Moscow, Russia

Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 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 taken by EMT (hereinafter referred to as the Operator).

The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.

This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://emtrpe.com.

2. Basic Concepts Used in the Policy

  • Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://emtrpe.com;
  • Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data;
  • User — any visitor to the website https://emtrpe.com;
  • Automated processing of personal data — processing of personal data using computer technology;
  • Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data);
  • Anonymization of personal data — actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific User or other subject of personal data;
  • Destruction of personal data — any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoration of the content of personal data.

3. Basic Rights and Obligations of the Operator

The Operator has the right to:

  • Receive reliable information and/or documents containing personal data from the subject of personal data;
  • In case of withdrawal of consent to the processing of personal data by the subject, the Operator has the right to continue processing personal data without the consent of the 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 fulfillment of obligations provided for by the Personal Data Law.

The Operator is obliged to:

  • Provide the subject of personal data, at their request, with 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;
  • 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 unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data.

4. Basic Rights and Obligations of Personal Data Subjects

Personal data subjects have the right to:

  • Receive information regarding the processing of their personal data, except in cases provided for by federal laws;
  • Require the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, or illegally obtained;
  • Withdraw consent to the processing of personal data, as well as 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 actions or inaction of the Operator in processing their personal data.

Personal data subjects are obliged to:

  • Provide the Operator with reliable data about themselves;
  • Inform the Operator about clarification (updating, changing) of their personal data.

5. Principles of Personal Data Processing

  • Processing of personal data is carried out on a lawful and fair basis;
  • Processing of personal data is limited to achieving specific, predetermined and legitimate purposes;
  • Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed;
  • Only personal data that meets the purposes of their processing are subject to processing;
  • The content and volume of processed personal data correspond to the stated purposes of processing;
  • When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data is ensured;
  • Storage of personal data is carried out in a form that allows identifying the subject of personal data for no longer than required by the purposes of processing personal data.

6. Personal Data Processed by the Operator

  • Full name;
  • Email address;
  • Phone numbers;
  • Company name and position;
  • The website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrica and others).

7. Purposes of Personal Data Processing

The purpose of processing User's personal data is to inform the User by sending emails; providing the User with access to services, information and/or materials contained on the website; clarifying order/request details.

The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending a letter to the Operator at the email address 416861032qq@gmail.com with the note 'Unsubscribe from notifications'.

8. Legal Grounds for Personal Data Processing

The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://emtrpe.com or sent to the Operator by email. By filling out the appropriate forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

The Operator processes anonymized data about the User if this is allowed in the User's browser settings (saving cookies and using JavaScript technology is enabled).

9. Procedure for Collection, Storage, Transfer 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.

The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

If inaccuracies in personal data are detected, the User can update them independently by sending a notification to the Operator at the email address 416861032qq@gmail.com with the note 'Update of personal data'.

The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to 416861032qq@gmail.com with the note 'Withdrawal of consent to the processing of personal data'.

The Operator ensures the confidentiality of personal data when processing personal data.

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

The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes and destroys personal data.

The Operator carries out automated processing of personal data with the receipt and/or transmission of received information via information and telecommunication networks or without it.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final Provisions

The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at 416861032qq@gmail.com.

This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.

The current version of the Policy is freely available on the Internet at https://emtrpe.com/privacy.

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416861032qq@gmail.com

+7 (800) 201-52-88

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