Policy on Personal Data Processing
1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law of 27.07.2006 No. 152-ФЗ “On Personal Data” (hereinafter – the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC “SIEM GROUP” (hereinafter – the Operator).
1.1. The Operator’s most important goal and condition for carrying out its activities is the observance of the rights and freedoms of a person and citizen in the processing of their personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors to the website https://cmsupply.pro/.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://cmsupply.pro/.
2.4. Personal data information system – the aggregate of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions resulting in it being impossible to determine, without the use of additional information, the personal data’s belonging to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal or individual person who independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a defined or definable User of the website https://cmsupply.pro/.
2.9. Personal data permitted by the subject of personal data for dissemination – personal data, access to which is granted to an unlimited circle of persons by the subject of personal data by giving consent to the processing of personal data permitted by the subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data permitted for dissemination).
2.10. User – any visitor of the website https://cmsupply.pro/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in personal data being irreversibly destroyed with no possibility of further restoration of the personal data content in the personal data information system and (or) resulting in the destruction of physical carriers of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
• receive from the subject of personal data truthful information and/or documents containing personal data;
• continue processing personal data without the consent of the subject of personal data if the subject withdraws consent to personal data processing, or if a request to stop personal data processing is submitted, provided there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations under 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 subject of personal data, at their request, information regarding the processing of their personal data;
• organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
• report to the authorized body for the protection of the rights of subjects of personal data, upon request from this body, the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted 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, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
• stop transferring (distributing, providing, accessing) personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• perform other duties as provided by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Subjects of personal data have the right to:
• receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator provides the personal data subject with the information in an accessible form, and it should 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 is established by the Personal Data Law;
• demand that the Operator clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, obtained unlawfully, or not necessary for the stated purpose of processing, as well as take measures prescribed by law to protect their rights;
• set a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services;
• withdraw consent to the processing of personal data at any time, and send a request to stop processing personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in processing their personal data;
• exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
• provide the Operator with accurate data about themselves;
• inform the Operator of any clarification (updating, change) of their personal data.
4.3. Persons who transfer inaccurate data about themselves to the Operator, or data 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 legitimate 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 combine databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing, shall be ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the personal data subject no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the processing purposes or in case the necessity of achieving those purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
<table>
<tr><th>Purpose of Processing</th><th>Personal Data</th><th>Legal Grounds</th><th>Types of Personal Data Processing</th></tr>
<tr><td>Informing the User via email</td><td>Last name, first name, patronymic;
email address;
phone numbers;
address of residence and registration address</td><td>Constituent (founding) documents of the Operator</td><td>Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data;
Sending informational emails to the email address</td></tr>
</table>

7. Conditions of Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The 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 the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data 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. Processing of personal data is carried out, access to an unlimited circle of persons to which is provided by the personal data subject or at their request (hereinafter – publicly available personal data).
7.7. Processing of personal data that is subject to publication or mandatory disclosure in accordance with federal law is being carried out.
8. Procedure for 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 preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator’s email address cmsupply@bk.ru with the subject line “Updating personal data”.
8.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected, unless another period is provided by contract or applicable law. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to the Operator’s email address cmsupply@bk.ru with the subject line “Withdrawal of consent to personal data processing”.
8.5. All information that is collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to independently familiarize themselves with those documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. The restrictions established by the personal data subject on transfer (except providing access), as well as on processing or conditions of processing (except obtaining access) of personal data permitted for dissemination, do not apply in cases of personal data processing in the state, public, and other public interests as 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 allows determining the personal data subject no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. A condition for terminating the processing of personal data may be the achievement of the personal data processing purposes, the expiry of the personal data subject’s consent, the withdrawal of consent by the personal data subject, or a demand to cease the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out the automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such means.
10. Cross-Border Transfer of Personal Data
10.1. Prior to the commencement of 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 sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is intended, the appropriate assurances regarding the protection of the transferred data.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose to third parties or disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at cmsupply@bk.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://cmsupply.pro/privacy.