Legal documents
[POLICY]
on privacy and
personal data processing
on privacy and
personal data processing
1. GENERAL PROVISIONS
This Policy on the Processing of Personal Data (the “Policy”) is an official document of NPO EUROCHIM LLC, located at 6A Mitrofanyevskoye Shosse, Building D, St Petersburg, 198095, Russia (the “Company” or “Operator”). It sets out the procedure for processing and protecting information about individuals (the “Users”) who use the services, information, facilities and programmes (including loyalty programmes) available at www.chemframe.ru (the “Site”).
The Company considers confidentiality important. This Policy aims to protect human and civil rights and freedoms when personal data is processed, including the rights to privacy and personal and family secrets, and to protect against unauthorised access and disclosure.
The Company has developed this Policy to describe how it processes personal data. Processing means any action or set of actions performed on personal data, with or without automation, including collection, recording, organisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision or access), anonymisation, blocking, deletion and destruction.
The processing of personal data and information about Site Users is governed by this Policy, other official documents of the Operator and applicable Russian law.
The Operator processes personal data on a lawful and fair basis. It acts reasonably and in good faith, following these principles:
- lawful purposes and methods of personal data processing;
- good faith;
- consistency of processing purposes with those defined and stated in advance when the data was collected, and with the Company’s powers;
- consistency of the scope and nature of the personal data processed, and of the processing methods, with the purposes of processing.
This Policy governs all types of processing of personal data and personal information (information that can identify a person and any other related information) concerning individuals who use the Company’s products or services.
This Policy applies to personal data collected by any means, active or passive, online or offline, from people anywhere in the world.
2. COLLECTION OF PERSONAL DATA
Personal data is processed so that the Operator can fulfil its obligations to Users in connection with their use of the Site and its services.
Users’ personal data is processed with the consent of the personal data subject.
Personal data means any information relating to a directly or indirectly identified or identifiable individual (personal data subject) that can be used to identify or contact that person.
The Operator may combine personal data it receives with information and products it already holds in order to provide and improve its products, services, content and communications.
Examples of personal data that the Company may collect and use include:
- first name, surname and patronymic;
- date of birth;
- sex;
- postal address (for correspondence);
- place of work;
- telephone number;
- email address.
Personal data may also include additional information supplied by Users at the Operator’s request so that the Operator can fulfil contractual obligations to them. In particular, the Operator may request other data it considers necessary and sufficient to identify a User, prevent abuse or infringement of third-party rights, or fulfil obligations imposed by Russian law.
If a User involves other people in Company events or activities or invites them to communicate with the Company, the Company may collect personal data provided about those people, such as their first name, surname, patronymic, date of birth, postal address, email address and telephone number.
When processing personal data, the Company ensures that it is accurate, sufficient and, where necessary, up to date in relation to the purposes of processing.
3. STORAGE AND USE OF PERSONAL DATA
Users’ personal data is stored only on electronic media and processed using automated systems, except where non-automated processing is necessary to meet legal requirements.
The personal data collected allows the Company to notify Users about new products, special offers and events. It also helps the Company improve its services, content and communications. A User who does not wish to receive mailings may unsubscribe at any time by contacting the Company using the stated contact details or by changing their profile settings on the Site (if registered).
The Company may use personal data to send important notices about changes to its provisions, terms and policies and to confirm orders placed and purchases made by a User. It may also use personal information for internal purposes, including audits, data analysis and other research to improve its products and services and its interactions with customers.
4. COLLECTION AND USE OF NON-PERSONAL INFORMATION
The Company also collects non-personal information: data that cannot be directly associated with an identified individual. It may collect, use, transfer and disclose non-personal information for any purpose. Examples include occupation, language, postcode, unique device identifier, location and the time zone in which a product is used. This information helps the Company understand customer behaviour and improve its products, services and communications.
The Company may also collect data or information about a User’s interests on the Site and when using other products and services. It collects and uses this information to give customers more useful information and understand which aspects of the Site, products and services interest them most. For the purposes of this Policy, aggregated data is treated as non-personal data or information.
If the Company combines non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.
5. TRANSFER OF PERSONAL DATA
Users’ personal data is not transferred to third parties except as expressly provided in this Policy.
A User’s personal data is processed without a time limit by any lawful means, including in personal data information systems, with or without automation.
The User agrees that the Operator may transfer personal data to third parties, including courier services, postal organisations and telecommunications providers, solely for the purposes stated in the “Collection of Personal Data” section of this Policy.
At the User’s direction or with the User’s consent, the User’s personal data may be transferred to the Operator’s third-party contractors, provided that they undertake to keep the information confidential, including when using applications.
Applications used by Users on the Site are hosted and supported by third-party developers that act independently of the Operator and do not act on its behalf or instructions. Before using such applications, Users must familiarise themselves with those third parties’ service terms and personal data protection policies.
A User’s personal data may be transferred at the request of authorised Russian government bodies only on the grounds and in accordance with the procedure established by Russian law.
From the time of a request by the User, the User’s legal representative or the authority responsible for protecting the rights of personal data subjects, the Operator blocks the relevant User’s personal data for the duration of a review if inaccurate data or unlawful actions are identified.
6. DISCLOSURE OF INFORMATION TO THIRD PARTIES
In some cases the Company may provide certain personal information and data to strategic partners that work with it to provide products and services or help it sell them to customers. The Company provides only the minimum personal data necessary to deliver the required service or complete the relevant transaction.
The Company provides personal information only to supply customers with products and services and to improve those products, services and related communications. It does not provide this information to third parties for their marketing purposes.
For any other use of Users’ personal data, the Company requests the User’s consent to its processing.
The Company may need to disclose a User’s personal data under the law, a court order, in legal proceedings, or in response to public requests or requests from government authorities in or outside the User’s country of residence. It may also disclose Users’ personal data or information if it considers disclosure necessary or appropriate for national security, law enforcement or other matters of public importance.
The Company may also disclose Users’ personal data or information if it considers disclosure necessary to enforce its policies and terms or protect its operations and other Users. In the event of a reorganisation, merger or sale, the Company may transfer some or all of the personal information it has collected to the relevant third party.
7. DESTRUCTION OF PERSONAL DATA
A User’s personal data is destroyed when the personal data subject withdraws consent to its processing.
8. PROTECTION OF PERSONAL DATA
The Company takes legal, organisational, administrative, technical and physical precautions to protect Users’ personal data in accordance with Article 19 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”. These measures are intended to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, distribution and other unlawful actions by third parties.
When a User uses certain Company products, services or applications or posts on forums, chats or social networks, the personal data they provide may be visible to other users and may be read, collected or used by them. Users are responsible for the personal data they choose to disclose. For example, a name and email address included in a forum post become public.
The Company therefore asks Users to exercise caution when using these features.
9. INTEGRITY AND RETENTION OF PERSONAL INFORMATION
Users can keep their personal data and information up to date when interacting with the Company. The Company retains a User’s personal data and information for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by law.
The Company does not collect personal data about minors. If it becomes aware that it has received personal data about a minor, it will take steps to delete that information as soon as possible.
The Company strongly recommends that parents and other people responsible for minors (their legal representatives, including parents, adoptive parents, guardians or trustees) supervise minors’ use of the Site.
10. THIRD-PARTY SITES AND SERVICES
The Site and the Company’s products, applications and services may contain links to third-party websites, products and services. The Company’s products and services may also use or offer third-party products or services. Personal data and information collected by third parties, which may include location or contact details, is governed by those parties’ privacy policies. The Company encourages Users to review those policies.
The Operator is not responsible for the actions of third parties that obtain access to information about a User through the internet or the Site, or for the consequences of using data and information that, by the nature of the Site, is available to any internet user.
11. COMPANY-WIDE CONFIDENTIALITY
To help keep Users’ personal data secure, the Company communicates its confidentiality and security rules to employees and strictly monitors compliance with confidentiality measures within the Company.
12. QUESTIONS ABOUT PRIVACY
If you have questions about this Policy or the Company’s processing of data, you can contact the Company’s authorised representatives by email at OFFICE@EHIM.SPB.SU.
13. USER REQUESTS
Russian law applies to this Policy and to the relationship between the User and the Operator.
Users may send the Operator requests, including requests concerning the use of their personal data or withdrawal of consent to processing. A request may be sent in writing to the address stated in the “General Provisions” section of this Policy or as an electronic document signed with a qualified electronic signature under Russian law and sent by email to OFFICE@EHIM.SPB.SU.
A User’s request must contain:
- the number of the primary identity document of the User or their representative;
- the date on which that document was issued and the issuing authority;
- information confirming the User’s relationship with the Operator;
- the signature of the User or their representative;
- an email address;
- a contact telephone number.
The Operator undertakes to review and respond to a request within 30 days of receiving it.
14. OTHER PROVISIONS
For matters not directly addressed in this Policy, the Company undertakes to follow Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
A visitor to the Company’s Site who provides personal data and information thereby agrees to this Policy.
The Company reserves the right to amend this Policy at any time at its discretion to further improve protection against unauthorised access to personal data supplied by Users, without obtaining the User’s consent. If the Company makes material changes to the Policy, it will post an appropriate notice on the Site together with the updated Policy or the relevant amendments or additions.
This Policy does not apply to the activities or online resources of third parties.
15. COOKIES AND OTHER TECHNOLOGIES
The Site, interactive services and applications, email messages and other Company communications may use cookies and other technologies, such as pixel tags and web beacons. These technologies help the Company understand Users’ behaviour, identify which sections of the Site they visit and measure the effectiveness of advertising and online searches.
The Company treats information collected through cookies and similar technologies as non-personal information.
The Company uses these technologies to make interactions with it more convenient and personal. For example, knowing a User’s name allows the Company to use it in communications. Knowing that someone using the User’s computer or device bought a product or used a service may help the Company make advertising and email messages more relevant to the User’s interests. Ultimately, this knowledge helps the Company provide Users with better service.
Users can disable cookies in their web browser or mobile device settings. Some Site features may become unavailable if cookies are disabled.
As with most websites, the Company collects certain information automatically and stores it in log files. This includes an Internet Protocol (IP) address, browser type and language, internet service provider information, referring and exit pages, operating system details, date and time stamps and visit data. The Company uses this information to understand and analyse trends, administer the Site, study Users’ behaviour and gather demographic information about its users as a whole. It may also use this information for marketing purposes.
Some Company emails contain interactive links to information on its Site. When Users follow these links, their requests are recorded separately before they reach the destination page. The Company tracks this click-through data to assess interest in particular topics and measure the effectiveness of its communications with customers. Users who do not want their actions tracked this way should avoid clicking text or image links in email messages.
Pixel tags allow the Company to send emails in a format customers can read and tell it whether those messages have been opened. The Company may use this information to limit the number of messages sent to customers or stop sending them. Production of up to 1,000 tonnes per year at our facility.
This Policy on the Processing of Personal Data (the “Policy”) is an official document of NPO EUROCHIM LLC, located at 6A Mitrofanyevskoye Shosse, Building D, St Petersburg, 198095, Russia (the “Company” or “Operator”). It sets out the procedure for processing and protecting information about individuals (the “Users”) who use the services, information, facilities and programmes (including loyalty programmes) available at www.chemframe.ru (the “Site”).
The Company considers confidentiality important. This Policy aims to protect human and civil rights and freedoms when personal data is processed, including the rights to privacy and personal and family secrets, and to protect against unauthorised access and disclosure.
The Company has developed this Policy to describe how it processes personal data. Processing means any action or set of actions performed on personal data, with or without automation, including collection, recording, organisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision or access), anonymisation, blocking, deletion and destruction.
The processing of personal data and information about Site Users is governed by this Policy, other official documents of the Operator and applicable Russian law.
The Operator processes personal data on a lawful and fair basis. It acts reasonably and in good faith, following these principles:
- lawful purposes and methods of personal data processing;
- good faith;
- consistency of processing purposes with those defined and stated in advance when the data was collected, and with the Company’s powers;
- consistency of the scope and nature of the personal data processed, and of the processing methods, with the purposes of processing.
This Policy governs all types of processing of personal data and personal information (information that can identify a person and any other related information) concerning individuals who use the Company’s products or services.
This Policy applies to personal data collected by any means, active or passive, online or offline, from people anywhere in the world.
2. COLLECTION OF PERSONAL DATA
Personal data is processed so that the Operator can fulfil its obligations to Users in connection with their use of the Site and its services.
Users’ personal data is processed with the consent of the personal data subject.
Personal data means any information relating to a directly or indirectly identified or identifiable individual (personal data subject) that can be used to identify or contact that person.
The Operator may combine personal data it receives with information and products it already holds in order to provide and improve its products, services, content and communications.
Examples of personal data that the Company may collect and use include:
- first name, surname and patronymic;
- date of birth;
- sex;
- postal address (for correspondence);
- place of work;
- telephone number;
- email address.
Personal data may also include additional information supplied by Users at the Operator’s request so that the Operator can fulfil contractual obligations to them. In particular, the Operator may request other data it considers necessary and sufficient to identify a User, prevent abuse or infringement of third-party rights, or fulfil obligations imposed by Russian law.
If a User involves other people in Company events or activities or invites them to communicate with the Company, the Company may collect personal data provided about those people, such as their first name, surname, patronymic, date of birth, postal address, email address and telephone number.
When processing personal data, the Company ensures that it is accurate, sufficient and, where necessary, up to date in relation to the purposes of processing.
3. STORAGE AND USE OF PERSONAL DATA
Users’ personal data is stored only on electronic media and processed using automated systems, except where non-automated processing is necessary to meet legal requirements.
The personal data collected allows the Company to notify Users about new products, special offers and events. It also helps the Company improve its services, content and communications. A User who does not wish to receive mailings may unsubscribe at any time by contacting the Company using the stated contact details or by changing their profile settings on the Site (if registered).
The Company may use personal data to send important notices about changes to its provisions, terms and policies and to confirm orders placed and purchases made by a User. It may also use personal information for internal purposes, including audits, data analysis and other research to improve its products and services and its interactions with customers.
4. COLLECTION AND USE OF NON-PERSONAL INFORMATION
The Company also collects non-personal information: data that cannot be directly associated with an identified individual. It may collect, use, transfer and disclose non-personal information for any purpose. Examples include occupation, language, postcode, unique device identifier, location and the time zone in which a product is used. This information helps the Company understand customer behaviour and improve its products, services and communications.
The Company may also collect data or information about a User’s interests on the Site and when using other products and services. It collects and uses this information to give customers more useful information and understand which aspects of the Site, products and services interest them most. For the purposes of this Policy, aggregated data is treated as non-personal data or information.
If the Company combines non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.
5. TRANSFER OF PERSONAL DATA
Users’ personal data is not transferred to third parties except as expressly provided in this Policy.
A User’s personal data is processed without a time limit by any lawful means, including in personal data information systems, with or without automation.
The User agrees that the Operator may transfer personal data to third parties, including courier services, postal organisations and telecommunications providers, solely for the purposes stated in the “Collection of Personal Data” section of this Policy.
At the User’s direction or with the User’s consent, the User’s personal data may be transferred to the Operator’s third-party contractors, provided that they undertake to keep the information confidential, including when using applications.
Applications used by Users on the Site are hosted and supported by third-party developers that act independently of the Operator and do not act on its behalf or instructions. Before using such applications, Users must familiarise themselves with those third parties’ service terms and personal data protection policies.
A User’s personal data may be transferred at the request of authorised Russian government bodies only on the grounds and in accordance with the procedure established by Russian law.
From the time of a request by the User, the User’s legal representative or the authority responsible for protecting the rights of personal data subjects, the Operator blocks the relevant User’s personal data for the duration of a review if inaccurate data or unlawful actions are identified.
6. DISCLOSURE OF INFORMATION TO THIRD PARTIES
In some cases the Company may provide certain personal information and data to strategic partners that work with it to provide products and services or help it sell them to customers. The Company provides only the minimum personal data necessary to deliver the required service or complete the relevant transaction.
The Company provides personal information only to supply customers with products and services and to improve those products, services and related communications. It does not provide this information to third parties for their marketing purposes.
For any other use of Users’ personal data, the Company requests the User’s consent to its processing.
The Company may need to disclose a User’s personal data under the law, a court order, in legal proceedings, or in response to public requests or requests from government authorities in or outside the User’s country of residence. It may also disclose Users’ personal data or information if it considers disclosure necessary or appropriate for national security, law enforcement or other matters of public importance.
The Company may also disclose Users’ personal data or information if it considers disclosure necessary to enforce its policies and terms or protect its operations and other Users. In the event of a reorganisation, merger or sale, the Company may transfer some or all of the personal information it has collected to the relevant third party.
7. DESTRUCTION OF PERSONAL DATA
A User’s personal data is destroyed when the personal data subject withdraws consent to its processing.
8. PROTECTION OF PERSONAL DATA
The Company takes legal, organisational, administrative, technical and physical precautions to protect Users’ personal data in accordance with Article 19 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”. These measures are intended to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, distribution and other unlawful actions by third parties.
When a User uses certain Company products, services or applications or posts on forums, chats or social networks, the personal data they provide may be visible to other users and may be read, collected or used by them. Users are responsible for the personal data they choose to disclose. For example, a name and email address included in a forum post become public.
The Company therefore asks Users to exercise caution when using these features.
9. INTEGRITY AND RETENTION OF PERSONAL INFORMATION
Users can keep their personal data and information up to date when interacting with the Company. The Company retains a User’s personal data and information for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by law.
The Company does not collect personal data about minors. If it becomes aware that it has received personal data about a minor, it will take steps to delete that information as soon as possible.
The Company strongly recommends that parents and other people responsible for minors (their legal representatives, including parents, adoptive parents, guardians or trustees) supervise minors’ use of the Site.
10. THIRD-PARTY SITES AND SERVICES
The Site and the Company’s products, applications and services may contain links to third-party websites, products and services. The Company’s products and services may also use or offer third-party products or services. Personal data and information collected by third parties, which may include location or contact details, is governed by those parties’ privacy policies. The Company encourages Users to review those policies.
The Operator is not responsible for the actions of third parties that obtain access to information about a User through the internet or the Site, or for the consequences of using data and information that, by the nature of the Site, is available to any internet user.
11. COMPANY-WIDE CONFIDENTIALITY
To help keep Users’ personal data secure, the Company communicates its confidentiality and security rules to employees and strictly monitors compliance with confidentiality measures within the Company.
12. QUESTIONS ABOUT PRIVACY
If you have questions about this Policy or the Company’s processing of data, you can contact the Company’s authorised representatives by email at OFFICE@EHIM.SPB.SU.
13. USER REQUESTS
Russian law applies to this Policy and to the relationship between the User and the Operator.
Users may send the Operator requests, including requests concerning the use of their personal data or withdrawal of consent to processing. A request may be sent in writing to the address stated in the “General Provisions” section of this Policy or as an electronic document signed with a qualified electronic signature under Russian law and sent by email to OFFICE@EHIM.SPB.SU.
A User’s request must contain:
- the number of the primary identity document of the User or their representative;
- the date on which that document was issued and the issuing authority;
- information confirming the User’s relationship with the Operator;
- the signature of the User or their representative;
- an email address;
- a contact telephone number.
The Operator undertakes to review and respond to a request within 30 days of receiving it.
14. OTHER PROVISIONS
For matters not directly addressed in this Policy, the Company undertakes to follow Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
A visitor to the Company’s Site who provides personal data and information thereby agrees to this Policy.
The Company reserves the right to amend this Policy at any time at its discretion to further improve protection against unauthorised access to personal data supplied by Users, without obtaining the User’s consent. If the Company makes material changes to the Policy, it will post an appropriate notice on the Site together with the updated Policy or the relevant amendments or additions.
This Policy does not apply to the activities or online resources of third parties.
15. COOKIES AND OTHER TECHNOLOGIES
The Site, interactive services and applications, email messages and other Company communications may use cookies and other technologies, such as pixel tags and web beacons. These technologies help the Company understand Users’ behaviour, identify which sections of the Site they visit and measure the effectiveness of advertising and online searches.
The Company treats information collected through cookies and similar technologies as non-personal information.
The Company uses these technologies to make interactions with it more convenient and personal. For example, knowing a User’s name allows the Company to use it in communications. Knowing that someone using the User’s computer or device bought a product or used a service may help the Company make advertising and email messages more relevant to the User’s interests. Ultimately, this knowledge helps the Company provide Users with better service.
Users can disable cookies in their web browser or mobile device settings. Some Site features may become unavailable if cookies are disabled.
As with most websites, the Company collects certain information automatically and stores it in log files. This includes an Internet Protocol (IP) address, browser type and language, internet service provider information, referring and exit pages, operating system details, date and time stamps and visit data. The Company uses this information to understand and analyse trends, administer the Site, study Users’ behaviour and gather demographic information about its users as a whole. It may also use this information for marketing purposes.
Some Company emails contain interactive links to information on its Site. When Users follow these links, their requests are recorded separately before they reach the destination page. The Company tracks this click-through data to assess interest in particular topics and measure the effectiveness of its communications with customers. Users who do not want their actions tracked this way should avoid clicking text or image links in email messages.
Pixel tags allow the Company to send emails in a format customers can read and tell it whether those messages have been opened. The Company may use this information to limit the number of messages sent to customers or stop sending them. Production of up to 1,000 tonnes per year at our facility.
[CONSENT]
to the processing of personal data
to the processing of personal data
By continuing to use www.chemframe.ru (the “Site”), the Site user (the “User”) consents to the processing of their personal data on the terms set out in this consent.
The personal data operator is NPO EUROCHIM LLC (the “Company”), located at 6A Mitrofanyevskoye Shosse, Building D, St Petersburg, 198095, Russia.
The User gives this consent in accordance with Article 9 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” so that the Company can sell goods, perform work and provide services, send important notices about changes to its provisions, terms and policies, and confirm orders placed and purchases made by the User. The Company may also use personal information for internal purposes, including audits, data analysis and other research to improve its products and services and its interactions with customers.
Consent is given to process the following personal data:
— first name, surname and patronymic;
— date of birth;
— sex;
— postal address (for correspondence);
— place of work;
— telephone number;
— email address.
This consent is effective from the date it is signed until it is withdrawn in writing, but for no less than one (1) year from the date on which the User takes actions on the Company’s Site that require the processing of their personal data. Withdrawals of consent to the processing of personal data should be sent to: NPO EUROCHIM LLC, 6A Mitrofanyevskoye Shosse, Building D, St Petersburg, 198095, Russia.
The personal data operator is NPO EUROCHIM LLC (the “Company”), located at 6A Mitrofanyevskoye Shosse, Building D, St Petersburg, 198095, Russia.
The User gives this consent in accordance with Article 9 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” so that the Company can sell goods, perform work and provide services, send important notices about changes to its provisions, terms and policies, and confirm orders placed and purchases made by the User. The Company may also use personal information for internal purposes, including audits, data analysis and other research to improve its products and services and its interactions with customers.
Consent is given to process the following personal data:
— first name, surname and patronymic;
— date of birth;
— sex;
— postal address (for correspondence);
— place of work;
— telephone number;
— email address.
This consent is effective from the date it is signed until it is withdrawn in writing, but for no less than one (1) year from the date on which the User takes actions on the Company’s Site that require the processing of their personal data. Withdrawals of consent to the processing of personal data should be sent to: NPO EUROCHIM LLC, 6A Mitrofanyevskoye Shosse, Building D, St Petersburg, 198095, Russia.
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