Personal Data Protection and Processing Policy

1. Purpose and Scope of the Document

   1. The Policy of LLC "Murashinsky Fanery Zavod" (hereinafter referred to as the "Company", located at: 610000, Kirov, ul. Vsesvyatskaya, 17) regarding the protection and processing of personal data (hereinafter referred to as the Policy) defines the Company's position and intentions in the field of personal data processing and protection, with the aim of respecting and protecting the rights and freedoms of every person, and in particular, the right to privacy, personal and family secrets, and the protection of one's honor and good name.

   2. The Policy is strictly observed by the managers and employees of all structural divisions and branches of the Company.

   3. The Policy applies to all personal data of subjects processed in the Company using automation tools and without the use of such tools.

   4. Any personal data subject has access to this Policy.

2. Definitions

   1. Personal Data - any information relating to a directly or indirectly identified or identifiable individual (citizen). Such information may include, in particular: full name, year, month, date and place of birth, address, telephone number, email address, information about marital, social, property status, education, profession, income, health status, as well as other information.

   2. Processing of Personal Data - any action (operation) or set of actions (operations) with personal data performed using automation tools or without the use of such tools. Such actions (operations) may include: collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

3. The Company processes personal data of the following persons:

   • employees of the Company;
   • subjects with whom civil law contracts have been concluded;
   • clients of the Company;
   • users of the Company's websites;
   • representatives of legal entities;
   • individuals, including individual entrepreneurs.

4. Principles and Conditions of Personal Data Processing

   1. The Company understands the security of personal data as the protection of personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data, and takes the necessary legal, organizational and technical measures to protect personal data.

   2. The processing and security of personal data in the Company is carried out in accordance with the requirements of the Constitution of the Russian Federation, Federal Law "On Personal Data" No. 152-FZ of July 27, 2006, and other regulatory legal acts defining the cases and features of personal data processing.

   3. When processing personal data, the Company adheres to the following principles:

      • legality and fair basis;
      • limiting the processing of personal data to the achievement of specific, predetermined and lawful purposes;
      • preventing the processing of personal data incompatible with the purposes of collecting personal data;
      • preventing the combination of databases containing personal data processed for incompatible purposes;
      • processing of personal data that meets the purposes of their processing.

   4. The Company processes personal data only if one of the following conditions exists:

      • processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;
      • processing of personal data is necessary to achieve the purposes provided by law, for the implementation and performance of the functions, powers and duties imposed on the operator by the legislation of the Russian Federation;
      • processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
      • processing of personal data is necessary for the exercise of the rights and legitimate interests of the Company or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;
      • processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at his request;
      • processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

   5. The Company has the right to entrust the processing of personal data of citizens to third parties on the basis of an agreement concluded with these persons. Persons processing personal data on behalf of the Company undertake to comply with the principles and rules of personal data processing and protection provided for by Federal Law "On Personal Data" No. 152-FZ of July 27, 2006.

   6. For each person, a list of actions (operations) with personal data that will be performed by the legal entity processing personal data, the purposes of processing, the obligation of such person to maintain confidentiality and ensure the security of personal data during their processing are defined, and the requirements for the protection of processed personal data are specified.

   7. In cases established by the legislation of the Russian Federation, the Company has the right to transfer personal data of citizens.

   8. For information support, publicly available sources of employees' personal data may be created in the Company, including directories and address books. With the employee's consent, his surname, first name, patronymic, date and place of birth, position, contact phone numbers, and email address may be included in publicly available sources of personal data. Information about an employee of the Company must be excluded from publicly available sources of personal data at any time at the request of the employee or by a court decision or other authorized state bodies.

   9. The Company destroys or depersonalizes personal data upon achieving the purposes of processing or in case of loss of the need to achieve the purpose of processing.

5. A citizen whose personal data is processed by the Company has the right to:

   1. receive from the Company:

      • confirmation of the fact of personal data processing by the Company;
      • legal grounds and purposes of personal data processing;
      • information about the methods of personal data processing used by the Company;
      • the name and location of the Company;
      • information about persons who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Company or on the basis of federal law;
      • a list of processed personal data related to the citizen who submitted the request and the source of their receipt, unless a different procedure for providing such data is provided by federal law;
      • information on the terms of personal data processing, including the terms of their storage;
      • information on the procedure for the citizen to exercise the rights provided for by Federal Law "On Personal Data" No. 152-FZ of July 27, 2006;
      • information about the ongoing or intended transfer of personal data;
      • the name and address of the person processing personal data on behalf of the Company;
      • other information provided for by Federal Law "On Personal Data" No. 152-FZ of July 27, 2006 or other regulatory legal acts;

6. Liability

   1. In case of non-compliance with the provisions of this Policy, the Company is liable in accordance with the current legislation of the Russian Federation.

   2. To receive clarifications on issues of interest to you regarding the processing of your personal data, you can contact the Company in person or send an official request to the legal address of the Company.

   3. When sending an official request, the text of the request must indicate:

      • full name;
      • details of the identity document of the personal data subject or his representative, including information on the date of issue of the said document and the issuing authority;
      • information confirming the relationship with the Company or information otherwise confirming the fact of the Company's processing of the applicant's personal data;
      • signature of the citizen (or his legal representative). If the request is sent electronically, it must be formatted as an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.

   4. Information on the implemented requirements for the protection of personal data

      • When processing personal data, the Company takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data.
      • To coordinate actions to ensure the security of personal data, a person responsible for ensuring the security of personal data has been appointed in the Company.

Appendix No. 1 to the policy on the protection and processing of personal data - user consent to the processing of personal data

The User, by leaving his data on the Internet sites (hereinafter referred to as the Site) of the Company, as well as by filling out the feedback form with personal data, accepts this Agreement on the processing of personal data (hereinafter referred to as the Consent). The acceptance (acceptance) of the offer of the Consent is the filling out of the form with personal data in the feedback form on the Internet site.

1. The User gives his consent to the Company, which owns this Internet site, to process his personal data under the following conditions:
2. This Consent is given for the processing of personal data, both without the use of automation tools and with their use.
3. Consent is given for the processing, but not limited to, the following personal data: full name, year, month, date and place of birth, address, telephone, email, information about marital, social, property status, education, profession, income, health status, as well as other information.
4. Purpose of personal data processing: fulfillment of contractual obligations, conducting advertising campaigns and marketing research, including SMS and email newsletters.
5. The basis for personal data processing are: Art. 24 of the Constitution of the Russian Federation; Art. 6 of Federal Law No. 152-FZ "On Personal Data".
6. During processing, the following actions will be performed with personal data: collection; recording; systematization; accumulation; storage; clarification (updating, modification); retrieval; use; transfer (distribution, provision, access); depersonalization; blocking; deletion; destruction.
7. Transfer of personal data to third parties is carried out on the basis of the legislation of the Russian Federation, an agreement with the participation of the personal data subject, or with the consent of the personal data subject. The User gives his consent to the possible transfer of his personal data to third parties.
8. Personal data is processed until the processing is completed. Also, the processing of personal data may be terminated at the request of the personal data subject. The term or condition for termination of personal data processing: termination of the Company's activities as a legal entity (liquidation or reorganization).
9. Consent is given, including for the possible cross-border transfer of personal data and informational (advertising) notifications.
10. Consent may be withdrawn by the personal data subject or his representative by sending a written application to the Company or its representative at the address specified at the beginning of this Policy.
11. In case of withdrawal of consent to the processing of personal data by the personal data subject or his representative, the Company has the right to continue processing personal data without the consent of the personal data subject 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" of June 26, 2006.