personal data processing POLICY
1. General Provisions

This Personal Data Processing Policy is compiled in accordance with requirements of the Federal Law dated 27.07.2006 №152-FZ “On Personal Data” (the “Law on Personal Data”) and sets forth the order of processing of personal data and measures to ensure safety of personal data undertaken by Mikhail Borisovich Trigubenko (“the Operator”).
1.1. The Operator makes its utmost goal and a condition of execution of its activities to respect the rights and freedoms of people and citizens in processing their personal data including protection of rights for personal privacy, and personal and familial secret.
1.2. This Policy of the Operator with respect to processing of personal data (“the Policy”) shall apply to all information about the visitors of the web site https://en.delta-tech.pro that the Operator may receive.

2. Terms and Definitions of this Policy

2.1. Automated processing of personal data: processing of personal data using computer technology.
2.2. Blocking of personal data: temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).
2.3. Website: a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the web address https://en.delta-tech.pro.
2.4. Information system of personal data: a set of personal data contained in databases, and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data: actions resulting in the impossibility to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of personal data: any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator: a state agency, a municipal agency, a legal entity or an individual, that performs, independently or jointly with other persons, the organization and (or) carrying out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.
2.8. Personal data: any information relating directly or indirectly to a specific or identifiable User of the website https://en.delta-tech.pro.
2.9. Personal data permitted for dissemination by the subject of personal data: personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (“personal data allowed for distribution”).
2.10. User: any user of the web site https://en.delta-tech.pro.
2.11. Providing personal data: actions aimed at disclosing personal data to a specific person or a certain scope of persons.
2.12. Dissemination of personal data: any actions aimed at disclosing personal data to an indefinite scope of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including the disclosure of personal data in the media, placement in information and telecommunication 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 an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data: any actions as a result of which personal data is destroyed irretrievably making it impossible to restore the content of personal data in the information system of personal data, and (or) material carriers of personal data are destroyed.

3. Operator’s Rights and Obligations

3.1. The Operator is entitled to:
– receive from the subject of personal data reliable information and / or documents containing personal data;
– in the event that the subject of personal data withdraws consent to the processing of personal data, the Operator shall be entitled to continue processing personal data without the consent of the subject of personal data provided there are grounds thereto specified in the Law on Personal Data;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated in the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obligated to:
– provide information regarding the processing of personal data to the subject of personal data, at their request;
– organize the processing of personal data in the manner specified by the current legislation of the Russian Federation;
– respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
– report the necessary information to the authorized agency for the protection of the rights of subjects of personal data, at the request of such agency, within 30 days from the date of receipt of such a request;
– publish this Policy regarding the processing of personal data or otherwise provide unrestricted access to the same;
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
– stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
– perform other duties stipulated by the Law on Personal Data.

4. Rights and Obligations of Subjects of Personal Data

4.1. The Subjects of Personal Data are entitled to:
– receive information regarding the processing of their personal data, except as otherwise provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
– require the operator to update their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
– put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
– to withdraw consent to the processing of personal data;
– appeal to the authorized agency for the protection of the rights of subjects of personal data or in court against illegal actions or inaction of the Operator when processing his personal data;
– to exercise other rights provided for by the legislation of the Russian Federation.
4.2. The Subjects of Personal Data are obligated to:
– provide the Operator with reliable data about themselves;
– inform the Operator about rectification (update, change) of their personal data.
4.3. Persons submitting to the Operator the false information about themselves or information about other subjects of personal data without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User:

5.1. Full name.
5.2. E-mail address.
5.3. Phone numbers.
5.4. The site also collects and processes anonymous data about visitors (including cookies) using Internet statistics services (Yandex Metrika, Google Analytics, etc.).
5.5. The above mentioned data are united hereinafter with the common term Personal Data.
5.6. The processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, and intimate life is not carried out by the Operator.
5.7. Processing of personal data permitted for distribution and belonging to special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is allowed if the restrictions and conditions provided for in Article 10.1 of the Law on Personal Data are respected.
5.8. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of his personal data. At the same time, the conditions provided for, in particular, by Article 10.1 of the Law on Personal Data. Requirements for the content of such consent are established by the authorized agency for the protection of the rights of personal data subjects.
5.8.1 The User gives consent to the processing of personal data permitted for distribution directly to the Operator.
5.8.2 The Operator shall, no later than three working days from the date of receipt of the specified consent of the User, to publish information on the conditions of processing, on the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.
5.8.3 The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution shall be terminated at any time at the request of the subject of personal data. This requirement should include the last name, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request can be processed only by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data permitted for distribution shall terminate from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. Principles of Processing Personal Data

6.1. The processing of personal data shall be carried out on a legal and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. It shall not be allowed to process personal data that is incompatible with the purposes of collecting personal data.
6.3. It shall not be allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
6.4. Only personal data that meet the purposes of their processing are subject to processing.
6.5. The content and scope of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing shall not be allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, shall be ensured. The operator takes the necessary measures and / or ensures their adoption to remove or clarify incomplete or inaccurate data.
6.7. The storage of personal data shall be carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data shall be destroyed or depersonalized upon reaching the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

7. Purposes of Processing Personal Data

7.1. The Following shall be the purpose of processing the User's personal data:
- Informing the User by e-mails;
- Informing the User by telephone calls.
7.2. The Operator also in entitled to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator to the email address oplacheno@gmail.com with the note "Refusal of notifications about new products and services and special offers".
7.3. Depersonalized Users’ data collected using Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.

8. Legal Grounds for the Processing Of Personal Data

8.1. Legal grounds for the processing of personal data are as follows:
- Federal Law dated 27.07.2006 No.152-FZ “On Personal Data”;
- Federal laws and other normative legal acts on protection of personal data;
- Users’ consents for processing of their personal data, and processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://en.delta-tech.pro or sent to the Operator by e-mail. By filling out the appropriate forms and / or sending their personal data to the Operator, the User agrees with this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (saving cookies and using JavaScript enabled).
8.4. The subject of personal data independently decides on the provision of their personal data and gives consent freely, of their own will and in their own interest.

9. Terms and Conditions of Processing Personal Data

9.1. The processing of personal data shall carried out with the consent of the subject of personal data to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, in order to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another agency or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is required for the performance of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as to conclude an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor.
9.5. The processing of personal data is required for the execution of rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. The processing of personal data is performed, access to an unlimited number of persons to which is provided by the subject of personal data or at their request (“publicly available personal data”).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for collecting, storing, transferring and other types of processing of personal data

The security of personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
10.1. The operator shall ensure the safety of personal data and take all possible measures to exclude access to personal data of unauthorized persons.
10.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s e-mail address oplacheno@gmail.com with the subject “Update of personal data”.
10.4. The time frame for the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different time frame is provided by the contract or applicable law.
The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification by e-mail to the Operator's email address oplacheno@gmail.com with the subject "Withdrawal of consent to the processing of personal data".
10.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and / or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by law of the Russian Federation.
10.7. When processing personal data, the operator shall ensure the confidentiality of personal data.
10.8. The operator shall store personal data in a form that allows to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
10.9. The condition for termination of the processing the personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.

11. List of actions performed by the Operator with the received personal data

11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
11.2. The operator carries out automated processing of personal data with the receipt and / or transmission of the received information via information and telecommunication networks or without the same.

12. Cross-border transfer of personal data

12.1. Prior to the start of cross-border transfer of personal data, the operator shall make sure that the foreign state, to whose territory it is planned to transfer personal data, provides reliable protection of the rights of subjects of personal data.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of his personal data and / or execution of an agreement to which the subject of personal data is a party.

13. Confidentiality of personal data

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

14. Closing Provisions

14.1. The User is entitled get any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via e-mail oplacheno@gmail.com.
14.2. This document will reflect any changes in the policy of processing personal data by the Operator. The policy is valid indefinitely until replaced by a new version.
14.3. Current version of the Policy in the public domain is available on the Internet at https://en.delta-tech.pro/privacy.