Policy regarding personal
data processing
data processing
1. General provisions
This personal data processing policy is developed 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 LLC "Stilkom" (hereinafter referred to as the Operator).
1.1. Operator sets compliance with the rights and freedoms of man and citizen when processing his personal data, including protection of the rights to privacy, personal and family secrets, as its most important goal and condition for the implementation
of its activities.
1.2. This Operator's policy 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://steelcom.ru.
2. Key concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology means.
2.2. Blocking of personal data - the temporary suspension of the processing of personal data
(except in cases where processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and informational materials, as well as programs for electronic computers and databases, ensuring their accessibility on the Internet at the network address https://steelcom.ru.
2.4. Personal data information system - a combination of personal data contained in databases and information technologies
and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed
with or without the use of automation 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.
2.7. Operator - a state body, a municipal body, a legal entity, or an individual, either 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, and the actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://steelcom.ru.
Personal data allowed by the subject of personal data for distribution - personal data to which an unlimited number of individuals has access as granted by the subject of personal data by giving consent for the processing of personal data,
approved by the subject of personal data for distribution in the manner provided by the Personal Data Law
(hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://steelcom.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific individual or a specific group of individuals.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite number
of individuals (transmission of personal data) or acquainting an unlimited number of individuals with personal data, including disclosure of personal data in mass media, placement in information and telecommunication networks, or providing access
to personal data by any other means.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state
to an authority of a foreign state or to a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irreversible destruction of personal data with the impossibility
of further restoration of the content of personal data in the personal data information system and/or the physical media
of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
- receive accurate information and/or documents containing personal data from the personal data subject;
- in case of the personal data subject's withdrawal of consent to the processing of personal data, as well as the submission
of a request for the cessation of personal data processing, the Operator may continue processing personal data without
the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for in the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise stipulated
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 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 Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of personal data subjects within 10 days from the date of receiving such request;
- publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unlawful actions with regard to personal data;
- cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
- fulfill other obligations stipulated by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except as provided by federal laws. The information
is provided by the Operator to the personal data subject in an accessible form and should not contain personal data related
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 obtaining it are determined by the Personal Data Law;
- demand that the operator clarifies their personal data, blocks, or destroys it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take measures provided
by law to protect their rights;
- impose a requirement for prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- withdraw consent to the processing of personal data, as well as submit a request to stop processing personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or through legal procedures
against the operator's unlawful actions or inaction in processing their personal data;
- exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate data about themselves;
- inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with inaccurate 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.
5. Principles of personal data processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to merge databases containing personal data processed for incompatible purposes.
5.4. Only personal data that meets the purposes of processing shall be subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes.
Redundancy of processed personal data in relation to the stated processing purposes is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes
of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required
by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract,
the party to which, the beneficiary, or the custodian of which is the personal data subject. Processed personal data
is destroyed or depersonalized upon achieving the processing purposes or when the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purpose of personal data processing
The purpose of processing is to inform the User by sending emails.
Personal data includes: last name, first name, patronymic, email address, phone numbers.
Legal basis: Federal Law "On Information, Information Technologies and Information Protection" of 27.07.2006 N 149-FZ.
Types of personal data processing: Transfer of personal data.
7. Conditions of personal data processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to processing their personal data.
7.2. Processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation
or by law, to fulfill the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority or official that must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, or for the performance of actions requested by the data subject prior to entering into a contract, as well as for entering into a contract
at the initiative of the data subject or a contract under which the data subject will be a beneficiary or a guarantor.
7.5. Processing of personal data is necessary for the realization of the rights and legitimate interests of the operator
or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms
of the data subject are not violated.
7.6. Personal data processing is carried out where an unlimited number of individuals have access to it as granted by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out for publication or compulsory disclosure in accordance with federal law.
8. The process of collecting, storing, transferring, and other types of personal data processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access
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 compliance with the current legislation or if the data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in the personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address info@steelcom with the subject "Personal Data Update".
8.4. The period of processing personal data is determined by the accomplishment of the purposes for which the personal data was collected, unless a different period is specified by the contract or applicable legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator
via email to the Operator's email address info@steelcom with the subject "Withdrawal of consent for the processing
of personal data".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy.
The data subject and/or with these documents. The Operator is not responsible for the actions of third parties, including
the service providers mentioned in this section.
8.6. Prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing
or conditions for processing (except for accessing), of personal data allowed for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The operator stores personal data in a form that allows identifying the subject of personal data for no longer than necessary for the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract,
with a party to which, beneficiary or trustee of which is the subject of personal data.
8.9. The termination of personal data processing may occur when the purposes of processing personal data have been achieved, the expiration of the consent period of the data subject, the revocation of consent by the data subject, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of actions carried out by the Operator with the received personal data
9.1. The Operator collects, records, organizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator 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.
10. Cross-border transfer of personal data
10.1. Before commencing cross-border transfer of personal data, the data controller must notify the authorized body
for the protection of the rights of personal data subjects of their intention to carry out such cross-border transfer of personal data (this notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above-mentioned notification, the data controller is required to obtain relevant information
from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer
of personal data is intended.
11. Confidentiality of personal data
The data controller and other persons who have access to personal data are obliged not to disclose to third parties
and not to distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The user can receive any explanations on issues related to the processing of his personal data by contacting the Operator
via email at info@steelcom.
12.2. This document will reflect any changes to the personal data processing policy by the Operator. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://steelcom.ru/privacy.
This personal data processing policy is developed 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 LLC "Stilkom" (hereinafter referred to as the Operator).
1.1. Operator sets compliance with the rights and freedoms of man and citizen when processing his personal data, including protection of the rights to privacy, personal and family secrets, as its most important goal and condition for the implementation
of its activities.
1.2. This Operator's policy 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://steelcom.ru.
2. Key concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology means.
2.2. Blocking of personal data - the temporary suspension of the processing of personal data
(except in cases where processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and informational materials, as well as programs for electronic computers and databases, ensuring their accessibility on the Internet at the network address https://steelcom.ru.
2.4. Personal data information system - a combination of personal data contained in databases and information technologies
and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed
with or without the use of automation 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.
2.7. Operator - a state body, a municipal body, a legal entity, or an individual, either 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, and the actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://steelcom.ru.
Personal data allowed by the subject of personal data for distribution - personal data to which an unlimited number of individuals has access as granted by the subject of personal data by giving consent for the processing of personal data,
approved by the subject of personal data for distribution in the manner provided by the Personal Data Law
(hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://steelcom.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific individual or a specific group of individuals.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite number
of individuals (transmission of personal data) or acquainting an unlimited number of individuals with personal data, including disclosure of personal data in mass media, placement in information and telecommunication networks, or providing access
to personal data by any other means.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state
to an authority of a foreign state or to a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irreversible destruction of personal data with the impossibility
of further restoration of the content of personal data in the personal data information system and/or the physical media
of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
- receive accurate information and/or documents containing personal data from the personal data subject;
- in case of the personal data subject's withdrawal of consent to the processing of personal data, as well as the submission
of a request for the cessation of personal data processing, the Operator may continue processing personal data without
the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for in the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise stipulated
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 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 Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of personal data subjects within 10 days from the date of receiving such request;
- publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unlawful actions with regard to personal data;
- cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
- fulfill other obligations stipulated by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except as provided by federal laws. The information
is provided by the Operator to the personal data subject in an accessible form and should not contain personal data related
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 obtaining it are determined by the Personal Data Law;
- demand that the operator clarifies their personal data, blocks, or destroys it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take measures provided
by law to protect their rights;
- impose a requirement for prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- withdraw consent to the processing of personal data, as well as submit a request to stop processing personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or through legal procedures
against the operator's unlawful actions or inaction in processing their personal data;
- exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate data about themselves;
- inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with inaccurate 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.
5. Principles of personal data processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to merge databases containing personal data processed for incompatible purposes.
5.4. Only personal data that meets the purposes of processing shall be subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes.
Redundancy of processed personal data in relation to the stated processing purposes is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes
of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required
by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract,
the party to which, the beneficiary, or the custodian of which is the personal data subject. Processed personal data
is destroyed or depersonalized upon achieving the processing purposes or when the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purpose of personal data processing
The purpose of processing is to inform the User by sending emails.
Personal data includes: last name, first name, patronymic, email address, phone numbers.
Legal basis: Federal Law "On Information, Information Technologies and Information Protection" of 27.07.2006 N 149-FZ.
Types of personal data processing: Transfer of personal data.
7. Conditions of personal data processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to processing their personal data.
7.2. Processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation
or by law, to fulfill the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority or official that must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, or for the performance of actions requested by the data subject prior to entering into a contract, as well as for entering into a contract
at the initiative of the data subject or a contract under which the data subject will be a beneficiary or a guarantor.
7.5. Processing of personal data is necessary for the realization of the rights and legitimate interests of the operator
or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms
of the data subject are not violated.
7.6. Personal data processing is carried out where an unlimited number of individuals have access to it as granted by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out for publication or compulsory disclosure in accordance with federal law.
8. The process of collecting, storing, transferring, and other types of personal data processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access
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 compliance with the current legislation or if the data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in the personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address info@steelcom with the subject "Personal Data Update".
8.4. The period of processing personal data is determined by the accomplishment of the purposes for which the personal data was collected, unless a different period is specified by the contract or applicable legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator
via email to the Operator's email address info@steelcom with the subject "Withdrawal of consent for the processing
of personal data".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy.
The data subject and/or with these documents. The Operator is not responsible for the actions of third parties, including
the service providers mentioned in this section.
8.6. Prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing
or conditions for processing (except for accessing), of personal data allowed for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The operator stores personal data in a form that allows identifying the subject of personal data for no longer than necessary for the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract,
with a party to which, beneficiary or trustee of which is the subject of personal data.
8.9. The termination of personal data processing may occur when the purposes of processing personal data have been achieved, the expiration of the consent period of the data subject, the revocation of consent by the data subject, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of actions carried out by the Operator with the received personal data
9.1. The Operator collects, records, organizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator 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.
10. Cross-border transfer of personal data
10.1. Before commencing cross-border transfer of personal data, the data controller must notify the authorized body
for the protection of the rights of personal data subjects of their intention to carry out such cross-border transfer of personal data (this notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above-mentioned notification, the data controller is required to obtain relevant information
from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer
of personal data is intended.
11. Confidentiality of personal data
The data controller and other persons who have access to personal data are obliged not to disclose to third parties
and not to distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The user can receive any explanations on issues related to the processing of his personal data by contacting the Operator
via email at info@steelcom.
12.2. This document will reflect any changes to the personal data processing policy by the Operator. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://steelcom.ru/privacy.
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Policy regarding personal data processing
1. General provisions
This personal data processing policy is developed 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 LLC "Stilkom" (hereinafter referred to as the Operator).
1.1. Operator sets compliance with the rights and freedoms of man and citizen when processing his personal data, including protection of the rights to privacy, personal and family secrets, as its most important goal and condition for the implementation
of its activities.
1.2. This Operator's policy 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://steelcom.ru.
2. Key concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology means.
2.2. Blocking of personal data - the temporary suspension of the processing of personal data
(except in cases where processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and informational materials, as well as programs for electronic computers and databases, ensuring their accessibility on the Internet at the network address https://steelcom.ru.
2.4. Personal data information system - a combination of personal data contained in databases and information technologies
and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed
with or without the use of automation 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.
2.7. Operator - a state body, a municipal body, a legal entity, or an individual, either 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, and the actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://steelcom.ru.
Personal data allowed by the subject of personal data for distribution - personal data to which an unlimited number of individuals has access as granted by the subject of personal data by giving consent for the processing of personal data,
approved by the subject of personal data for distribution in the manner provided by the Personal Data Law
(hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://steelcom.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific individual or a specific group of individuals.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite number
of individuals (transmission of personal data) or acquainting an unlimited number of individuals with personal data, including disclosure of personal data in mass media, placement in information and telecommunication networks, or providing access
to personal data by any other means.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state
to an authority of a foreign state or to a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irreversible destruction of personal data with the impossibility
of further restoration of the content of personal data in the personal data information system and/or the physical media
of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
- receive accurate information and/or documents containing personal data from the personal data subject;
- in case of the personal data subject's withdrawal of consent to the processing of personal data, as well as the submission
of a request for the cessation of personal data processing, the Operator may continue processing personal data without
the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for in the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise stipulated
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 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 Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of personal data subjects within 10 days from the date of receiving such request;
- publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unlawful actions with regard to personal data;
- cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
- fulfill other obligations stipulated by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except as provided by federal laws. The information
is provided by the Operator to the personal data subject in an accessible form and should not contain personal data related
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 obtaining it are determined by the Personal Data Law;
- demand that the operator clarifies their personal data, blocks, or destroys it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take measures provided
by law to protect their rights;
- impose a requirement for prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- withdraw consent to the processing of personal data, as well as submit a request to stop processing personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or through legal procedures
against the operator's unlawful actions or inaction in processing their personal data;
- exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate data about themselves;
- inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with inaccurate 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.
5. Principles of personal data processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to merge databases containing personal data processed for incompatible purposes.
5.4. Only personal data that meets the purposes of processing shall be subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes.
Redundancy of processed personal data in relation to the stated processing purposes is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes
of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required
by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract,
the party to which, the beneficiary, or the custodian of which is the personal data subject. Processed personal data
is destroyed or depersonalized upon achieving the processing purposes or when the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purpose of personal data processing
The purpose of processing is to inform the User by sending emails.
Personal data includes: last name, first name, patronymic, email address, phone numbers.
Legal basis: Federal Law "On Information, Information Technologies and Information Protection" of 27.07.2006 N 149-FZ.
Types of personal data processing: Transfer of personal data.
7. Conditions of personal data processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to processing their personal data.
7.2. Processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation
or by law, to fulfill the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority or official that must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, or for the performance of actions requested by the data subject prior to entering into a contract, as well as for entering into a contract
at the initiative of the data subject or a contract under which the data subject will be a beneficiary or a guarantor.
7.5. Processing of personal data is necessary for the realization of the rights and legitimate interests of the operator
or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms
of the data subject are not violated.
7.6. Personal data processing is carried out where an unlimited number of individuals have access to it as granted by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out for publication or compulsory disclosure in accordance with federal law.
8. The process of collecting, storing, transferring, and other types of personal data processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access
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 compliance with the current legislation or if the data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in the personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address info@steelcom with the subject "Personal Data Update".
8.4. The period of processing personal data is determined by the accomplishment of the purposes for which the personal data was collected, unless a different period is specified by the contract or applicable legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator
via email to the Operator's email address info@steelcom with the subject "Withdrawal of consent for the processing
of personal data".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy.
The data subject and/or with these documents. The Operator is not responsible for the actions of third parties, including
the service providers mentioned in this section.
8.6. Prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing
or conditions for processing (except for accessing), of personal data allowed for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The operator stores personal data in a form that allows identifying the subject of personal data for no longer than necessary for the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract,
with a party to which, beneficiary or trustee of which is the subject of personal data.
8.9. The termination of personal data processing may occur when the purposes of processing personal data have been achieved, the expiration of the consent period of the data subject, the revocation of consent by the data subject, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of actions carried out by the Operator with the received personal data
9.1. The Operator collects, records, organizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator 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.
10. Cross-border transfer of personal data
10.1. Before commencing cross-border transfer of personal data, the data controller must notify the authorized body
for the protection of the rights of personal data subjects of their intention to carry out such cross-border transfer of personal data (this notification
is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above-mentioned notification, the data controller is required to obtain relevant information
from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer
of personal data is intended.
11. Confidentiality of personal data
The data controller and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The user can receive any explanations
on issues related to the processing of his personal data by contacting the Operator
via email at info@steelcom.
12.2. This document will reflect any changes
to the personal data processing policy by the Operator. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://steelcom.ru/privacy.
This personal data processing policy is developed 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 LLC "Stilkom" (hereinafter referred to as the Operator).
1.1. Operator sets compliance with the rights and freedoms of man and citizen when processing his personal data, including protection of the rights to privacy, personal and family secrets, as its most important goal and condition for the implementation
of its activities.
1.2. This Operator's policy 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://steelcom.ru.
2. Key concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology means.
2.2. Blocking of personal data - the temporary suspension of the processing of personal data
(except in cases where processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and informational materials, as well as programs for electronic computers and databases, ensuring their accessibility on the Internet at the network address https://steelcom.ru.
2.4. Personal data information system - a combination of personal data contained in databases and information technologies
and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed
with or without the use of automation 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.
2.7. Operator - a state body, a municipal body, a legal entity, or an individual, either 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, and the actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://steelcom.ru.
Personal data allowed by the subject of personal data for distribution - personal data to which an unlimited number of individuals has access as granted by the subject of personal data by giving consent for the processing of personal data,
approved by the subject of personal data for distribution in the manner provided by the Personal Data Law
(hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://steelcom.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific individual or a specific group of individuals.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite number
of individuals (transmission of personal data) or acquainting an unlimited number of individuals with personal data, including disclosure of personal data in mass media, placement in information and telecommunication networks, or providing access
to personal data by any other means.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state
to an authority of a foreign state or to a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irreversible destruction of personal data with the impossibility
of further restoration of the content of personal data in the personal data information system and/or the physical media
of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
- receive accurate information and/or documents containing personal data from the personal data subject;
- in case of the personal data subject's withdrawal of consent to the processing of personal data, as well as the submission
of a request for the cessation of personal data processing, the Operator may continue processing personal data without
the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for in the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise stipulated
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 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 Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of personal data subjects within 10 days from the date of receiving such request;
- publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unlawful actions with regard to personal data;
- cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
- fulfill other obligations stipulated by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except as provided by federal laws. The information
is provided by the Operator to the personal data subject in an accessible form and should not contain personal data related
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 obtaining it are determined by the Personal Data Law;
- demand that the operator clarifies their personal data, blocks, or destroys it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take measures provided
by law to protect their rights;
- impose a requirement for prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- withdraw consent to the processing of personal data, as well as submit a request to stop processing personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or through legal procedures
against the operator's unlawful actions or inaction in processing their personal data;
- exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate data about themselves;
- inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with inaccurate 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.
5. Principles of personal data processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to merge databases containing personal data processed for incompatible purposes.
5.4. Only personal data that meets the purposes of processing shall be subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes.
Redundancy of processed personal data in relation to the stated processing purposes is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes
of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required
by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract,
the party to which, the beneficiary, or the custodian of which is the personal data subject. Processed personal data
is destroyed or depersonalized upon achieving the processing purposes or when the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purpose of personal data processing
The purpose of processing is to inform the User by sending emails.
Personal data includes: last name, first name, patronymic, email address, phone numbers.
Legal basis: Federal Law "On Information, Information Technologies and Information Protection" of 27.07.2006 N 149-FZ.
Types of personal data processing: Transfer of personal data.
7. Conditions of personal data processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to processing their personal data.
7.2. Processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation
or by law, to fulfill the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority or official that must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, or for the performance of actions requested by the data subject prior to entering into a contract, as well as for entering into a contract
at the initiative of the data subject or a contract under which the data subject will be a beneficiary or a guarantor.
7.5. Processing of personal data is necessary for the realization of the rights and legitimate interests of the operator
or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms
of the data subject are not violated.
7.6. Personal data processing is carried out where an unlimited number of individuals have access to it as granted by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out for publication or compulsory disclosure in accordance with federal law.
8. The process of collecting, storing, transferring, and other types of personal data processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access
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 compliance with the current legislation or if the data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in the personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address info@steelcom with the subject "Personal Data Update".
8.4. The period of processing personal data is determined by the accomplishment of the purposes for which the personal data was collected, unless a different period is specified by the contract or applicable legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator
via email to the Operator's email address info@steelcom with the subject "Withdrawal of consent for the processing
of personal data".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy.
The data subject and/or with these documents. The Operator is not responsible for the actions of third parties, including
the service providers mentioned in this section.
8.6. Prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing
or conditions for processing (except for accessing), of personal data allowed for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The operator stores personal data in a form that allows identifying the subject of personal data for no longer than necessary for the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract,
with a party to which, beneficiary or trustee of which is the subject of personal data.
8.9. The termination of personal data processing may occur when the purposes of processing personal data have been achieved, the expiration of the consent period of the data subject, the revocation of consent by the data subject, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of actions carried out by the Operator with the received personal data
9.1. The Operator collects, records, organizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator 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.
10. Cross-border transfer of personal data
10.1. Before commencing cross-border transfer of personal data, the data controller must notify the authorized body
for the protection of the rights of personal data subjects of their intention to carry out such cross-border transfer of personal data (this notification
is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above-mentioned notification, the data controller is required to obtain relevant information
from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer
of personal data is intended.
11. Confidentiality of personal data
The data controller and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The user can receive any explanations
on issues related to the processing of his personal data by contacting the Operator
via email at info@steelcom.
12.2. This document will reflect any changes
to the personal data processing policy by the Operator. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://steelcom.ru/privacy.
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