1. General Provisions
1.1. The Operator sets compliance with the rights and freedoms of individuals as its primary goal and condition for carrying out its activities in the processing of 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 referred to as the "Policy") applies to all information that the Operator may obtain about visitors (hereinafter referred to as "Users") of the website https://en.ntech.ru (hereinafter referred to as the "Website").
1.3. The use of the Website's services signifies the User's unconditional consent to this Policy and the conditions for the processing of their personal information stated herein; in case of disagreement with these conditions, the User must refrain from using the services.
2. Key Terms 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 the processing of personal data (except in cases 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 provide their accessibility on the Internet at the network address https://en.ntech.ru.
2.4. Personal data information system - a set of databases containing personal data and providing their processing through information technology and technical means.
2.5. Depersonalization 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 using additional information.
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, modification), retrieval, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a government body, municipal body, legal or natural person, acting independently or jointly with others, organizing and/or carrying out the processing of personal data, and determining the purposes of personal data processing, the composition of personal data subject to processing, 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.ntech.ru.
2.9. Personal data authorized for dissemination by the personal data subject - personal data to which an unrestricted circle of individuals is granted access by the personal data subject by giving consent to the processing of personal data authorized for dissemination by the personal data subject in the manner provided by the Personal Data Law (hereinafter referred to as "personal data authorized for dissemination").
2.10. User - any visitor to the website https://en.ntech.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of individuals.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of individuals (transferring personal data) or acquainting an unlimited circle of individuals with personal data, including publication of personal data in mass 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 state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irrevocable destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
· receive reliable information and/or documents containing personal data from the personal data subject;
· continue processing personal data without the consent of the personal data subject in case of the withdrawal of consent for the processing of personal data by the personal data subject or upon receipt of a request to stop processing personal data, provided there are grounds specified in the Personal Data Law;
· independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and 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 their personal data;
· organize the processing of personal data in accordance with the current legislation of the Russian Federation;
· respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
· provide the necessary information to the authorized body for the protection of the rights of personal data subjects within 10 (ten) days from the date of receiving a request from that authority;
· publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
· take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions regarding personal data;
· cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
· fulfill other obligations provided by the Personal Data Law.
4. Here are the key rights and obligations of the personal data subjects:
4.1. Rights of the personal data subjects:
· The right to receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided by the Operator to the personal data subject in an accessible form and should not include personal data related to other individuals unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are determined by the Personal Data Law.
· The right to request the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing. They also have the right to take measures provided by law to protect their rights.
· The right to require the Operator's prior consent for the processing of personal data for marketing purposes.
· The right to withdraw consent for the processing of personal data and to submit a request to stop processing personal data.
· The right to appeal to the authorized body for the protection of the rights of personal data subjects or to the court against unlawful actions or inaction of the Operator in the processing of their personal data.
· The right to exercise other rights provided by Russian legislation.
4.2. Obligations of the personal data subjects:
· To provide accurate data about themselves to the Operator.
· To inform the Operator about any updates, changes, or modifications to their personal data.
4.3. Responsibilities of individuals who provide false information about themselves to the Operator or provide information about another personal data subject without their consent are determined in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-determined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not allowed.
5.3. The merging of databases containing personal data, the processing of which serves incompatible purposes, is not allowed.
5.4. Only personal data that corresponds to the purposes of its processing shall be subject to processing.
5.5. The content and scope of the processed personal data correspond to the declared purposes of processing. Processing of personal data that is excessive in relation to the declared purposes is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing personal data shall be ensured. The data controller shall take necessary measures and/or ensure their adoption to delete or rectify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the data subject for no longer than necessary for the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract, the party to which, the beneficiary or guarantor of which is the data subject. Processed personal data shall be destroyed or depersonalized upon the achievement of the processing purposes or in case the necessity to achieve these purposes is lost, unless otherwise provided by federal law.
6. Conditions for Personal Data Processing
6.1. The processing of personal data is carried out with the consent of the data subject for the processing of their personal data.
6.2. The processing of personal data is necessary for the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed on the data controller by the legislation of the Russian Federation.
6.3. The processing of personal data is necessary for the administration of justice, the execution of a court ruling, an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
6.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, or for the performance of a contract in favor of the data subject or at the initiative of the data subject, or for the conclusion of a contract where the data subject will be a beneficiary or a guarantor.
6.5. The processing of personal data is necessary for the exercise of rights and legitimate interests of the data controller or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms of the data subject are not violated.
6.6. Personal data that is publicly available or provided by the data subject or at their request is processed (hereinafter referred to as "publicly available personal data").
6.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
6.8. The data controller processes the following personal data of clients:
· Surname, first name, middle name;
· Date of birth;
· Contact phone number;
· Email address;
· IP address of the data subject's devices, cookies information, information about the program through which the user accesses the website, the time of user's access to the website, and the history of all their actions on the operator's website;
· Login and password for accessing the user's "Personal Account" (individual interactive web page of the data subject on the website).
6.9. The following categories of personal data are NOT processed:
· Racial or ethnic origin;
· Political opinions;
· Philosophical beliefs;
· Health condition;
· Intimate life details;
· Religious beliefs.
6.10. Biometric personal data (information characterizing the physiological and biological features of a person based on which their identity can be established) are NOT processed.
6.11. There is NO cross-border transfer of personal data.
7. Purposes of Personal Data Processing
7.1. The operator collects and stores only the personal information that is necessary for providing services or fulfilling agreements and contracts with the user, except in cases where the legislation requires mandatory storage of personal information for a specified period. In the event of receiving a notification from the user regarding the withdrawal of consent for the processing of personal data, the operator shall cease processing the user's personal data within a period not exceeding 10 (ten) working days from the date of receiving the notification. Notification of the withdrawal of consent for the processing of personal data should be sent to the email address: firstname.lastname@example.org, as well as by written correspondence to the legal address: 141090, Moscow Region, Korolev City, Yubileiny Microdistrict, Pioneer Street, Building ¼, Office XXIX.
7.2. The operator processes the user's personal information for the following purposes:
· Identification of the user registered on the website https://en.ntech.ru.
· Providing the user with access to personalized resources of the website.
· Establishing communication with the user, including sending notifications, inquiries related to the use of the website, provision of services, processing user requests and applications.
· Determining the user's location to ensure security and prevent fraud.
· Verifying the accuracy and completeness of the personal data provided by the user.
· Creating an account for making purchases, if the user has given consent to create an account.
· Providing effective customer and technical support to the user in case of any issues related to the use of the website.
· Conducting advertising activities with the user's consent.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data
8.1. The security of personal data processed by the operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.
8.2. The operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.3. The user's personal data will never be transferred to third parties under any circumstances, except in cases related to the fulfillment of current legislation or when the user has given consent to the operator for the transfer of data to a third party to fulfill obligations under a civil contract.
8.4. In case of inaccuracies in the personal data, the user can update them independently by sending a notification to the operator's email address email@example.com with the subject line "Updating Personal Data."
8.5. The processing period of personal data is determined by the achievement of the purposes for which the personal data was collected, unless otherwise provided by the contract or current legislation. The user can withdraw their consent to the processing of personal data at any time by sending a notification to the operator via email to the operator's email address firstname.lastname@example.org with the subject line "Withdrawal of Consent to the Processing of Personal Data."
8.7. The prohibitions on transfer (except for providing access), as well as on processing or conditions for processing (except for obtaining access) of personal data imposed by the data subject, do not apply in cases of processing personal data for state, public, and other public interests as determined by Russian legislation.
8.8. The operator ensures the confidentiality of personal data during its processing.
8.9. The processing of personal data may be terminated upon the achievement of the purposes of processing personal data, expiration of the consent period of the data subject, withdrawal of consent by the data subject, or upon a request to terminate the processing of personal data, as well as upon the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The operator carries out automated processing of personal data, including obtaining and/or transmitting the received information through information and telecommunication networks or without them.
10. Confidentiality of Personal Data
10.1. The operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.
11. Final Provisions
11.1. The user can obtain any clarifications regarding the processing of their personal data by contacting the operator via email at email@example.com.
11.2. Any changes to the policy for the processing of personal data by the operator will be reflected in this document. The policy is effective indefinitely until it is replaced by a new version.
11.3. The current version of the Policy is publicly available on the Internet at https://en.ntech.ru/privacy.