Personal Data Processing Policy
1. General ProvisionsThis Personal Data Processing Policy has been developed 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 the measures taken to ensure the security of personal data by Nordtech LLC (hereinafter referred to as the “Operator”).
1.1. The Operator’s primary objective and essential condition for carrying out its activities is to observe the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy and personal and family confidentiality.
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://nordtech-spb.ru.
2. Key Terms Used in the Policy2.1. 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 where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://nordtech-spb.ru.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means enabling their processing.
2.5. Depersonalization (anonymization) of personal data — actions resulting in the impossibility, without the use of additional information, of determining whether personal data belong to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing and determines the purposes of personal data processing, 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 website https://nordtech-spb.ru.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the personal data subject through consent for processing in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User — any visitor to the website https://nordtech-spb.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. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign public authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of restoring their content in a personal data information system and/or destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator3.1. The Operator has the right to:

• receive accurate information and/or documents containing personal data from the personal data subject;
• in the event that the personal data subject withdraws consent for processing or submits a request to terminate processing, continue processing personal data without consent if 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 the obligations stipulated by the Personal Data Law and related regulatory acts, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject, upon request, with information regarding the processing of their personal data;
• organize personal data processing in accordance with the current legislation of the Russian Federation;
• respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the Personal Data Law;
• provide the authorized personal data protection authority with the necessary information within 10 days from the date of receipt of the request;
• publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions;
• terminate the transfer (dissemination, provision, access), cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• perform other duties stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:

• receive information regarding the processing of their personal data, except in cases provided by federal laws. The information shall be provided in an accessible form and must not contain personal data relating to other subjects, except where there are lawful grounds for disclosure. The scope of information and procedure for obtaining it are defined by the Personal Data Law;
• require the Operator to clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
• set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
• withdraw consent to personal data processing and submit a request to terminate processing;
• appeal unlawful actions or inaction of the Operator to the authorized personal data protection authority or in court;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate information about themselves;
• inform the Operator of any clarification (update or modification) of their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that subject’s consent shall bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes for which the personal data were collected shall not be permitted.
5.3. The consolidation of databases containing personal data processed for purposes that are incompatible with one another shall not be permitted.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and scope of the processed personal data shall correspond to the stated purposes of processing. The processed personal data shall not be excessive in relation to the declared purposes of their processing.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or in the event that the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of Processing:
Clarification of cooperation details.
Personal Data:

• Surname, first name, patronymic
• Telephone numbers

Legal Grounds:

• Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection.”

Types of Personal Data Processing:

• Collection, recording, systematization, accumulation, storage, destruction, and anonymization (depersonalization) of personal data.

7. Conditions for Personal Data Processing
7.1. Personal data shall be processed with the consent of the personal data subject.
7.2. Personal data processing 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. Personal data processing is necessary for the administration of justice, execution of a court decision, or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into 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. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out in respect of 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 is carried out in respect of personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Forms of Personal Data ProcessingThe security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with applicable personal data protection legislation.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except where required by applicable law or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update such data independently by sending a notification to the Operator via email at nordtech-spb@mail.ru marked “Personal Data Update.”
8.4. The period of personal data processing shall be determined by the achievement of the purposes for which the personal data were collected, unless another period is provided by contract or applicable law.
The User may withdraw consent to personal data processing at any time by sending a notification to the Operator via email at nordtech-spb@mail.ru marked “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, shall be stored and processed by such entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall independently review these documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Any prohibitions established by the personal data subject on the transfer (except for granting access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for dissemination, shall not apply where personal data are processed in state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures their confidentiality.
8.8. The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, a request to terminate processing, or detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transmission of the obtained information via information and telecommunication networks or without using such networks.
10. Cross-Border Transfer of Personal Data10.1. Prior to initiating cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such transfer (such notification shall be submitted separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator shall obtain the necessary 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 DataThe Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at nordtech-spb@mail.ru.
12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at: [website address].