User Agreement

The User, by leaving a request on the website sfcprotection.ru, accepts this Consent to the processing of personal data (hereinafter referred to as the Consent). Acting freely, of his own free will and in his own interests, and also confirming his legal capacity, the User gives his consent to OOO "Sibirskaya Lining Company" (TIN 5404070281), which is located at the address, 630120, Novosibirsk, ul. Svyazistov, 12B, to process his personal data with the following conditions:

1. This Consent is given for the processing of personal data, both without the use of automation tools and with their use.

1.1. Consent is given for the processing of the following personal data:

1.1.1 Personal data that is not special or biometric (contact phone numbers, email addresses, place of work and position held) and user data (location information, OS type and version, browser type and version, device type and screen resolution, source from which the user came to the site, from which site or via which advertisement, OS and browser language, which pages the user opens and which buttons the user clicks, IP address).

1.2. Personal data is not publicly available.

1.3. Purpose of personal data processing: processing incoming requests from individuals for the purpose of providing consultations, analyzing the actions of individuals on the website and the functioning of the website, conducting advertising and news mailings.

1.4. The basis for processing personal data is: Art. 24 of the Constitution of the Russian Federation; Art. 6 of Federal Law 152-FZ "On Personal Data"; this consent to the processing of personal data.

1.5. During the processing of personal data, the following actions will be performed: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction.

1.6. Personal data are processed until an individual unsubscribes from advertising and newsletters. Also, the processing of personal data may be terminated at the request of the subject of personal data. Storage of personal data recorded on paper media is carried out in accordance with Federal Law No. 125-FZ "On Archival Affairs in the Russian Federation" and other regulatory legal acts in the field of archival affairs and archival storage.

1.7. Consent may be revoked by the subject of personal data or his representative by sending a written statement to Siberian Lining Company LLC or his representative at the address specified at the beginning of this Consent.

1.8. In the event of the withdrawal of consent to the processing of personal data by the subject of personal data or his representative, Siberian Lining Company LLC has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in paragraphs 2–11 of Part 1 of Article 6, Part 2 of Article 10 and Part 2 of Article 11 of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006.

1.9. This consent is valid until the termination of the processing of personal data specified in paragraph 7 and paragraph 8 of this Consent.

 

2. The following terms and definitions apply in this Agreement:

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

Depersonalization of personal data – actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data by a specific subject of personal data.

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

Operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

Personal data – any information relating to a directly or indirectly identified or identifiable natural person (subject of personal data).

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

Dissemination of personal data – actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.

Cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to a foreign government body, a foreign individual or a foreign legal entity.

Destruction of personal data – actions as a result of which it is impossible to restore the content of personal data in the personal information system

data and (or) as a result of which the tangible media of personal data are destroyed.

3. Principles and conditions for processing personal data

3.1 Principles of personal data processing

The Operator processes personal data based on the following principles:

· legality and fair basis;

· limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;

· preventing the processing of personal data that is incompatible with the purposes of collecting personal data;

· preventing the unification of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;

· processing only those personal data that meet the purposes of their processing;

· compliance of the content and volume of processed personal data with the stated purposes of processing;

· preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;

· ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;

· destruction or depersonalization of personal data upon achieving the purposes of their processing or in the event of loss of the need to achieve these purposes, if it is impossible for the Operator to eliminate the violations of personal data committed, unless otherwise provided by federal law.

3.2. Terms of personal data processing

The operator processes personal data if at least one of the following conditions is met:

· the processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;

· the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation and performance of the functions, powers and duties imposed on the operator by the legislation of the Russian Federation;

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

· the processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor;

· the processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;

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

· personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

3.3. Confidentiality of personal data

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

3.4. Publicly available sources of personal data

For the purposes of information support, the Operator may create publicly available sources of personal data of subjects, including directories and address books. Publicly available sources of personal data, with the written consent of the subject, may include his/her last name, first name, patronymic, date and place of birth, position, contact telephone numbers, e-mail address and other personal data provided by the subject of personal data.

Information about a subject must be excluded from publicly available sources of personal data at any time at the request of the subject or by decision of a court or other authorized state bodies.

3.5. Special categories of personal data

The processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, is permitted in cases where:

· the subject of personal data has given written consent to the processing of his/her personal data;

· personal data have been made publicly available by the subject of the personal data;

· processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on pensions under state pension provision, on labor pensions;

· the processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of other persons and obtaining the consent of the subject of personal data is impossible;

· the processing of personal data is carried out for medical and preventive purposes, for the purpose of establishing a medical diagnosis, providing medical and medical and social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities and is obliged, in accordance with the legislation of the Russian Federation, to maintain medical confidentiality;

· the processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;

· personal data is processed in accordance with the legislation on compulsory types of insurance, with insurance legislation. The processing of special categories of personal data must be immediately terminated if the reasons for which they were processed are eliminated, unless otherwise established by federal law.

The processing of personal data on criminal records may be carried out by the Operator exclusively in cases and in the manner determined in accordance with federal laws.

3.6. Biometric personal data

Information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established - biometric personal data - can be processed by the Operator only with the written consent of the subject.

3.7. Assigning the processing of personal data to another person

The Operator has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules for processing personal data provided for by Federal Law No. 152.

3.8. Cross-border transfer of personal data

The operator is obliged to ensure that the foreign state to whose territory it is proposed to transfer personal data ensures adequate protection of the rights of personal data subjects before such transfer begins.

Cross-border transfer of personal data to the territory of foreign states that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:

· the presence of written consent from the subject of personal data to the cross-border transfer of his personal data;

· execution of an agreement to which the subject of personal data is a party.

4. Rights of the personal data subject

4.1. Consent of the subject of personal data to the processing of his personal data

The subject of personal data makes a decision on the provision of his personal data and gives consent to their processing freely, of his own free will and in his own interests. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form that allows confirming the fact of its receipt, unless otherwise established by federal law.

The obligation to provide proof of receipt of the consent of the personal data subject to the processing of his personal data or proof of the existence of the grounds specified in Federal Law 152 rests with the Operator.

4.2. Rights of the personal data subject

The personal data subject has the right to receive information from the Operator concerning the processing of his personal data, unless such right is limited in accordance with federal laws. The personal data subject has the right to demand from the Operator clarification of his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, and also to take measures provided by law to protect his rights.

Processing of personal data for the purpose of promoting goods, works, services on the market by means of direct contacts with a potential consumer using communication tools, as well as for the purposes of political agitation is permitted only with the prior consent of the personal data subject. The said processing of personal data is recognized as being carried out without the prior consent of the personal data subject, unless the Company proves that such consent has been obtained.

The operator is obliged to immediately stop, at the request of the personal data subject, the processing of his personal data for the above purposes.

It is prohibited to make decisions based solely on automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, except in cases stipulated by federal laws or in the presence of written consent from the subject of personal data.

If the personal data subject believes that the Operator processes his personal data in violation of the requirements of Federal Law No. 152 or otherwise violates his rights and freedoms, the personal data subject has the right to appeal the actions or inaction of the Operator in

The authorized body for the protection of the rights of personal data subjects or in court.

The subject of personal data has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damages in court.

5. Ensuring the security of personal data

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure compliance with the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

· appointment of officials responsible for organizing the processing and protection of personal data;

· limiting the number of persons who have access to personal data;

· familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator on the processing and protection of personal data;

· organization of accounting, storage and circulation of information carriers;

· identification of threats to the security of personal data during their processing, formation of threat models based on them;

· development of a personal data protection system based on the threat model;

· checking the readiness and effectiveness of using information security tools;

· restriction of user access to information resources and software and hardware for information processing;

· registration and accounting of actions of users of personal data information systems;

· use of antivirus tools and means of restoring the personal data protection system;

· application, where necessary, of firewalling, intrusion detection, security analysis and cryptographic information protection tools;

· organization of access control to the Operator’s territory, security of premises with technical means for processing personal data.

5. Final Provisions

Other rights and obligations of the Operator as an operator of personal data are determined by the legislation of the Russian Federation in the field of personal data.

The Operator's officials guilty of violating the rules governing the processing and protection of personal data shall bear material, disciplinary, administrative, civil or criminal liability in accordance with the procedure established by federal laws.

The Company is obliged to publish or otherwise ensure unrestricted access to this Personal Data Processing Policy in accordance with Part 2 of Article 18.1 of Federal Law No. 152.

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