Privacy Policy for Personal Data Processing

1. General ProvisionsThis Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by LLC "NPP Center Composite" (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with 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 a key condition of its activities.
1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://hpl-russia.ru/.

2. Key Terms 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 personal data processing (except when processing is required to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as software and databases that ensure their availability on the Internet at https://hpl-russia.ru/.
2.4. Personal data information system – a set of personal data contained in databases and the technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific user or other personal data subject.
2.6. Processing of personal data – any action (operation) or set of actions performed with personal data using automation tools or without them, including collection, recording, systematization, accumulation, storage, updating, modification, extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or processes personal data and determines the purposes and scope of such processing.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable user of the website https://hpl-russia.ru/.
2.9. Personal data permitted for distribution – personal data made available to an unlimited number of persons with the consent of the data subject, in accordance with the Personal Data Law.
2.10. User – any visitor of the website https://hpl-russia.ru/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Distribution of personal data – actions aimed at disclosing personal data to an unlimited number of persons, including publication in media, posting on the Internet, or providing access by other means.
2.13. Cross-border transfer of personal data – transfer of personal data to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – actions that irreversibly destroy personal data without the possibility of recovery.

3. 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 personal data subject.

• Continue processing personal data without the consent of the subject if such consent is withdrawn, provided that there are legal grounds specified in the Personal Data Law.
• Independently determine the composition and list of measures necessary and sufficient to ensure compliance with legal obligations regarding personal data protection.

3.2 The Operator is obliged to:Provide personal data subjects with information concerning the processing of their personal data upon request.

• Organize the processing of personal data in accordance with the legislation of the Russian Federation.
• Respond to requests from personal data subjects and their representatives in accordance with the Personal Data Law.
• Provide necessary information to the authorized personal data protection authority upon request within 10 days.
• Publish or otherwise ensure unrestricted access to this Privacy Policy.
• Take legal, organizational, and technical measures to protect personal data from unauthorized access, destruction, alteration, blocking, copying, distribution, or other unlawful actions.
• Stop transferring and processing personal data and destroy personal data in cases established by law.
• Fulfill other obligations provided for by Russian legislation.

4. 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 by law.

• Request clarification, blocking, or deletion of their personal data if such data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the processing purpose.
• Require prior consent for the processing of personal data for marketing purposes.
• Withdraw consent for personal data processing.
• Appeal unlawful actions or inaction of the Operator to the authorized supervisory authority or in court.
• Exercise other rights provided by the legislation of the Russian Federation.

4.2 Personal data subjects are obliged to:Provide accurate personal data.

• Notify the Operator of any changes or updates to their personal data.

4.3 Individuals who provide false information about themselves or about another person without their consent bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1 Personal data processing is carried out on a lawful and fair basis.
5.2 Processing of personal data is limited to achieving specific, predetermined, and legitimate purposes.
5.3 The merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4 Only personal data that meets the purposes of processing shall be processed.
5.5 The scope and content of personal data must correspond to the stated processing purposes and must not be excessive.
5.6 The Operator ensures the accuracy and relevance of personal data and takes necessary measures to update or delete inaccurate or incomplete data.
5.7 Personal data shall be stored in a form allowing identification of the data subject no longer than necessary for processing purposes, unless a different storage period is required by law or contract. After achieving the processing purposes, personal data shall be destroyed or anonymized unless otherwise required by law.

6. Purposes of Personal Data Processing

• Full name (surname, name, patronymic)
• Email address
• Phone numbers

• The Operator’s charter (founding) documents
• Agreements concluded between the Operator and the personal data subject

• Collection
• Recording
• Systematization
• Accumulation
• Storage
• Destruction
• Depersonalization of personal data

7. Conditions for Personal Data Processing

7.1. Personal data processing is carried out with the consent of the personal data subject.
7.2. Processing of personal data is necessary to achieve the purposes provided for by international treaties of the Russian Federation or by law, and to perform functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a court act, or an act of another authority or official subject to execution in accordance with Russian legislation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, or for entering into a contract at the initiative of the personal data subject.
7.5. Processing of personal data is necessary for the exercise of the Operator’s rights and legitimate interests or those of third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out for personal data made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures required to fully comply with applicable personal data protection legislation.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never be transferred to third parties under any circumstances, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator for such transfer to fulfill obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator via email at info@cntcom.ru with the subject line “Personal Data Update.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the data was collected unless otherwise provided by a contract or applicable law.
The User may withdraw consent for personal data processing at any time by sending an email notification to info@cntcom.ru with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. Any information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties in accordance with their own user agreements and privacy policies. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject regarding transfer (except for providing access) or processing conditions of personal data permitted for distribution do not apply in cases where processing is carried out in the public interest as defined by Russian law.
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 allows identification of the personal data subject no longer than necessary for processing purposes, unless a longer storage period is required by law or contract.
8.9. The termination of personal data processing may occur when:

• the processing purposes are achieved,
• the consent of the personal data subject expires,
• the consent is withdrawn,
• the subject requests termination of processing,
• unlawful processing of personal data is detected.

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

9.1. The Operator performs the following actions with personal data:
collection, recording, systematization, accumulation, storage,clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking,deletion,destruction
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of information via information and telecommunications networks or without them.телекоммуникационным сетям или без таковой.

10. Cross-Border Transfer of Personal Data

10.1. Before carrying out cross-border transfer of personal data, the Operator must notify the authorized authority responsible for protecting the rights of personal data subjects of its intention to carry out such transfer.
10.2. Prior to submitting the above notification, the Operator must obtain relevant information from foreign government authorities, foreign individuals, or foreign legal entities to whom the personal data will be transferred.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at info@cntcom.ru.
12.2. Any changes to this personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at:
https://hpl-russia.ru/privacy-policy