1. 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 determines the procedure for personal data processing and the measures taken by OOO “GTL” (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family confidentiality, to be its highest priority and an essential condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://gt-el.ru/privacy-policy
2. Key Terms Used in the 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 personal data processing, except where processing is necessary to clarify 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://gt-el.ru/privacy-policy
2.4. Personal data information system means a set of personal data contained in databases, as well as information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data means actions resulting in the impossibility of determining, without the use of additional information, whether personal data belongs 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, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, alteration), retrieval, 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 personal data processing, as well as determines the purposes of personal data processing, the composition of personal data subject to processing, 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://gt-el.ru/privacy-policy
2.9. Personal data permitted by the personal data subject for distribution 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 distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as “personal data permitted for distribution”).
2.10. User means any visitor to the website https://gt-el.ru/privacy-policy
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. Distribution 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 in the mass media, placement in information and telecommunication 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 public authority, 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 with no possibility of further restoring the content of personal data in a personal data information system and/or resulting in the destruction of material media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator shall have the right to:
– receive reliable information and/or documents containing personal data from the personal data subject;
– if the personal data subject withdraws consent to the processing of personal data, the Operator shall have the right to continue processing personal data without the consent of the personal data subject where grounds specified in the Personal Data Law exist;
– 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 regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator shall be obliged to:
– provide the personal data subject, upon request, with information concerning the processing of his or her personal data;
– organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
– respond to applications and requests 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 personal data subjects’ rights, upon its request, with the necessary information within 30 days from the date of receipt of such request;
– 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 against unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions with respect to personal data;
– cease the transfer (distribution, 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 provided for by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects shall have the right to:
– receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the personal data subject 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 and the procedure for obtaining it are established by the Personal Data Law;
– require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take measures provided by law 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 unlawful actions or omissions of the Operator in the processing of personal data to the authorized body for the protection of personal data subjects’ rights or in court;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall be obliged to:
– provide the Operator with accurate data about themselves;
– inform the Operator of any clarification (updating, alteration) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.
5. Personal Data of the User That May Be Processed by the Operator
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. The website also collects and processes depersonalized data about visitors, including cookie files, using Internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The above data are hereinafter collectively referred to in this Policy as Personal Data.
5.6. The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted provided that the prohibitions and conditions set forth in Article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for distribution shall be executed separately from other consents to the processing of his or her personal data. The conditions provided for, in particular, by Article 10.1 of the Personal Data Law shall be observed. Requirements for the content of such consent shall be established by the authorized body for the protection of personal data subjects’ rights.
5.8.1. Consent to the processing of personal data permitted for distribution shall be provided by the User directly to the Operator.
5.8.2. The Operator shall, no later than three business days from receipt of the User’s specified consent, publish information on the processing conditions, on the existence of prohibitions, and on the conditions for processing by an unlimited number of persons the personal data permitted for distribution.
5.8.3. Transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution shall be ceased at any time at the request of the personal data subject. Such request shall include the surname, first name, patronymic (if any), contact information (telephone number, email address, or postal address) of the personal data subject, as well as the list of personal data whose processing must be ceased. The personal data specified in such request may be processed only by the Operator to whom the request is addressed.
5.8.4. Consent to the processing of personal data permitted for distribution shall cease to be effective upon receipt by the Operator of the request specified in Clause 5.8.3 of this Personal Data Processing Policy.
6. Principles of Personal Data Processing
6.1. Personal data shall be processed on a lawful and fair basis.
6.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection shall not be permitted.
6.3. Databases containing personal data processed for purposes incompatible with one another shall not be combined.
6.4. Only personal data that correspond to the purposes of their processing shall be subject to processing.
6.5. The content and scope of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing shall not be permitted.
6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be 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 period for storing personal data is established by a federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or if the need to achieve such 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 shall be:
– informing the User by sending emails;
– conclusion, performance, and termination of civil-law contracts;
– providing the User with access to services, information, and/or materials contained on the website https://gt-el.ru/privacy-policy
7.2. The Operator shall also have 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@gt-el.ru with the subject line “Opt-out of notifications about new products and services and special offers”.
7.3. Depersonalized data of Users collected through 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 personal data processing by the Operator shall be:
– the charter and constituent documents of the Operator;
– contracts concluded between the Operator and the personal data subject;
– 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 distribution.
8.2. The Operator shall process 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://gt-el.ru/privacy-policy 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 shall process depersonalized data about the User if this is permitted in the User’s browser settings, including where cookie storage and the use of JavaScript technology are enabled.
8.4. The personal data subject independently decides whether to provide his or her personal data and gives consent freely, of his or her own will, and in his or her own interest.
9. Conditions for Personal Data Processing
9.1. Personal data processing shall be carried out with the consent of the personal data subject to the processing of his or her 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, or to perform 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 act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Personal data to which access by an unlimited number of persons has been granted by the personal data subject or at his or her request is processed (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
The security of personal data processed by the Operator shall be 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.
10.1. The Operator shall ensure the safekeeping of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.
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 current legislation or where the personal data subject has given the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil-law contract.
10.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@gt-el.ru with the subject line “Personal Data Update”.
10.4. The period of personal data processing shall be determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or current legislation.
The User may at any time withdraw his or her consent to the processing of personal data by sending a notification to the Operator by email at info@gt-el.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.
10.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, shall be stored and processed by such persons (operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User shall independently and in a timely manner review the specified documents. The Operator shall not be liable 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 for provision of access), as well as prohibitions on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of personal data processing in state, public, and other public interests determined by the legislation 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 makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by a federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The condition for terminating personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, or identification of unlawful personal data processing.
11. List of Actions Performed by the Operator with the Personal Data Received
11.1. The Operator shall carry out collection, recording, systematization, accumulation, storage, clarification (updating, alteration), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator shall carry out automated processing of personal data with and/or without receiving and/or transferring the information obtained through information and telecommunication networks.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing cross-border transfer of personal data, the Operator shall ensure that the foreign state to whose territory the transfer of personal data is intended provides 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 his or her personal data and/or for the performance of a contract to which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data shall not disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User may obtain any clarifications on issues of interest relating to the processing of his or her personal data by contacting the Operator via email at info@gt-el.ru.
14.2. This document shall reflect any changes to the Operator’s Personal Data Processing Policy. The Policy shall remain in effect indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://gt-el.ru/privacy-policy