroy personal data.
3.2.1. To enable us to provide You with a Quotation containing full information about the product and/or service which interests You, please, fill in the relevant form, including the fields containing contact details:
- Full name;
- phone number;
- e-mail address.
3.2.2. Personal data processed for the said aim does not fall into any specialized categories and is not considered biometric in accordance with articles 10-11 of the Federal Law 152-FZ, and is processed by an automated method.
3.2.3. In this process, the ground for processing of Your personal data is the Consent for Personal Data Processing (Annex № 1.2).
3.2.4. All information on such interactions between NTT LLC and Users is stored in Bitrix 24 information system.
3.2.5. We will destroy Your personal data within 30 days from the moment of completion of the discussion of Your project or from the moment of receipt of revocation of the Consent for Personal Data Processing in accordance with parts 4-5 of article 21 of the Federal Law 152-FZ, whichever occurs first.
3.2.6. Upon the achievement of the specified processing aim, Your personal data will be destroyed by means of deletion from Bitrix 24 information system.
3.2.7. In case after our discussion we execute an agreement, we will continue processing Your personal data for the purposes of its performance.
3.3. On our website, Users may also leave messages in order to “Say thank you”, “Complain”, “Ask a question” or “Leave feedback”. In order to process such messages, NTT LLC also processes personal data of Users. In this process, Users are Personal Data Subjects.
For the achievement of the abovesaid aim, we will collect, record, systematize, accumulate, store, validate (update, alter), extract, use, transfer (provide, grant access), block, delete and destroy personal data.
3.3.1. In order to enable us to process such messages, Users fill in the relevant form, including fields containing contact details:
- Full name;
- phone number;
- e-mail address.
3.3.2. Personal data processed for the said aim does not fall into any specialized categories and is not considered biometric in accordance with articles 10-11 of the Federal Law 152-FZ, and is processed by an automated method.
3.3.3. In this process, the ground for processing of Your personal data is the Consent for Personal Data Processing (Annex No. 1.3).
3.3.4. All information on such interactions between NTT LLC and Users is stored in Bitrix 24 information system.
3.3.5. We will destroy personal data of Users within 30 days from the moment of receipt of revocation of the Consent for Personal Data Processing in accordance with parts 4-5 of article 21 of the Federal Law 152-FZ.
3.4. On our website, Users may fill in a “Questionnaire” in order to provide more information on where, how and for what purposes our products and services are planned to be utilized. In order to process such Questionnaires, NTT LLC also processes personal data. In this process, Users are Personal Data Subjects.
For the achievement of the abovesaid aim, we will collect, record, systematize, accumulate, store, validate (update, alter), extract, use, transfer (provide, grant access), block, delete and destroy personal data.
3.4.1. Filling in the Questionnaire, Users also fill in the fields of the form containing contact details:
- Full name;
- e-mail address;
- phone number;
- company name.
3.4.2. Personal data processed for the said aim does not fall into any specialized categories and is not considered biometric in accordance with articles 10-11 of the Federal Law 152-FZ, and is processed by an automated method.
3.4.3. In this process, the ground for processing of Your personal data is the Consent for Personal Data Processing (Annex No. 1.4).
3.4.4. All information on such interactions between NTT LLC and Users is stored in Bitrix 24 information system.
3.4.5. We will destroy personal data within 30 days from the moment of completion of our discussion of Your project based on the Questionnaire filled in by You and received by us, or from the moment of receipt of revocation of the Consent for Personal Data Processing in accordance with parts 4-5 of article 21 of the Federal Law 152-FZ, whichever occurs first.
3.4.6. Upon the achievement of the specified processing aim, Your personal data will be destroyed by means of deletion from the information system.
3.4.7. In case after our discussion we execute an agreement, we will continue processing Your personal data for the purposes of its performance.
3.5. Through the functions of our website, Users can send us applications for the delivery of Presentation materials related to products and/or services which interest them. For that purpose, Users fill in the relevant form on our website. In order to process such applications, NTT LLC also processes personal data. In this process, Users are Personal Data Subjects.
For the achievement of the abovesaid aim, we will collect, record, systematize, accumulate, store, validate (update, alter), extract, use, transfer (provide, grant access), block, delete and destroy personal data.
3.5.1. Filling in the form, Users specify the following information:
- e-mail address.
3.5.2. Personal data processed for the said aim does not fall into any specialized categories and is not considered biometric in accordance with articles 10-11 of the Federal Law 152-FZ, and is processed by an automated method.
3.5.3. In this process, the ground for processing of Your personal data is the Consent for Personal Data Processing (Annex No. 1.8).
3.5.4. All information on such interactions between NTT LLC and Users is stored in Bitrix 24 information system.
3.5.5. We will destroy personal data within 30 days from the moment of delivery of Presentation materials to You, or from the moment of receipt of revocation of the Consent for Personal Data Processing in accordance with parts 4-5 of article 21 of the Federal Law 152-FZ, whichever occurs first.
3.5.6. Upon the achievement of the specified processing aim, Your personal data will be destroyed by means of deletion from the information system.
3.5.7. In case after delivery of Presentation materials to You we execute an agreement, we will continue processing Your personal data for the purposes of its performance.
3.6. Whenever You use our website, the following information related to You becomes available to us:
- IP address,
- type and revision of the operating system of the device,
- details of the mobile device, including device identifier and session identifier,
- browser details,
- information on Your actions on the internet. The number of viewed pages, the duration of the website visit, queries used to transfer to the website and the pages from which transfers to the website had been performed.
3.6.1. We process the abovesaid data for statistical and marketing research, including studies of user behavior and reasons for its changes.
3.6.2. In this case, the ground for processing of Your personal data is the Consent for Personal Data Processing (Annex No. 1.7), provided by You by pressing the button “I Agree” on the cookie banner located on the main page of the website.
3.6.3. Personal data processed for the said aim does not fall into any specialized categories and is not considered biometric in accordance with articles 10-11 of the Federal Law 152-FZ, and is processed by an automated method.
3.6.4. Upon the achievement of the specified processing aim, the data will be deleted from the information system.
3.6.5. In case You do not want us to process the said data, You may tune the browser and operation system of the device used by You accordingly.
3.7. We would like our website to be interesting and convenient for Users. One of the technologies utilized by us for automatic information collection and improved content quality is cookie files collecting User data. In this process, Users are Personal Data Subjects.
Cookie files are small files, usually consisting of letters and figures, downloaded to the device when You enter specific websites. Cookie files allow the website to recognize Your device and present our website in accordance with Your preferences.
3.7.1. Cookie files can be very different. Here are the ones used by us:
Essential
Such cookie files are aimed to ensure faultless operation of websites.
Advertising
This type of cookie files allows to collect information concerning individual preferences of website Users in order to demonstrate advertisements most relevant to such Users. In particular, they are used to prevent demonstrations of annoying and irrelevant advertisements and help to maintain integrity of advertising campaigns.
Analytical
These cookie files are used to collect statistical information concerning the use of the website by Users, for example, the most popular pages, and also information concerning website performance.
3.7.2. Our website may utilize cookie files of third-party services, such as Vkontakte and Yandex Metrics.
3.7.3. Data collected with the help of cookie files does not fall into any specialized categories and is not considered biometric in accordance with articles 10-11 of the Federal Law 152-FZ, and is processed by an automated method.
3.7.4. In such case, the ground for processing of Your personal data is the Consent for Personal Data Processing provided by Users of the website (Annex No. 1.7) by pressing the button “I Agree” on the cookie banner located on the main page of the website.
3.7.5. Upon expiration of processing terms, personal data will be destroyed by means of deletion from information systems.
3.7.6. In case You do not want us to collect Your data with the help of cookie files, You may disable its collection in the options of Your browser. You can find out more about this by using the following links:
Yandex.Browser
https://browser.yandex.ru/help/ru/personal-data-protection/cookies.html
Google Chrome
https://support.google.com/accounts/answer/61416?hl=ru&co=GENIE.Platform%3DDesktop
3.8. NTT LLC also processes personal data of Users for promotion of its products and services. Among other things, NTT LLC may mail out advertising and marketing messages to Users. In this process, Users are Personal Data Subjects.
For the achievement of the abovesaid aim, we will collect, record, systematize, accumulate, store, validate (update, alter), extract, use, transfer (provide, grant access), block, delete and destroy personal data.
3.8.1. In order to send advertising and marketing messages to Users, NTT LLC processes the following personal data of theirs:
- Full name;
- phone number;
- e-mail address.
3.8.2. Personal data processed for the said aim does not fall into any specialized categories and is not considered biometric in accordance with articles 10-11 of the Federal Law 152-FZ, and is processed by an automated method.
3.8.3. In this process, the ground for processing of Your personal data is the Consent for Personal Data Processing for marketing purposes (Annex No. 1.5).
We may send You messages of advertising or marketing nature and for this purpose, process Your personal data exclusively subject to Your Consent for Receipt of Advertising and Marketing Messages (Annex No. 1.6) and Consent for Personal Data Processing for that purpose (Annex No. 1.5). Such Consents are given by You by means of marking (ticking) the relevant checkbox.
3.8.4. You may refuse to receive advertising and marketing messages at all times by sending us a letter to the e-mail address info@ntt.su marked as “Rejection of notifications of new products, services and special offers”.
3.8.5. All information on such interactions between NTT LLC and Users is stored in information systems.
3.8.6. We will destroy personal data within 30 days from the moment of receipt from You of revocation of the Consent for Personal Data Processing and/or Consent for Receipt of Advertising and Marketing Messages.
4. Data transfers to third parties
4.1. For the purposes of increased quality of our interaction, we transfer information concerning You to the following third parties:
| Third party | Aim of transfer | Address of the third party |
|---|---|---|
| Yandex LLC | Analysis of the efficiency of advertising campaigns and optimization of advertisements. | 119021, Moscow, Leo Tolstoy st. 16 |
| V Kontakte LLC | Analysis of the efficiency of advertising campaigns and optimization of advertisements. | 191024, Saint-Petersburg, Hersonskaya st. 12-14, premise A, room 1-N |
| “UNISENDER SMART” | Mailouts of advertising and marketing messages | 127015, Moscow, Bolshaya Novodmitrovskaya st. 23, floor 2, room 46 |
| Novosystem LLC | Analysis of behavior of the website Users on the Internet | 117638, Moscow, Odesskaya st. 2 |
| Rostelecom PJSC | Provision of services by communications providers | 117638, Moscow, Odesskaya st. 2 |
| “Comagic” Limited Liability Company | Analysis of behavior of the website Users on the Internet | 117638, Moscow, Odesskaya st. 2, floor 11, room 2 |
| R01 Registrar LLC | Provider of a Data Processing Center | 125315, Moscow, Leningradsky Prospekt 72, building 3 |
| TIMEWEB.TECHNOLIGIES Limited Liability Company | Provider of a Data Processing Center | 196006, Saint-Petersburg, Zastavskaya st. 22, building 2, premise A |
| TIMEWEB.TECH LLC | Provider of a Data Processing Center | 196006, Saint-Petersburg, Zastavskaya st. 22, building 2, premise A |
| RSIC JSC | Provider of a Data Processing Center | 125315, Moscow, Leningradsky Prospekt 72, building 3 |
| 1C-Bitrix LLC |
Processing of data of persons leaving applications or messages Provider of the software complex for website control |
109544, Moscow, Entuziastov Boulevard 2, floor 13 |
5. Data security
5.1. Personal data of Users processed by NTT LLC is deemed as confidential information.
5.2. We protect it from loss, alteration and unauthorized access in accordance with the requirements of the legislation of the Russian Federation in the field of personal data.
5.3. For that purpose, NTT LLC applies technical means and managerial measures in accordance with art. 18, 18.1, 19 of the Personal Data Law.
6. Information on the terms of processing and existence of bans and restrictions concerning processing by the general public of personal data allowed for distribution by the subject of such personal data.
6.1. The following rules and restrictions apply to personal data published on the website of the Operator:
- personal data processing by the general public is allowed;
- personal data obtained by the Operator may be transferred by means of information and telecommunications networks;
- transfer of personal data to the general public is allowed.
7. Changes to this Policy
Our company is evolving and accordingly, specific business processes are subject to changes. Thus, we will be urged to update our Policy and introduce amendments. We would like you to regularly review all updates of our Policy.
8. Our details
Name: NTT Innovative Pipe Solutions Limited Liability Company
PSRN 5077746425257,
TIN/TRRC (Tax Registration Reason Code) 7707622256/504201001,
Mail address: 141320, Moscow Region, Sergievo-Posadsky Urban District, Kovrovo village 50, room 2;
E-mail: info@ntt.su,
phone: +7 (495) 151-11-27.
9. Annexes to this Policy are as follows:
Annex No. 1.1. – Consent for personal data processing (“callback form”);
Annex No. 1.2. - Consent for personal data processing («форма «оставить заявку»);
Annex No. 1.3 - Consent for personal data processing («форма «оставить обращение»);
Annex No. 1.4. - Consent for personal data processing («опросный лист»);
Annex No. 1.5. - Consent for personal data processing for marketing purposes;
Annex No. 1.6. – Consent for delivery of advertising mailouts;
Annex No. 1.7. – “Consent for personal data processing including with the use of cookie files”;
Annex No. 1.8. – “Consent for personal data processing (“send presentation materials” form”).