Personal Data Processing Policy
1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-ФЗ “On Personal Data” and determines the procedure for processing personal data and measures to ensure the security of personal data of KALUGA TOBACCO FACTORY LLC (hereinafter the “Operator”).
1. The operator sets as his most important goal and condition for the implementation of his activities the observance of the rights and freedoms of man and citizen in the processing of his personal data, including the protection of rights to privacy, personal and family secrets.
2. This Operator’s policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator can receive about visitors to the website https://en.ktftobacco.ru.
2. Key Concepts Used in Politics
1. Automated processing of personal data — processing of personal data using computer technology;
2. Blocking of personal data — temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data);
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://en.ktftobacco.ru;
4. Information system of personal data — a set of personal data contained in databases, and ensuring their processing of information technologies and technical means;
5. Anonymization of personal data — actions, as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other personal data subject;
6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
7. Operator — a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) committed with personal data;
8. Personal data — any information relating directly or indirectly to a specific or determined User of the website https://en.ktftobacco.ru
9. User — any visitor to the website https://en.ktftobacco.ru
10. Providing personal data — actions aimed at disclosing personal data to a specific person or a certain circle of persons;
11. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or to familiarizing oneself with personal data of an unlimited number of persons, including disclosing personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way;
12. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or foreign legal entity;
13. Destruction of personal data — any actions as a result of which personal data is permanently destroyed with the inability to further restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.
3. The operator may process the following personal data of the User
1. Surname, name, patronymic;
2. Email address;
3. Phone numbers;
4. The site also collects and processes anonymized data about visitors (including cookies) with the help of Internet statistics services (Yandex Metric and Google Analytics and others).
5. The above data hereinafter referred to in the Policy are united by the general concept of Personal Data.
4. Purpose of processing personal data
1. The purpose of processing the User’s personal data is to inform the User by sending emails.
2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The user can always refuse to receive informational messages by sending an e-mail to the Operator to the email address firstname.lastname@example.org marked «Refusal to notify of new products and services and special offers.»
3. Anonymized data of Users, collected using the Internet statistics services, are used to collect information about the actions of Users on the site, improve the quality of the site and its content.
5. Legal basis for the processing of personal data
1. The operator processes the User’s personal data only if they are filled and / or sent by the User independently through special forms located on the site https://en.ktftobacco.ru. By filling out the appropriate forms and / or sending your personal data to the Operator, the User expresses his consent to this Policy.
6. The procedure for the collection, storage, transfer and other types of processing of personal data
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 the current legislation in the field of personal data protection.
1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
2. The User’s personal data will never, under any circumstances, be transferred to third parties, with the exception of cases related to the implementation of applicable law.
3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s email address email@example.com marked “Updating personal data”.
4. The term for processing personal data is unlimited. The user can at any time withdraw his consent to the processing of personal data by sending a notification to the Operator by e-mail to the operator’s email address firstname.lastname@example.org marked “Revocation of consent to the processing of personal data”.
7. Cross-border transfer of personal data
1. The operator, prior to the start of the cross-border transfer of personal data, is obliged to make sure that the foreign state in whose territory it is supposed to transfer personal data provides reliable protection of the rights of the subjects of personal data.
2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the personal data subject to the cross-border transfer of his personal data and / or the execution of the contract to which the personal data subject is a party.
8. Final provisions
1. The user can get any clarification on questions of interest regarding the processing of his personal data by contacting the Operator via e-mail email@example.com.
2. This document will reflect any changes in the policy of processing personal data by the Operator. The policy is valid indefinitely until it is replaced with a new version.
3. The current version of the Policy is freely available on the Internet at https://en.ktftobacco.ru/pivacy-policy/.