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Policy on personal data processing

  1. General Provisions

This policy of processing of personal data is made according to requirements of the Federal law dated 27.07.2006. № 152-FZ “About personal data” (hereinafter referred to as the Law on personal data) and defines the order of processing of personal data and measures on providing security of personal data, undertaken by SOIL COMMODITIES & LOGISTICS LCC (hereinafter referred to as the Operator).

1.1 The Operator sets as its most important objective and condition for realization its activity observance a human and citizen’s rights and freedoms at processing of his personal data, including protection of the rights to privacy, personal and family secrets.

1.2 The present Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information which the Operator can obtain about the visitors of the website https://soilcoms.com/.

2. Basic concepts used in the Policy

2.1 Automated processing of personal data – processing of personal data by means of computer equipment.

2.2 Blocking of personal data – is temporary termination of processing of personal data (except when the processing is necessary to clarify personal data).

2.3 Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://soilcoms.com/.

2.4 Personal Data Information System – a set of personal data contained in databases of personal data and information technologies and technical means ensuring their processing.

2.5 De-identification of personal data – actions, as a result of which it is impossible to determine, without using additional information, what personal data belongs to a particular User or other subject of personal data.

2.6 Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation means 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 entity or individual, independently or jointly with other persons, arranging and/or carrying out processing of personal data, as well as determining the purpose of processing of personal data, composition of personal data to be processed, actions (operations) performed with personal data.

2.8 Personal data – any information relating directly or indirectly to a particular or defined User of the website https://soilcoms.com/.

2.9. Personal data, authorized by the subject of personal data for distribution – personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter – personal data, authorized for distribution).

2.10. User – any visitor of https://soilcoms.com/ website.

2.11. Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of people.

2.12. Dissemination of personal data – any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize the general public with personal data, including publication of personal data in the media, placement in information and telecommunications 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 a foreign state authority, a foreign individual or a foreign legal entity.

2.14. Personal data destruction – any actions, as a result of which personal data is destroyed with no further possibility to restore the content of personal data in the information system of personal data and/or material 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 subject of personal data reliable information and/or documents containing personal data;

– in case the personal data subject withdraws consent to personal data processing, as well as in case of sending a request to terminate personal data processing, the Operator has the right to continue processing of personal data without the consent of the personal data subject, if there are grounds specified in the Personal Data Law;

– to independently determine the composition and list of measures, necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2 The Operator shall:

– provide the subject of personal data, at his/her request, with information relating to the processing of his/her personal data;

– organize the processing of personal data in the manner prescribed by applicable laws of the Russian Federation;

– respond to requests and inquiries of subjects of personal data and their legal representatives, in accordance with the requirements of the Law on Personal Data;

– communicate to the authority responsible for the protection of human subjects of personal data, at the request of such body, the necessary information within 10 days from the date of receipt of such request

– publish or otherwise ensure unrestricted access to this Policy on personal data processing

– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions in relation to personal data

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

– fulfill other obligations laid down by the Personal Data Law.

4. The basic rights and obligations of subjects of personal data

4.1 The subjects of personal data have the right:

– To receive information relating to the processing of his personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;

– to require the Operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;

– to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market

– to withdraw the consent to the processing of personal data, as well as to request the cessation of personal data processing

– to appeal to the authorized body for protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of his personal data

– to exercise other rights provided by the legislation of the Russian Federation.

4.2 Subjects of personal data shall:

– provide the Operator with reliable data about themselves;

– notify the Operator of the clarification (updating, modification) of their personal data. 4.3.

4.3 Persons who provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Russian Federation.

5. Personal data processing principles

5.1 Personal data processing is performed on a lawful and fair basis.

5.2 Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes for which the personal data is collected is not permitted.

5.3 Databases containing personal data, which are processed for purposes incompatible with each other, shall not be combined.

5.4 Only personal data that meets the purposes of processing shall be processed.

5.5 The content and scope of processed personal data shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.

5.6 When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purpose of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.

5.7 Personal data shall be stored in a form that makes it possible to identify the subject of personal data, no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, a contract, a party to which, a beneficiary or a guarantor under which the subject of personal data is a party. Processed personal data shall be destroyed or depersonalized upon attainment of processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.

6. Purposes of processing of personal data

Purpose of processing clarification of order details

Personal data      

last name, first name, middle name

E-mail address

telephone numbers

Legal basis          

The contracts concluded between the Operator and the subject of personal data

Types of processing of personal data           

Sending informative letters to the e-mail address

7. Processing conditions of personal data

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

7.2 Personal data processing is necessary for achieving the objectives envisaged by an international treaty of the Russian Federation or by law, for implementing the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.

7.3 Personal data processing is necessary for administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4 Personal data processing shall be necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which the personal data subject is a party, as well as for conclusion of an agreement on the initiative of the personal data subject or an agreement, 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 important goals, provided that this does not violate the rights and freedoms of the subject of personal data.

7.6 Personal data shall be processed if access to such data is granted to an unlimited number of persons by or at the request of the personal data subject (hereinafter, “publicly available personal data”).

7.7 Personal data subject to publication or compulsory disclosure in accordance with the federal law shall be processed.

8. Procedure for collection, storage, transfer and other processing of personal data

Security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to meet in full the requirements of current legislation in the field of personal data protection.

8.1 The Operator provides safety of personal data and takes all possible measures, excluding access to personal data by unauthorized persons.

8.2 The personal user’s data will never, under no circumstances be transferred to third parties, except in cases related to the implementation of the 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.

8.3 In case of identification of inaccuracies in personal data, the User may update them independently by sending a notice to the Operator’s e-mail address info@soilcoms.com with a note “Updating of personal data”.

8.4 Processing period of personal data is determined by achieving the purposes for which the personal data was collected, unless a different period is stipulated by the contract or applicable law.

The user may withdraw their consent to the processing of personal data at any time by sending a notice via email to the Operator’s email address info@soilcoms.com marked “Withdrawal of consent to the processing of personal data”.

8.5 The whole information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.

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

8.7. The Operator shall ensure the confidentiality of personal data when processing personal data.

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

8.9 A condition for termination of personal data processing may be the achievement of personal data processing objectives, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a requirement to terminate personal data processing, as well as the discovery of unlawful personal data processing.

9. List of actions performed by the Operator with personal data received

9.1 The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.

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

10. Cross-border transfer of personal data

10.1 The Operator must notify the competent authority for the protection of personal data subjects’ rights of its intention to transfer personal data across borders (such notification is sent separately from the notification of intention to process personal data) before commencing the transborder transfer of personal data.

10.2 Before submitting the above notification, the Operator must obtain the relevant information from the foreign authorities, foreign individuals, foreign legal entities to which the trans-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who obtained 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 can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator by e-mail at info@soilcoms.com.

12.2 This document will reflect any changes in the personal data processing policy of the Operator. 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://soilcoms.com/privacy-policy/.