Personal data processing policy

Personal data processing policy
1. General provisions. This Personal data processing policy has been prepared in accordance with requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" and specifies the personal data processing procedure and measures to ensure security of personal data which are taken by INNOBETON 21 (the Processor.)
1.1. The Processor's absolute priority and condition precedent to its activities is respecting human and civil rights and freedoms during processing of personal data, in particular, respect to privacy policies, personal and family confidentiality.
1.2. This Personal Data Processing Policy of the Processor (hereinafter: the Policy) applies to all information that may be obtained by the Processor about visitors of its website:
2. Key Terms Used in the Policy
2.1. Automated personal data processing means processing of personal data by means of computers
2.2. Personal data blocking means temporary cease of personal data processing (unless such processing is required for refining personal data)
2.3. Website means a population of graphical and data materials along with the computer software and databases that ensure their availability online at
2.4. Personal data information system means a population of personal data in databases and information technologies and hardware that ensure the processing thereof
2.5. Personal data impersonation means actions that make it impossible to attribute personal data to a specific User or any other subject of personal data without supplementary information
2.6. Personal data processing means any action (operation) or a set of actions (operations) with personal data whether involving or not involving any automation equipment including but not limited to acquiring, recording, systemizing, accumulating, storing, refining (updating, modifying) such data, or retrieval, use, transfer (dissemination, provision, access), impersonation, blocking, deletion, and erasing of personal data
2.7. Processor means a federal government authority, local authority, legal entity, or individual which/who manages and/or performs, whether independently or jointly with other parties, processing of personal data and determines the purposes of personal data processing, composition of personal data to be processed, and actions (operations) to be performed with personal data
2.8. Personal data means any information concerning (whether directly or indirectly) a specific or identifiable User of the website
2.9. User means any visitor of the website titled
2.10. Provision of personal data means actions intended to disclose personal data to a particular person or range of persons
2.11. Dissemination of personal data means any actions intended to disclose personal data to the public at large (transfer of personal data) or to make personal data available to the public at large, in particular, by making personal data available to the public in mass media, placing them in data and telecommunications networks, or providing access to personal data otherwise
2.12. Cross-border transfer of personal data means transfer of personal data to the territory of a foreign state to a foreign state government authority, foreign individual, or foreign legal entity
2.13. Personal data erasure means any actions that result in irrevocable destruction of personal data making it impossible to recover the content of personal data in the personal data information system in future and/or destruction of the physical media bearing personal data.
3. User's personal data that may be processed by the Processor are as follows:
3.1. Full Name
3.2. E-mail address
3.3. Phone numbers
3.4. In addition, the website is used to acquire and process impersonal data on its visitors (including their cookies) by means of online statistics services (Yandex Metrics, Google Analytics, etc.)
3.5. The data mentioned above shall hereafter be collectively referred as Personal Data.
4. Purposes of Personal Data Processing
4.1. The purpose of processing the User's personal data is to provide information to the User by means of e-mail messages to provide the User with access to the services, information, and/or materials available on the website.
4.2. The Processor may also send notifications to the User about new products and services, special offers and different events. The User may choose to unsubscribe from information messages anytime by sending a message to the Processor's e-mail address <> marked "Unsubscribe from notifications about new products, services, and special offers".
4.3. The Users' impersonal data collected by means of online statistics services are used to acquire data on the Users' actions on the website and to improve the quality of the website and its content.
5. Legal Framework for Personal Data Processing
5.1. The Processor shall process the User's personal data only if they have been filled in and/or submitted by the very User using the special forms available at: By completing the relevant forms and/or sending his/her personal data to the Processor, the User will express his/her acceptance hereof.
5.2. The Processor shall process impersonal data on the User provided that it is permitted in the User's browser settings (the options 'save cookies' and 'use JavaScript' are enabled).
6. Procedure for Personal Data Acquisition, Storage, Transfer, and Other Types of Personal Data ProcessingThe personal data processed by the Processor shall be secured by implementing legal, data leak preventative, and technical measures required for full compliance with the requirements of applicable laws in terms of personal data protection.
6.1. The Processor shall ensure the integrity of personal data and take all reasonable effort to rule out the risk of access to personal data by unauthorised persons.
6.2. Under no circumstances User's personal data will be ever transferred to any third parties, unless it is required otherwise in compliance with applicable laws.
6.3. In case of detecting any inaccuracies in personal data, the User may update them on his/her own by sending a notice to the Processor's e-mail box with a subject saying "Update personal data".
6.4. There is no time limit for personal data processing. The User may withdraw his/her consent to personal data processing at any time by e-mailing his/her notice to the Processor's e-mail box with a subject saying "Withdraw consent to personal data processing".
7. Cross-Border Transfer of Personal Data
7.1. Prior to launching cross-border transfer of personal data, the Processor shall make sure that the foreign state where the personal data are supposed to be transferred ensures adequate protection of personal data owners.
7.2. No cross-border transfer of personal data to the states that do not meet the requirements referred to above may take place without a written consent of the personal data owner to the cross-border transfer of his/her personal data and/or performance of the contract where the personal data owner is a party to such a contract.
8. Final Provisions
8.1. The User may receive any explanations for the matters of interest thereto concerning the processing of his/her personal data by contacting the Processor by e-mail
8.2. This document will reflect any modifications of the Personal Data Processing Policy made by the Processor. The Policy shall remain in force indefinitely until it is superseded by a new revision.
8.3. The current revision of the Policy is available online in the public domain at

Privacy Policy

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