Personal Data Processing Policy
This Privacy Policy is formulated in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by the Site Administrator.
The primary goal and condition for the Site Administrator’s activities is to observe human and civil rights and freedoms when processing their personal data, including the protection of rights to privacy, personal and family secrets.
This Privacy Policy (hereinafter referred to as the Policy) applies to information that the Site Administrator may receive about the Users of the Site, accessible at the following link: https://спгмаркет.рф/
Any use of the Site signifies the User’s unconditional consent to this Policy and the terms of personal data processing outlined herein.
Acceptance (acknowledgment) of the Policy without exceptions or reservations is deemed to be the User’s provision of their personal data by commencing the use of the Site.
1. Terms and Definitions
  • Site Administrator – Joint-stock company “Attraktor” (TIN: 7806596568, KPP: 780601001, Address: 188480, Russia, Leningrad Region, Kingisepp, Teatralnaya St., bld. 1, off. 7), which is the right holder of the Site and/or a person authorized by the right holder of the Site to exercise the powers of the Site Administrator, and acts as a personal data operator.
  • Personal Data Processing – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
  • Personal Data Operator – the Site Administrator, independently or jointly with other persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
  • User – an individual who has entered into a User Agreement with the Site Administrator and acts as a personal data subject, and has provided the Site Administrator with consent to process their personal data, as well as consent to transfer personal data to third parties.
  • Site – a complex of software and hardware, software codes, and other intellectual property results, publicly posted at the address https://спгмаркет.рф/, of which the Site Administrator is the right holder.
  • Third-Party Services – services hosted on the Internet, over which the Site Administrator has no management or administration authority. The Site Administrator is not responsible for the legal relations arising between the User and Third-Party Services. The User undertakes to familiarize themselves with all documents (agreements, policies, etc.) independently before starting to use a Third-Party Service.
  • Cookies – a small piece of data that the Site requests from the browser used on the User’s computer or mobile device. Cookies reflect the User’s preferences or their actions on the Site, as well as information about their equipment, date, and session time. Cookies are stored locally on the User’s computer or mobile device. The User can delete saved Cookies in the settings of the corresponding browser.
Other terms and their definitions are used in the meanings provided in the User Agreement.
When processing personal data, processing is carried out based on the following principles:
  • Personal data processing is carried out on a lawful and fair basis.
  • Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.
  • The consolidation of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
  • Only personal data that meets the purposes of their processing is subject to processing.
  • The content and volume of personal data being processed correspond to the stated purposes of processing. Excessiveness of personal data being processed in relation to the stated purposes of their processing is not allowed.
  • When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured. The Site Administrator takes necessary measures and/or ensures their adoption for the deletion or clarification of incomplete or inaccurate data.
  • Personal data is stored in a form that allows the User to be identified, no longer than required by the purposes of personal data processing, unless the retention period of personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of processing purposes or in case of loss of necessity for achieving these purposes, unless otherwise provided by federal law.
  • Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
In addition, within the scope of personal data processing, the Site Administrator strictly adheres to:
  • Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter – the Personal Data Law);
  • Federal Law No. 149-FZ of July 27, 2006 “On Information, Information Technologies, and Information Protection”;
  • Resolution of the Government of the Russian Federation No. 1119 of November 1, 2012 “On Approval of Requirements for the Protection of Personal Data during their Processing in Personal Data Information Systems”;
  • Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data ETS No. 108 (Strasbourg, January 28, 1981);
  • Other regulatory acts and recommendations of authorized state bodies in the field of personal data protection – the Federal Service for Supervision of Communications, Information Technology and Mass Media, the Federal Security Service of Russia, and the Federal Service for Technical and Export Control.
By agreeing to this Policy, the User confirms their readiness to adhere to the above principles within the framework of using the Site.
Section 1. Procedure and Conditions for Processing Personal Data by the Site Administrator as a Personal Data Operator
1.1. The Site Administrator processes personal data, acting as a Personal Data Operator, to the following extent:
* User’s full name;
* User’s date of birth;
* User’s place of birth;
* User’s place of work;
* User’s phone number;
* User’s email address;
* User’s IP address;
* Cookies;
* Details (series, number, date of issue, issuing authority code) of the User’s identity document.
1.2. The processing of personal data specified in clause 1.1. of this Policy is carried out for the following purposes:
* Fulfilling User requests to the Site in accordance with the terms of the User Agreement.
* Enabling the conclusion and execution of civil law contracts with the User.
* Establishing feedback with the User if necessary, including sending notifications, requests, information, and documents related to the use of the Site.
* Improving the quality of the Site’s operation, its usability, and developing new Site functionality.
* Conducting statistical and other research based on anonymized data.
* Transferring User’s personal data to third parties based on User requests to the Site for the purpose of using the Site’s functionality provided by the User Agreement and/or civil law contracts concluded with the User.
1.3. The processing of User’s personal data is carried out by the Site Administrator exclusively on the basis of the User’s consent, which is provided in the following manner:
1.3.1. When the User accesses the Site, they are provided with the opportunity to review the following documents regulating the Site Administrator’s activities in processing personal data, including:
* Privacy Policy;
* User Agreement.
1.3.2. After the User has reviewed the documents specified in clause 1.3.1. of this Policy, the User is provided with the opportunity to review the content of the consent to process personal data and the consent to transfer personal data to third parties.
1.4. By performing the sequence of actions provided for in clause 1.3. of this Policy, the User confirms that they have familiarized themselves with the terms of this Policy and the User Agreement, agree with the conditions reflected therein, and have no objections.
1.5. The User is obliged to independently monitor the current version of this Policy and the User Agreement for possible changes in the terms of personal data processing.
1.6. When the User uses the functional features of the Site, the Site Administrator acts as an information intermediary by virtue of Article 1253.1 of the Civil Code of the Russian Federation. In this case, the Site Administrator, in all instances of User data transmission and/or receipt:
* is not the initiator of such data transfer, as the Site carries out such transfer exclusively based on User requests;
* does not alter the data received or transmitted by the User, except for changes made to ensure the technological process of data transmission;
* does not analyze or research User data for compliance with the current legislation of the Russian Federation;
* uses machine algorithms, technologies, and protocols that ensure data transmission in encrypted form without the possibility of access to such data by the algorithms of the Site itself or the Site Administrator’s employees.
1.7. In case of data transfer between Users using the Site, the Site Administrator is not responsible for the accuracy, relevance, and completeness of the transmitted data.
Section 2. Use of Cookies
2.1. The Site Administrator uses cookies to improve the quality of the Site’s operation, its usability for the User, and to develop new services.
2.2. If the User does not agree to the processing of cookies, they must assume the risk that in such a case, the functions and capabilities of the Site may not be fully available, and then follow one of the following options:
* Independently configure their browser in accordance with its documentation or help in such a way that it permanently does not allow accepting and sending cookie data;
* Switch to the browser’s special “incognito” mode for using cookies on the site until the browser window is closed or until switched back to normal mode;
* Leave the Site to avoid further processing of cookies.
Section 3. Main Rights and Obligations of the Site Administrator
3.1. The Site Administrator has the right:
3.1.1. To receive reliable information and/or documents containing personal data from the personal data subject;
3.1.2. In case of withdrawal of consent to process personal data by the personal data subject, as well as in case of sending a request to cease processing personal data, the Site Administrator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
3.1.3. To independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated 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 Site Administrator is obliged:
3.2.1. To provide the personal data subject, upon their request, with information concerning the processing of their personal data;
3.2.2. To organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
3.2.3. To respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
3.2.4. To inform the authorized body for the protection of the rights of personal data subjects, upon the request of that body, within 10 days from the date of receiving such a request;
3.2.5. To publish or otherwise ensure unrestricted access to this Privacy Policy;
3.2.6. To 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 unlawful actions in relation to personal data;
3.2.7. To cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
3.2.8. To fulfill other obligations stipulated by the Personal Data Law.
Section 4. Main Rights and Obligations of the User
4.1. The User has the right:
4.1.1. To receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the User by the Site Administrator in an accessible form, and it must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
4.1.2. To demand from the Site Administrator clarification of their personal data, its blocking or destruction in case if personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the declared processing purpose, as well as to take measures provided by law to protect their rights;
4.1.3. To stipulate a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
4.1.4. To withdraw consent to the processing of personal data, as well as to send a request to cease processing personal data;
4.1.5. To appeal unlawful actions or inaction of the Site Administrator in processing their personal data to the authorized body for the protection of personal data subjects or to court;
4.1.6. To exercise other rights provided for by the legislation of the Russian Federation.
4.2. The User is obliged:
4.2.1. To provide the Site Administrator with reliable information about themselves;
4.2.2. To inform the Site Administrator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Site Administrator with unreliable information about themselves, or information about another personal data subject without the latter’s consent, bear responsibility in accordance with the legislation of the Russian Federation.
Section 5. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
5.1. The Site Administrator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data by unauthorized persons.
5.2. User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation, as well as in the event of the User sending a request to the Site that involves the transfer of personal data to a third party, provided that the User gives consent to such transfer.
5.3. In case of detecting inaccuracies in personal data, the User can update them independently by sending a notification to the Site Administrator’s email address with the subject line “Personal Data Update”.
5.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the User Agreement or current legislation.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Site Administrator via email to the Site Administrator’s email address with the subject line “Revocation of Consent to Personal Data Processing”. Revocation of consent to the processing of personal data is an unconditional basis for terminating the User Agreement and the User’s cessation of using the Site.
5.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by these persons (Operators) in accordance with their user agreement and privacy policy. The Site Administrator is not responsible for the actions of third parties, including the service providers indicated in this clause.
5.6. The Site Administrator, in processing personal data, ensures the confidentiality of personal data.
5.7. The Site Administrator stores personal data in a form that allows the personal data subject to be identified, no longer than required by the purposes of personal data processing, unless the retention period of personal data is established by federal law, an agreement to which the User is a party, beneficiary, or guarantor.
5.8. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the personal data subject’s consent, the withdrawal of consent by the personal data subject or a request to cease processing personal data, as well as the detection of unlawful processing of personal data.
Section 6. List of Actions Performed by the Site Administrator with Personal Data Received
6.1 The Site Administrator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
6.2 The Site Administrator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without them.
6.3 The Site Administrator has the right to entrust the processing of personal data to another person with the consent of the personal data subject, based on an agreement concluded with that person. The agreement must include a list of actions (operations) with personal data that will be performed by the person processing the personal data, the purposes of processing, the obligation of such person to maintain the confidentiality of personal data and ensure the security of personal data during their processing, as well as requirements for the protection of processed personal data in accordance with Article 19 of Federal Law No. 152-FZ. The consent of the personal data subject is not required in cases established by the legislation of the Russian Federation (including when concluding agreements that are mandatory for the Company due to the requirements of the current legislation of the Russian Federation).
Section 7. Cross-border Transfer of Personal Data
7.1. Cross-border transfer of personal data is not carried out.
Section 8. Confidentiality of Personal Data
8.1. The Site Administrator and other persons who have gained access to personal data are obligated not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
8.2. The Site Administrator has implemented a set of organizational and technical measures to protect confidential information, which includes Personal Data, as well as special measures and means to ensure the information security of Personal Data, aimed at preventing unauthorized or accidental access to Personal Data, their destruction, distortion, blocking, dissemination, and other unlawful actions.
Section 9. Final Provisions
9.1 Any changes to the Site Administrator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
Site Administrator’s Details:
JSC “Attractor”
OGRN: 1227800032503
INN: 7806596568
KPP: 470701001
Address: 188480, Leningrad Region, Kingisepp District, Kingisepp, Tetralnaya St., bld. 1, off. 7
Email: info@lng.market
Phone: +7 921 926 3862
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