Personal Data Processing Policy

1. General provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006, hereinafter referred to as the Personal Data Law, and defines the procedure for processing personal data and the measures taken by MTK SFERA LLC, hereinafter referred to as the Operator, to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data to be one of its most important goals and conditions for carrying out its activities, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s Personal Data Processing Policy, hereinafter referred to as the Policy, applies to all information that the Operator may receive about visitors to the website https://mtksfera.ru.

1. Key terms used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of personal data processing, except in cases where processing is necessary to clarify personal data.
2.3. Website means a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://mtksfera.ru.
2.4. Personal data information system means a set of personal data contained in databases, as well as information technologies and technical means that ensure the processing of such personal data.
2.5. Anonymization of personal data means actions as a result of which it becomes impossible, without using additional information, to determine whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data means 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, retrieval, use, transfer, distribution, provision, access, anonymization, blocking, deletion and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions, operations, performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://mtksfera.ru.
2.9. Personal data permitted by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted for distribution in the manner provided for by the Personal Data Law, hereinafter referred to as personal data permitted for distribution.
2.10. User means any visitor to the website https://mtksfera.ru.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons, transfer of personal data, or making personal data available to an unlimited number of persons, including publication of personal data in the media, placement in information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the material media containing personal data are destroyed.

1. Main rights and obligations of the Operator

3.1. The Operator has the right to:
receive reliable information and/or documents containing personal data from the personal data subject;
in the event that the personal data subject withdraws consent to personal data processing, or submits a request to terminate personal data processing, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
provide the personal data subject, upon request, with information concerning the processing of their personal data;
organize personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
provide the authorized body for the protection of the rights of personal data subjects, upon request of that body, with the necessary information within 10 days from the date of receipt of such request;
publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
take 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;
terminate the transfer, distribution, provision, access, processing and destruction of personal data in the manner and in the cases provided for by the Personal Data Law;
fulfill other obligations provided for by the Personal Data Law.

1. Main rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:
receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
request that the Operator clarify their personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
set a condition of prior consent when personal data is processed for the purpose of promoting goods, works and services on the market;
withdraw consent to personal data processing, and also submit a request to terminate personal data processing;
appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator during the processing of their personal data;
exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
provide the Operator with reliable data about themselves;
inform the Operator about clarification, updating or modification of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.

1. Principles of personal data processing

5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.3. Combining databases containing personal data processed for purposes incompatible with each other is not permitted.
5.4. Only personal data that corresponds to the purposes of its processing shall be processed.
5.5. The content and scope of the personal data being processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of its processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that makes it possible to identify the personal data subject for no longer than is required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.

1. Purpose of personal data processing

informing the User by sending emails
Personal data
surname, first name, patronymic
email address
telephone numbers
Legal grounds
the Operator’s charter and incorporation documents
Types of personal data processing
collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
sending informational emails to the email address

1. Conditions for personal data processing

7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, an act of another authority or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed where access to such data by an unlimited number of persons has been provided by the personal data subject or at their request, hereinafter referred to as publicly available personal data.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

1. Procedure for the collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation, or where the personal data subject has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil law agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator’s email address logvinov@mtksfera.ru with the subject line “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or current legislation.
The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator by email at logvinov@mtksfera.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by such persons, Operators, in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User shall independently review such documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on transfer, except for providing access, as well as on processing or processing conditions, except for obtaining access, of personal data permitted for distribution, do not apply in cases where personal data is processed in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than is required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. Personal data processing may be terminated upon achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to terminate personal data processing, or detection of unlawful personal data processing.

1. List of actions performed by the Operator with the received personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, updates, modifies, retrieves, uses, transfers, distributes, provides, grants access to, anonymizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transferring the received information via information and telecommunication networks.

1. Cross-border transfer of personal data

10.1. Before carrying out activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data. Such notification is submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals or foreign legal entities to whom the personal data is planned to be transferred.

1. Confidentiality of personal data

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

1. Final provisions

12.1. The User may receive any clarification on issues related to the processing of their personal data by contacting the Operator via email at logvinov@mtksfera.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet.