1. General provisions
1.1. This Policy sets out the procedure for processing personal data and the measures to ensure its security taken by Общество с ограниченной ответственностью «ФИННВАКУМ» (INN 7718163660, OGRN 1027739459362, registered address: 109377, Россия, г. Москва, ул. Зеленодольская, д. 9, корп. 5, кв. 20) (hereinafter, the Operator).
1.2. The Policy has been prepared in accordance with Russian Federal Law No. 152-FZ “On Personal Data” of 27 July 2006 (hereinafter, the Law) and applies to all information the Operator may obtain about visitors to the website finnvacum.ru (hereinafter, the Website).
1.3. The Policy is publicly available on the Website in accordance with Part 2 of Article 18.1 of the Law.
1.4. Personal data is processed only where there is a legal basis. Consent to the processing of personal data is given in a separate document — the Consent to the processing of personal data.
2. Definitions
Personal data means any information relating directly or indirectly to an identified or identifiable individual (data subject).
Processing of personal data means any operation or set of operations performed on personal data, with or without automation: collection, recording, organisation, accumulation, storage, clarification (updating, alteration), retrieval, use, transfer (provision, access), depersonalisation, blocking, deletion, destruction.
User means any person visiting the Website and (or) sending information to the Operator through the Website forms, by phone, email or messengers.
3. Purposes, data and legal grounds
| Purpose | Data | Legal ground |
|---|---|---|
| Processing requests, consulting, preparing a quote, sending samples | name, phone number and (or) email address, company name, information about the product and task, preferred contact method | consent of the data subject (clause 1, Part 1, Article 6 of the Law) |
| Concluding and performing a supply contract | full name, position, contact details of the counterparty’s representative, shipping address | conclusion and performance of a contract (clause 5, Part 1, Article 6 of the Law) |
| Ensuring the operation and security of the Website, traffic analysis | IP address, cookie data, information about the browser, device and actions on the Website | consent of the data subject |
3.2. The Operator does not process special categories of personal data (on racial or ethnic origin, political views, religious beliefs, health, etc.) or biometric personal data.
3.3. The Operator does not make decisions producing legal effects for the data subject based solely on automated processing of personal data.
4. Procedure and conditions of processing
4.1. Processing is carried out with and without the use of automation.
4.2. When collecting personal data of citizens of the Russian Federation, including through the Website, the Operator ensures its recording, organisation, accumulation, storage, clarification and retrieval using databases located in the Russian Federation (Part 5, Article 18 of the Law).
4.3. Personal data is stored no longer than required by the purposes of processing: data from requests — until the purpose is achieved, but no more than 3 years from the last contact; data related to contract performance — for the periods set by accounting and tax legislation. Upon expiry of these periods or withdrawal of consent, the data is destroyed within 30 days unless otherwise provided by law.
4.4. The Operator does not sell personal data and does not transfer it to third parties without the data subject’s consent, except as provided by the legislation of the Russian Federation. Data may be provided to transport companies to the extent necessary to ship an order.
4.5. If the User chooses to communicate via a messenger (Max, Telegram, WhatsApp), correspondence is conducted by means of the chosen service in accordance with its rules.
5. Cookies and web analytics
5.1. The Website may use cookies necessary for its operation, as well as web analytics services (for example, Yandex Metrica) to analyse traffic and improve the Website.
5.2. Analytics cookies are used with the User’s consent. The User may disable or delete cookies in the browser settings at any time; this may affect some functions of the Website.
5.3. The Contacts page shows a static map image (map data © OpenStreetMap contributors) that is loaded from the Website and does not transfer the User’s data to third-party services. The “Open in Yandex Maps”, “2GIS” and “Google Maps” links lead to the websites of those services; when following them, data is processed by the respective service in accordance with its own rules.
6. Personal data protection measures
The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision and dissemination, including:
- appoints a person responsible for organising personal data processing;
- issues internal regulations on the processing and protection of personal data;
- limits access to personal data to employees who need it to perform their duties;
- uses a secure connection (HTTPS) when transferring data through the Website;
- carries out internal control of compliance of processing with the Law;
- in the event of unlawful transfer (leak) of personal data, notifies Roskomnadzor within the time limits set by Part 3.1, Article 21 of the Law.
7. Rights of the data subject
The data subject has the right to:
- receive information about the processing of their personal data (Article 14 of the Law);
- demand clarification, blocking or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose;
- withdraw consent to the processing of personal data;
- appeal against the actions or inaction of the Operator to Roskomnadzor or in court.
Requests or withdrawal of consent should be sent to info@finnvacum.ru or by post to the Operator’s address. The Operator responds within 10 business days of receiving the request; this period may be extended by no more than 5 business days with a reasoned notice (Part 3, Article 14, Article 20 of the Law).
8. Final provisions
8.1. The Operator may amend the Policy. The new version takes effect when it is published on the Website unless the new version provides otherwise.
8.2. Questions about personal data processing: info@finnvacum.ru, +7 (495) 673-68-69.