Privacy Policy for Personal Data When Using the Website https://metalitmash.ru
Personal Data Processing Policy1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken by MetaLitMash LLC (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the protection of human and civil rights and freedoms in the processing of personal data to be one of its primary objectives and an essential condition of its activities, including the protection of the rights to privacy and to personal and family confidentiality.
1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://metalitmash.ru.
2. Key Terms Used in This Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where processing is necessary to clarify or update personal data.
2.3. Website means a collection of graphical and informational materials, as well as computer software and databases, that make such materials available on the Internet at https://metalitmash.ru.
2.4. Personal data information system means a set of personal data contained in databases, together with the information technologies and technical means used to process such data.
2.5. Anonymization of personal data means actions resulting in the inability to determine, without the use of additional information, whether personal data relates to a specific User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, whether by automated means or without the use of such means, including the collection, recording, systematization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision, access), anonymization, 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 determines the purposes of personal data processing, the categories of personal data to be processed, and the actions (operations) to be performed with personal data.
2.8. Personal data means any information directly or indirectly relating to an identified or identifiable User of the website https://metalitmash.ru.
2.9. Personal data authorized 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 providing consent to the processing of personal data authorized by the personal data subject for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for dissemination”).
2.10. User means any visitor to the website https://metalitmash.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 number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the mass media, placement of personal data in information and telecommunications networks, or providing 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently restore the content of such personal data in the personal data information system, and/or resulting in the destruction of physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain from the personal data subject accurate information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing such personal data without the personal data subject’s consent where there are legal grounds for doing so under the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and the regulatory legal acts adopted pursuant thereto, 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 concerning the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the applicable 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 responsible for protecting the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as against any other unlawful actions involving 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;
— fulfill other obligations stipulated by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— obtain information concerning the processing of their personal data, except in cases provided for by federal law. Such information shall be provided by the Operator in an accessible form and shall 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 to be provided and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take other measures provided for by law to protect their rights;
— require prior consent as a condition for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
— appeal to the authorized body responsible for protecting the rights of personal data subjects or to a court against unlawful actions or omissions of the Operator in connection with 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 accurate information about themselves;
— notify the Operator of any clarification, update, or change to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that person’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing personal data in a manner incompatible with the purposes for which such data was collected is not permitted.
5.3. Databases containing personal data that are processed for mutually incompatible purposes shall not be combined.
5.4. Only personal data that are relevant to the purposes of processing shall be processed.
5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes of processing is not permitted.
5.6. When processing personal data, the Operator shall ensure the accuracy and sufficiency of such data and, where necessary, their relevance to the purposes of processing. The Operator shall take, and/or ensure that appropriate measures are taken, to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a different retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized once the purposes of processing have been achieved, or when there is no longer any need to achieve those purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
7. Conditions for Processing Personal Data
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a court judgment, or the enforcement of an act issued by another authority or official, where such act is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will act as a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data may be processed where access to such data by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data
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 applicable legislation governing the protection of personal data.
8.1. The Operator ensures the security and integrity of personal data and takes all reasonable measures to prevent unauthorized persons from gaining access to personal data.
8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except where such transfer is required for compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the purpose of fulfilling obligations under a civil-law agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator at manager@metalitmash.ru with the subject line “Personal Data Update.”
8.4. The period during which personal data is processed shall be determined by the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator at manager@metalitmash.ru with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, shall be stored and processed by such parties (operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject should review the relevant documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer of personal data (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, shall not apply where such personal data is processed in the state, public, or other public interests specified by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during its processing.
8.8. The Operator shall store personal data in a form that permits identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a different retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of such consent by the personal data subject, receipt of a request to terminate processing, or identification of unlawful processing of personal data.
9. Actions Performed by the Operator with the Personal Data Obtained
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (disseminates, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing any activity involving the cross-border transfer of personal data, the Operator shall notify the authorized body responsible for protecting the rights of personal data subjects of its intention to carry out such cross-border transfer. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above-mentioned notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is intended to be made.
11. Confidentiality of Personal Data
The Operator and any other persons who have obtained access to personal data shall not disclose such data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarification on any matters concerning the processing of their personal data by contacting the Operator by email at manager@metalitmash.ru.
12.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at manager@metalitmash.ru/privacy-policy.
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken by MetaLitMash LLC (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the protection of human and civil rights and freedoms in the processing of personal data to be one of its primary objectives and an essential condition of its activities, including the protection of the rights to privacy and to personal and family confidentiality.
1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://metalitmash.ru.
2. Key Terms Used in This Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where processing is necessary to clarify or update personal data.
2.3. Website means a collection of graphical and informational materials, as well as computer software and databases, that make such materials available on the Internet at https://metalitmash.ru.
2.4. Personal data information system means a set of personal data contained in databases, together with the information technologies and technical means used to process such data.
2.5. Anonymization of personal data means actions resulting in the inability to determine, without the use of additional information, whether personal data relates to a specific User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, whether by automated means or without the use of such means, including the collection, recording, systematization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision, access), anonymization, 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 determines the purposes of personal data processing, the categories of personal data to be processed, and the actions (operations) to be performed with personal data.
2.8. Personal data means any information directly or indirectly relating to an identified or identifiable User of the website https://metalitmash.ru.
2.9. Personal data authorized 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 providing consent to the processing of personal data authorized by the personal data subject for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for dissemination”).
2.10. User means any visitor to the website https://metalitmash.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 number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the mass media, placement of personal data in information and telecommunications networks, or providing 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently restore the content of such personal data in the personal data information system, and/or resulting in the destruction of physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain from the personal data subject accurate information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing such personal data without the personal data subject’s consent where there are legal grounds for doing so under the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and the regulatory legal acts adopted pursuant thereto, 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 concerning the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the applicable 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 responsible for protecting the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as against any other unlawful actions involving 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;
— fulfill other obligations stipulated by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— obtain information concerning the processing of their personal data, except in cases provided for by federal law. Such information shall be provided by the Operator in an accessible form and shall 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 to be provided and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take other measures provided for by law to protect their rights;
— require prior consent as a condition for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
— appeal to the authorized body responsible for protecting the rights of personal data subjects or to a court against unlawful actions or omissions of the Operator in connection with 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 accurate information about themselves;
— notify the Operator of any clarification, update, or change to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that person’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing personal data in a manner incompatible with the purposes for which such data was collected is not permitted.
5.3. Databases containing personal data that are processed for mutually incompatible purposes shall not be combined.
5.4. Only personal data that are relevant to the purposes of processing shall be processed.
5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes of processing is not permitted.
5.6. When processing personal data, the Operator shall ensure the accuracy and sufficiency of such data and, where necessary, their relevance to the purposes of processing. The Operator shall take, and/or ensure that appropriate measures are taken, to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a different retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized once the purposes of processing have been achieved, or when there is no longer any need to achieve those purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing | granting the User access to services, information, and/or materials contained on the website |
Personal data | Surname, first name, patronymic Email address Phone numbers |
Legal grounds | charter (founding) documents of the Operator |
Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data Sending informational emails to the email address |
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a court judgment, or the enforcement of an act issued by another authority or official, where such act is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will act as a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data may be processed where access to such data by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data
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 applicable legislation governing the protection of personal data.
8.1. The Operator ensures the security and integrity of personal data and takes all reasonable measures to prevent unauthorized persons from gaining access to personal data.
8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except where such transfer is required for compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the purpose of fulfilling obligations under a civil-law agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator at manager@metalitmash.ru with the subject line “Personal Data Update.”
8.4. The period during which personal data is processed shall be determined by the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator at manager@metalitmash.ru with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, shall be stored and processed by such parties (operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject should review the relevant documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer of personal data (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, shall not apply where such personal data is processed in the state, public, or other public interests specified by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during its processing.
8.8. The Operator shall store personal data in a form that permits identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a different retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of such consent by the personal data subject, receipt of a request to terminate processing, or identification of unlawful processing of personal data.
9. Actions Performed by the Operator with the Personal Data Obtained
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (disseminates, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing any activity involving the cross-border transfer of personal data, the Operator shall notify the authorized body responsible for protecting the rights of personal data subjects of its intention to carry out such cross-border transfer. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above-mentioned notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is intended to be made.
11. Confidentiality of Personal Data
The Operator and any other persons who have obtained access to personal data shall not disclose such data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarification on any matters concerning the processing of their personal data by contacting the Operator by email at manager@metalitmash.ru.
12.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at manager@metalitmash.ru/privacy-policy.