This is a courtesy translation; the Russian version prevails.
Personal Data Processing Policy
1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” of 27.07.2006 (hereinafter, the Personal Data Law) and sets out the procedure for processing personal data and the measures taken by Trading House Moscow Fish Processing Plant LLC (hereinafter, the Operator) to ensure the security of personal data.
1.1. The Operator’s most important goal and condition for carrying out its activities is the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family secrets.
1.2. This Operator’s policy on the processing of personal data (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the websites https://td-mrk.ru and https://market.td-mrk.ru.
2. Basic terms used in the Policy
2.1. Automated processing of personal data — processing of personal data by means of 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 information materials, as well as computer programs and databases, that make them available on the Internet at the network addresses https://td-mrk.ru and https://market.td-mrk.ru.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalisation of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belong to a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with other persons, organises and/or carries out the processing of personal data, and also determines the purposes of processing personal data, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the websites https://td-mrk.ru and https://market.td-mrk.ru.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter, personal data permitted for distribution).
2.10. User — any visitor to the websites https://td-mrk.ru and https://market.td-mrk.ru.
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 the 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 — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, 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, making it impossible to further restore the content of the personal data in the personal data information system, and/or the physical media of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— if the personal data subject withdraws consent to the processing of personal data, or sends a request to stop the processing of personal data, the Operator may continue processing the personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided for by the Personal Data Law and the regulations 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 personal data subject, at their request, with information concerning the processing of their personal data;
— organise the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorised body for the protection of the rights of personal data subjects, at the request of that body, with the necessary information within 10 days of the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
— take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision or distribution of personal data, as well as from other unlawful actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop the processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform other obligations provided for 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 concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except 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 that the operator clarify, block or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and also take measures provided for by law to protect their rights;
— set a condition of prior consent when personal data are processed for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data, and also send a request to stop the processing of personal data;
— appeal against unlawful actions or inaction of the Operator in the processing of their personal data to the authorised body for the protection of the rights of personal data subjects or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable information about themselves;
— inform the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data are processed 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 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 the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of their processing.
5.6. When personal data are processed, their accuracy, sufficiency and, where necessary, relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that makes it possible to identify the personal data subject for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. The personal data processed are destroyed or depersonalised once the purposes of processing have been achieved or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing — informing the User by sending emails.
Personal data:
— surname, first name, patronymic;
— email address;
— telephone numbers.
Legal grounds: Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” of 27.07.2006.
Types of personal data processing: transfer of personal data.
7. Conditions for the processing of personal data
7.1. Personal data are processed 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 the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and obligations 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 or the execution of a judicial act, or of an act of another body or official, subject to execution 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 concluding 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 to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data are processed to which the personal data subject has granted access to an unlimited number of persons, or at the subject’s request (hereinafter, publicly available personal data).
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. 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 by implementing the legal, organisational 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 prevent access to personal data by unauthorised 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 current legislation, or if the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are found in the personal data, the User may update them independently by sending the Operator a notice to the Operator’s email address info@td-mrk.com marked “Updating personal data”.
8.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator’s email address info@td-mrk.com marked “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the said documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions set by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases where personal data are processed in state, public and other public interests 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 makes it possible to identify the personal data subject for no longer than the purposes of processing personal data require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiry of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to stop 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 the personal data received
9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), depersonalises, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before starting cross-border transfers of personal data, the Operator is obliged to notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data (such notice is sent separately from the notice of intention to process personal data).
10.2. Before submitting the above notice, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to which 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 them without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator by email at info@td-mrk.com.
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://td-mrk.ru/policy and https://market.td-mrk.ru/policy.