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Policy on the Protection and Processing of Personal Data of Clients, Counterparties and Website Users

1. GENERAL PROVISIONS

1.1. This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Limited Liability Company “CNGS Engineering” (hereinafter referred to as the Operator) to ensure the security of personal data.

1.2. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including protection of the rights to privacy, personal and family secrets, to be its most important objective and a prerequisite for carrying out its activities.

1.3. This Policy of the Operator regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://www.cngsengineering.ru (hereinafter referred to as the Website). The Website does not control and is not responsible for third-party websites that the User may access through links available on the Website https://www.cngsengineering.ru.

1.4. Use of the Website services constitutes the User’s unconditional consent to this Policy and to the terms of processing of the User’s personal information set out herein. If the User does not agree with these terms, the User must refrain from using the services.

2. TERMS USED IN THE POLICY

2.1. Automated processing of personal data means processing of personal data using computer technology.

2.2. Blocking of personal data means temporary suspension of the processing of personal data, except where processing is necessary to clarify the personal data.

2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://www.cngsengineering.ru.

2.4. Personal data information system means a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a specific User or other personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, whether using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the Website https://www.cngsengineering.ru.

2.9. Personal data permitted by the personal data subject for dissemination means personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).

2.10. User means any visitor to the Website https://www.cngsengineering.ru.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the mass media, placement in information and telecommunications networks, or provision of access to personal data by any other means.

2.13. Cross-border transfer of personal data means the 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 means any actions as a result of which personal data is irreversibly destroyed, making it impossible to further restore the content of personal data in the personal data information system, and/or as a result of which tangible media containing personal data are destroyed.

3. RIGHTS AND OBLIGATIONS OF THE OPERATOR

3.1. The Operator has the right to:

– receive from the personal data subject reliable information and/or documents containing personal data;

– if the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;

– independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

  • provide the personal data subject, at the subject’s request, with information concerning the processing of the subject’s personal data;
  • organize the processing of personal data in the manner established by 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 authorized body for the protection of the rights of personal data subjects, upon that body’s request, with the necessary information within 10 business days from the date of receipt of such request;
  • publish or otherwise provide unrestricted access to this Policy regarding personal data processing;
  • take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
  • cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
  • perform other obligations provided for by the Personal Data Law.

4. RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS

4.1. Personal data subjects have the right to:

  • receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • require the Operator to clarify their personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and also to take legally prescribed measures to protect their rights;
  • make prior consent a condition for the processing of personal data for the purpose of promoting goods, works and services in the market;
  • withdraw consent to the processing of personal data;
  • appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or omissions of the Operator in the processing of their personal data;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with reliable data about themselves;
  • inform the Operator of any clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.

5. LIST OF USER PERSONAL DATA PROCESSED BY THE OPERATOR

5.1. Surname, first name and patronymic.

5.2. Email address.

5.3. Telephone numbers.

5.4. Year, month, date and place of birth.

5.5. Photographs.

5.6. Place of work and position.

5.7. The Website collects and processes depersonalized data about visitors, including cookies, using Internet statistics services (Yandex Metrica, Google Analytics and others).

5.8. The above data are hereinafter collectively referred to in the Policy as “Personal Data”.

5.9. The Operator does not process special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.

5.10. Processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for by Article 10.1 of the Personal Data Law are observed.

5.11. The User’s consent to the processing of personal data permitted for dissemination is executed separately from other consents to the processing of the User’s personal data. At the same time, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.11.1. The User provides consent to the processing of personal data permitted for dissemination directly to the Operator.

5.11.2. Within no later than three business days from the moment of receiving the User’s specified consent, the Operator is obliged to publish information on the processing conditions, on the existence of prohibitions and conditions for processing by an unlimited number of persons of personal data permitted for dissemination.

5.11.3. Transfer (dissemination, provision, access) of personal data permitted by the personal data subject for dissemination must be discontinued at any time upon the request of the personal data subject. Such request must include the surname, first name and patronymic (if any), contact information (telephone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing must be discontinued.

The personal data specified in such request may be processed only by the Operator to which the request is addressed.

5.11.4. Consent to the processing of personal data permitted for dissemination ceases to be valid from the moment the Operator receives the request specified in clause 5.11.3 of this Personal Data Processing Policy.

6. PRINCIPLES OF PERSONAL DATA PROCESSING

6.1. Personal data is processed on a lawful and fair basis.

6.2. Personal data processing is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected is not permitted.

6.3. It is not permitted to combine databases containing personal data where the processing is carried out for mutually incompatible purposes.

6.4. Only personal data that meets the purposes of its processing is subject to processing.

6.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of its processing is not permitted.

6.6. When personal data is processed, the accuracy of the personal data, its sufficiency and, where necessary, its relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that such measures are taken to delete or clarify incomplete or inaccurate data.

6.7. Personal data is stored in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.

Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.

7. PURPOSES OF PERSONAL DATA PROCESSING

7.1. The purpose of processing the User’s personal data is:

  • to inform the User by sending emails;
  • to provide the User with access to the services, information and/or materials contained on the Website https://www.cngsengineering.ru.

7.2. The Operator has the right to send the User notifications about new products and services, special offers and various events. The User may at any time opt out of receiving informational messages by sending an email to the Operator at info@cngsengineering.ru marked “Refusal of notifications about new products and services and special offers”.

7.3. Depersonalized User data collected using Internet statistics services is used to collect information about Users’ actions on the Website and to improve the quality of the Website and its content.

8. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

8.1. The legal grounds for the Operator’s processing of personal data are:

  • the Operator’s charter (constituent) documents;
  • federal laws and other regulatory legal acts in the field of personal data protection;
  • Users’ consents to the processing of their personal data and to the processing of personal data permitted for dissemination.

8.2. The Operator processes the User’s personal data only if it is completed and/or sent by the User independently through special forms located on the Website https://www.cngsengineering.ru or sent to the Operator by email. By completing the relevant forms and/or sending personal data to the Operator, the User expresses consent to this Policy.

8.3. The Operator processes depersonalized data about the User if this is permitted in the User’s browser settings (saving cookies and use of JavaScript technology are enabled).

8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own will and in their own interest.

9. TERMS OF PERSONAL DATA PROCESSING

9.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

9.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to exercise the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.

9.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

9.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

9.6. Personal data is processed where access by an unlimited number of persons has been granted by the personal data subject or at the personal data subject’s request (hereinafter referred to as publicly available personal data).

9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

10. PROCEDURE FOR COLLECTION, STORAGE, TRANSFER AND OTHER TYPES OF PERSONAL DATA PROCESSING

10.1. 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 current legislation in the field of personal data protection.

10.2. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

10.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.

10.4. The term of personal data processing is determined by achievement of the purposes for which the personal data was collected, unless another term is provided by an agreement or by current legislation.

The User may withdraw consent to the processing of personal data at any time by sending the Operator a notification by email to the Operator’s email address info@cngsengineering.ru marked “Withdrawal of consent to personal data processing”.

10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and promptly familiarize themselves with the specified documents.

The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. Prohibitions established by the personal data subject on transfer (except provision of access), as well as on processing or processing conditions (except obtaining access) for personal data permitted for dissemination, do not apply in cases of personal data processing in state, public and other public interests defined by the legislation of the Russian Federation.

10.7. When processing personal data, the Operator ensures the confidentiality of personal data.

10.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.

10.9. The condition for termination of personal data processing may be achievement of the purposes of personal data processing, expiration of the validity period of the personal data subject’s consent or withdrawal of consent by the personal data subject, as well as identification of unlawful processing of personal data.

11. LIST OF ACTIONS PERFORMED BY THE OPERATOR WITH USERS’ PERSONAL DATA

11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the obtained information via information and telecommunications networks or without such networks.

12. CROSS-BORDER TRANSFER OF PERSONAL DATA

12.1. Before commencing cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state to whose territory the personal data is intended to be transferred ensures reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if there is written consent of the personal data subject to the cross-border transfer of their personal data and/or for the performance of an agreement to which the personal data subject is a party.

13. CONFIDENTIALITY OF PERSONAL DATA

13.1. The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.

By continuing to use this website, you give consent to the processing of
personal data by analytics tools and cookie files
and accept the Personal Data Processing Policy.