Personal Data Processing Policy

This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 “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 undertaken by JSC "NPK "SPP" (hereinafter referred to as the Operator).

1. The Operator considers observance of human and civil rights and freedoms in the processing of personal data, including protection of the rights to privacy, personal and family confidentiality, to be its most important goal and condition for carrying out its activities.
2. This Operator's personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://npk-spp.ru/.

1. Automated processing of personal data means processing of personal data using computer technology.
2. Blocking of personal data means temporary suspension of personal data processing, except where processing is necessary to clarify personal data.
3. Website means a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at https://npk-spp.ru
4. Personal data information system means a set of personal data contained in databases and information technologies and technical means ensuring their processing.
5. Depersonalization of personal data means actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or another personal data subject.
6. Processing of personal data means any action (operation) or a set of actions (operations) performed with or without automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
7. Operator means a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
8. Personal data means any information directly or indirectly related to an identified or identifiable User of the website https://npk-spp.ru/.
9. Personal data permitted by the personal data subject for distribution means personal data to which access by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
10. User means any visitor to the website https://npk-spp.ru/.
11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in the mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
13. Cross-border transfer of personal data means transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual or foreign legal entity.
14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data with no possibility of further restoring the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.

1. The Operator has the right to:
   • receive accurate information and/or documents containing personal data from the personal data subject;
   • if the personal data subject withdraws consent to personal data processing, continue processing personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
   • independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations provided for by the Personal Data Law and regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
2. The Operator is obliged to:
   • provide the personal data subject, upon request, with information concerning the processing of their personal data;
   • organize personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
   • respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
   • provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 30 days from the date of receipt of such request;
   • publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
   • take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions in relation to personal data;
   • cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
   • fulfill other obligations provided for by the Personal Data Law.

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 shall be provided to the personal data subject by the Operator in an accessible form and shall 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;
   • request that the Operator clarify their personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and take measures provided by law to protect their rights;
   • set a condition of prior consent when personal data is processed for the purpose of promoting goods, works and services on the market;
   • withdraw consent to personal data processing;
   • appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction
   • of the Operator in the processing of their personal data;
   • exercise other rights provided for by the legislation of the Russian Federation.
2. Personal data subjects are obliged to
   • provide the Operator with accurate data about themselves;
   • notify the Operator of any clarification (updating, modification) of their personal data.
3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter's consent shall be liable in accordance with the legislation of the Russian Federation.

1. Last name, first name, patronymic.
2. Email address.
3. Telephone numbers.
4. Year, month, date and place of birth.
5. Photographs.
6. The website also collects and processes depersonalized data about visitors, including cookie files, using the Yandex.Metrica web analytics service.
7. The above data are hereinafter collectively referred to in the Policy as Personal Data.
8. The Operator does not process special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, or intimate life.
9. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for by Article 10.1 of the Personal Data Law are complied with.
10. The User's consent to the processing of personal data permitted for distribution is executed separately from other consents to the processing of their personal data. In this case, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law shall be observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
    1. The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
    2. The Operator is obliged, no later than three business days from the date of receipt of the User's consent, to publish information on the processing conditions and on the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.
    3. The transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be terminated at any time at the request of the personal data subject. Such request must include the last name, first name, patronymic (if any), contact information (telephone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing must be terminated. The personal data specified in such request may be processed only by the Operator to whom it is sent.
    4. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.10.3 of this Personal Data Processing Policy.

1. Principles of personal data processing
2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
3. Combining databases containing personal data whose processing is carried out for purposes incompatible with each other is not permitted.
4. Only personal data that meet the purposes of their processing shall be processed.
5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not permitted.
6. When processing personal data, accuracy, sufficiency and, where necessary, relevance of personal data in relation to the purposes of personal data 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.
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 personal data processing, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or if the need to achieve such purposes is lost, unless otherwise provided by federal law.

1. The purpose of processing the User's personal data is:
   • informing the User by sending emails;
   • conclusion, performance and termination of civil law contracts;
   • providing the User with access to services, information and/or materials available on the website https://npk-spp.ru/.
2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may always opt out of receiving informational messages by sending an email to the Operator at spp@npk-spp.ru with the subject line “Refusal of notifications about new products and services and special offers”.
3. Depersonalized User data collected using web analytics services are used to collect information about Users' actions on the website, improve the quality of the website and its content.

1. The legal grounds for personal data processing by the Operator are:
   • Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”;
   • Federal Law No. 149-FZ dated 27.07.2006 “On Information, Information Technologies and Information Protection”;
   • the Civil Code of the Russian Federation;
   • other regulatory legal acts of the Russian Federation governing relations related to personal data processing;
   • the Operator's charter documents;
   • contracts concluded between the Operator and personal data subjects;
   • consents of personal data subjects to the processing of their personal data.
2. The Operator processes the User's personal data only if it is filled in and/or submitted by the User independently through special forms located on the website https://npk-spp.ru/ or sent to the Operator by email. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses consent to this Policy.
3. The Operator processes depersonalized data about the User if this is permitted in the User's browser settings (saving of cookie files and use of JavaScript technology are enabled).
4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own will and in their own interest.

1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
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 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.
5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
6. Personal data is processed when access to it by an unlimited number of persons has been provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
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 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.
3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator's email address spp@npk-spp.ru with the subject line “Personal data update”.
4. The period of personal data processing is determined by achievement of the purposes for which the personal data was collected, unless another period is provided for by a contract or current legislation. The User may at any time withdraw consent to personal data processing by sending a notice by email to the Operator's email address spp@npk-spp.ru with the subject line “Withdrawal of consent to personal data processing”.
5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
6. Prohibitions established by the personal data subject on transfer (except for granting access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public and other public interests determined by the legislation of the Russian Federation.
7. The Operator ensures confidentiality of personal data when processing it.
8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor.
9. The condition for termination of personal data processing may be achievement of the purposes of personal data processing, expiry of the personal data subject's consent, withdrawal of consent by the personal data subject, or identification of unlawful processing of personal data.

1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes and destroys personal data.
2. The Operator carries out automated processing of personal data with or without receiving and/or transferring the received information via information and telecommunication networks.

1. Before carrying out cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the personal data is to be transferred provides reliable protection of the rights of personal data subjects
2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if the personal data subject provides written consent to the cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.

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 personal data without the consent of the personal data subject, unless otherwise provided by federal law.

1. When visiting the website https://npk-spp.ru/, cookie files may be stored on the User's device and other similar technologies may be used.
2. Cookie files are small text files stored by the User's browser that help ensure the correct operation of the website, remember user settings, analyze website usage, and improve the quality of services provided.
3. The Operator uses technical, functional and analytical cookie files, including through the Yandex.Metrica web analytics service, to obtain depersonalized information about Users' actions on the website, evaluate website traffic, analyze traffic sources, improve the usability of the website and improve its operation.
4. Information collected using cookie files is not used by the Operator to identify the User without obtaining additional information and is processed in accordance with the requirements of the legislation of the Russian Federation.
5. The User has the right to change cookie settings or completely disable cookies in their browser settings. At the same time, disabling cookies may make it impossible to use certain website functions.
6. By continuing to use the website after the relevant notice (banner) is displayed, the User expresses consent to the use of cookies in the manner provided for by this Policy.

1. The User may receive any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at spp@npk-spp.ru.
2. Any changes to the Operator's Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
3. The current version of the Policy is freely available on the Internet at https://npk-spp.ru/.