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Personal data processing policy


1. General provisions

This personal data processing policy has been compiled in accordance with the requirements of the Federal Law No. 152-FZ of 07/27/2006 "On Personal Data" (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data implemented by UNITED INDUSTRIAL LIMITED LIABILITY COMPANY (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and the condition for the pursuit of its activities the respect for human and civil rights and freedoms in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. The Operator's personal data processing policy (hereinafter referred to as the Policy) applies to all information about visitors to the website https://unitedindustrial.ru/eng that the Operator can receive.


2. General definitions used in the Policy

2.1. Automated processing of personal data — processing of personal data by means of computer technology.

2.2. Blocking of personal data — temporary termination of the processing of personal data (except in cases where processing is necessary for the rectification of personal data).

2.3. Website - a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet under the web address of https://unitedindustrial.ru/eng

2.4. Personal data information system — a body of personal data contained in databases as well as the information technologies and technical means that enable the processing thereof.

2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without using additional information, the ascription of personal data to a specific User or another personal data subject.

2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automatic means on personal data, including collection, recording, systematization, accumulation, storage, rectification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator — a government authority, a municipal authority, a legal entity or an individual, that independently or jointly with other persons organizes the processing and/or processes personal data, as well as determines the purposes of the processing of personal data, the composition of personal data to be processed, the actions (operations) performed on personal data.

2.8. Personal data — any information related directly or indirectly to a specific or identifiable User of the website https://unitedindustrial.ru/eng

2.9. Personal data authorized for distribution by the personal data subject — personal data, access to which is granted to an unlimited number of persons by the personal data subject giving consent to the processing of personal data authorized for distribution by the personal data subject in accordance with the procedure provided for by the Law on Personal Data (hereinafter — personal data authorized for distribution).

2.10. User — any visitor of the website https://unitedindustrial.ru/eng

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

2.12. Distribution of personal data — any actions aimed at disclosure of personal data to an indefinite group of persons (transfer of personal data) or disclosure of personal data to the general public, including disclosure of personal data to the media, publication on information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign country to an authority of a foreign country, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data is permanently destroyed with the inability to further restore the content of personal data in the personal data information system and/or the physical carriers of personal data are destroyed.


3. Main rights and obligations of the Operator

3.1. The Operator has the right to:

— receive true information and/or documents containing personal data from the personal data subject;

— in case the personal data subject withdraws consent to the processing of personal data, as well as sends a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;

— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and the statutory instruments adopted in accordance with it, unless otherwise specified by the Law on Personal Data or other federal laws.

3.2. The Operator has the obligation to:

— provide the personal data subject, at their request, with information concerning the processing of their personal data;

— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

— to relay the necessary information to the competent personal data subjects’ rights protection authority at the request of this authority within 10 days from the date of receipt of such a request;

— to publish or otherwise provide unrestricted access to this Personal data processing policy;

— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

— stop transferring (distributing, providing, accessing) personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Law on Personal Data;

— perform other obligations provided for by the Law on Personal Data.


4. Main rights and obligations of the personal data subjects

4.1. Personal data subjects have the right to:

— receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining thereof is established by the Law on Personal Data;

— require the Operator to clarify, block or destroy their personal data if said personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided for by the law to protect their rights;

— set forth a condition of prior consent when processing personal data in order to promote goods, works and services on the market;

— revoke consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;

— appeal to the competent personal data subjects’ rights protection authority or in court against wrongful actions or omissions of the Operator while processing the Personal data subject’s personal data;

— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects have the obligation to:

— provide the Operator with true information about themselves;

— inform the Operator about the rectification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about a different personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.


5. Principles of personal data processing

5.1. The personal data processing is carried out on a lawful and fair basis.

5.2. The personal data processing is limited to achieving specific, predetermined and legitimate purposes. Personal data processing incompatible with the purposes of personal data collection is not allowed.

5.3. Integration of databases containing personal data, the processing of which performed for mutually incompatible purposes is prohibited.

5.4. Only personal data that meets the purposes of processing thereof is subject to said processing.

5.5. The content and the volume of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is prohibited.

5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that said measures are taken to delete or rectify incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows determining the personal data subject, no longer than the purposes of personal data processing require, unless the period of storage of personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data is destroyed or anonymized upon achievement of the processing purposes or in case there is no further need to achieve these purposes, unless otherwise specified by federal law.


6. Purposes of personal data processing

The purpose of the processing is to inform the User by sending emails.

Personal data comprise:
— surname, first name, patronymic
— email address
— telephone numbers
— address of the actual place of residence, address of residency registration and/or address of registration at the place of stay

Legal grounds comprise incorporation (constituent) documents of the Operator
contracts concluded between the Operator and the Personal data subject
the Federal Law "On Information, Information Technologies and the Protection of Information" of 27.07.2006 No. 149-FZ

Types of personal data processing:
— Collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
— Sending information letters to an email address


7. Terms of personal data processing

7.1. The processing of personal data is carried out 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 fulfill the purposes provided for by an international agreement to which the Russian Federation is a party, or by the law, in order to carry out 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 execution of a court ruling, an act of a different authority or an official to be executed 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, a beneficiary or a guarantor, as well as for the conclusion of an agreement initiated by the personal data subject or an agreement to which the personal data subject will be a beneficiary or a guarantor.

7.5. The processing of personal data is necessary to exercise the rights and for the purposes of legitimate interest of the Operator or third parties, or to achieve goals of social significance, provided that the rights and freedoms of the personal data subject are not infringed.

7.6. Personal data is processed, access to which is provided to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

7.7. The procession of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.


8. The procedure for the collection, storage, transfer and other types of personal data processing

The safe-keeping 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.

8.1. The Operator ensures the safe-keeping and integrity of personal data and takes all possible measures to prevent access of unauthorized persons to personal data.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address info@uind.ru marked "Rectification of personal data".

8.4. The period of personal data processing is determined by the fulfillment of the purposes for which personal data was collected, unless another period is provided for 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 by means of email at the Operator's email address info@uind.ru marked "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

8.6. The prohibitions established by the personal data subject in regards to the transfer (except for granting access), as well as to the processing or conditions of processing (except for obtaining access) of personal data that was allowed for distribution, do not apply in cases of processing personal data in the state's, society's or other public interest defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that enables the identification of the personal data subject for a period of time no longer than the purposes of personal data processing require, unless the period of storage of personal data is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor.

8.9. The condition for the termination of personal data processing may be the fulfillment of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.


9. Summary of actions performed by the Operator with the acquired personal data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, rectification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.

9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.


10. Cross-border transfer of personal data

10.1. Prior to the start of cross-border transfer of personal data, the Operator is obliged to notify the competent personal data subjects’ rights protection authority of its intention to carry out cross-border transfer of personal data (such a notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the aforementioned notification, the Operator is obliged to receive relevant information from the authorities of a foreign country, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.


11. Privacy of personal data

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


12. Final provisions

12.1. The User can receive any clarifications on points of interest related to the processing of their personal data by contacting the Operator via email at info@uind.ru.

12.2. This document will reflect any changes to the Operator's personal data processing policy. This Policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely accessible on the Internet at https://unitedindustrial.ru/privacy/eng