Privacy and Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC PromEnergo (hereinafter — the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, as its primary goal and essential condition for carrying out its activities.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors of the website https://promenergo.pro/.

2. Basic Concepts 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 the processing of personal data (except where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://promenergo.pro/.

2.4. Information system of personal data — a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data.

2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://promenergo.pro/.

2.9. Personal data permitted by the subject of personal data for distribution — personal data to which an unlimited number of persons have access provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in accordance with the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor of the website https://promenergo.pro/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in mass 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 — the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or physical media of personal data are destroyed.

3. Basic 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 subject of personal data; — in case the subject of personal data withdraws consent to the processing of personal data, as well as submits a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 for by the Personal Data Law or other federal laws.

3.2. The Operator must:

— provide the subject of personal data, upon request, with information regarding the processing of their personal data;

— organize the processing of personal data in accordance with the current legislation of the Russian Federation;

— respond to appeals and requests of subjects of personal data 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 subjects of personal data, upon request of this body, with the necessary information within 10 days from the date of receipt of such a request;

— publish or otherwise provide 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, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to personal data;

— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;

— fulfill other duties stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it 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;

— demand the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;

— require prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;

— withdraw consent to the processing of personal data, as well as submit a request to terminate the processing of personal data;

— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;

— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects must:

— provide the Operator with accurate information about themselves;

— notify the Operator about clarifying (updating, changing) their personal data.

4.3. Persons who provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. It is not permitted to combine databases containing personal data, the processing of which is carried out 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 personal data being processed correspond to the stated purposes of processing. The redundancy of personal data being processed in relation to the stated purposes of their processing is not permitted.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, party, beneficiary, or guarantor of which is the personal data subject. Processed personal data is destroyed or depersonalized upon achievement of processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided for by federal law.

6. Purposes of Personal Data Processing

Purpose of processing

informing the User by sending emails;

providing the “Callback” service;

providing the User with access to services, information, and/or materials contained on the website

Personal data

last name, first name, patronymic, email address, phone numbers

Legal grounds

Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ of 27.07.2006

Types of personal data processing

Sending informational emails to the email address, callback

7. Conditions of Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to exercise the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another body 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, a party to which, or a beneficiary or guarantor under which, is the subject of personal data, as well as for the conclusion of a contract initiated by the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the subject of personal data are not thereby violated.

7.6. Processing of personal data is carried out if access to an unlimited number of persons is provided by the subject of personal data or at their request (hereinafter — publicly available personal data).

7.7. Processing of personal data is carried out if the personal data are subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing 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 safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except for cases related to compliance with current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party in order to fulfill obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address info@promenergo.pro with the note “Update of personal data.”

8.4. The period of personal data processing is determined by achieving the purposes for which personal data was collected, unless another period is provided for by contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@promenergo.pro with the note “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 these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data must familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. Restrictions established by the subject of personal data on the transfer (except granting access), as well as on processing or conditions of processing (except obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data during their processing.

8.8. The Operator stores personal data in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, party, beneficiary, or guarantor of which is the personal data subject.

8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the validity period of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or the requirement to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information through information and telecommunication networks or without them.

10. Cross-Border Transfer of Personal Data

10.1. Before carrying out cross-border transfer of personal data, the Operator must 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-mentioned notification, the Operator must obtain the relevant information from the authorities of a foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.

11. 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 subject of personal data, unless otherwise provided for by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@promenergo.pro.

12.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://promenergo.pro/privacy.