PERSONAL DATA PROCESSING POLICY
PERSONAL DATA PROCESSING POLICY
1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-ФЗ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by “LMK-Precision Casting Plant” Ltd. (hereinafter referred to as the Operator).
1.1. The Operator sets the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets as its most important goal and condition for the implementation of its activities.
1.2. This personal data processing policy if the Operator (hereinafter referred to as the Policy) shall apply to all information that the Operator can obtain about visitors to the website https://lmk.group/.

2. Basic Concepts Used in the Policy


2.1. Automated Processing of Personal Data shall mean computer-assisted processing of personal data.
2.2. Personal Data Blocking shall mean temporary suspension of personal data processing (except for where processing is required to clarify personal data).
2.3. Website shall mean a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://lmk.group/.
2.4. Personal Data Information System shall mean an aggregation of personal data contained in the personal data databases and the IT technologies and technical means ensuring personal data processing.
2.5. Personal Data Anonymization shall mean actions resulting in the impossibility to attribute personal data to a specific User or another personal data subject without additional information.
2.6. Processing of Personal Data shall mean any action or cumulative action performed with personal data with the use of automation facilities or without them, including collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (distribution, provision, access) impersonation, blocking, deletion, and destruction of personal data.
2.7 Operator shall mean a state body, municipal body, legal entity or individual, independently or jointly with other persons arranging and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal Data shall mean any information relating, directly or indirectly, to an identified or identifiable User of the website https://lmk.group/.
2.9. Personal Data Permitted by the Subject of Personal Data for Dissemination shall mean personal data to which the general public has been granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for dissemination).
2.10. User shall mean any visitor to the website https://lmk.group/.
2.11. Provision of Personal Data shall mean actions aimed at disclosing personal data to a certain person or a certain number of persons.
2.12. Dissemination of Personal Data shall mean any actions aimed at disclosing personal data to the general public (transfer of personal data) or at acquaintance with the personal data by the general public, including the disclosure of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-Border Transfer of Personal Data shall mean transfer of personal data to a foreign jurisdiction to an authority therein, to a foreign individual or to a foreign legal entity.
2.14. Destruction of Personal Data shall mean any actions as a result of which personal data are destroyed irrevocably with the impossibility of further recovery of the content of personal data in the personal data information system and (or) the physical media of personal data.

3. Fundamental Rights and Obligations of the Operator

3.1. The Operator may:
- receive reliable information and/or documents containing personal data from the subject of personal data;
- in case of withdrawal by the subject of personal data of the consent to the processing of personal data, the Operator may continue the processing of personal data without the consent of the subject of personal data subject if there are grounds specified in the Law on Personal Data;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance therewith, unless otherwise provided for by the Law on Personal Data or other federal laws.
3.2. The Operator shall:
- provide the subject of the personal data at its request with information regarding the processing of its personal data;
- arrange the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
- respond to requests and applications of subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
- inform the authorized body for the protection of the rights of personal data subjects at the request of this body about the necessary information within 30 days from the date of receipt of such request;
- publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access thereto, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
- stop the transfer of (distribution, provision, access to) personal data, stop processing and destroy personal data in the manner and in cases provided for by the Law on Personal Data;
- perform other duties provided for by the Law on Personal Data.

4. Fundamental Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects may:
- receive information regarding the processing of their personal data, except for cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form, and it shall not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- require the operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
- withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator in the processing of their personal data;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
- provide the Operator with reliable data about themselves;
- inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have transferred false information about themselves to the Operator, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Surname, name, patronymic.
5.2. Email.
5.3. Phone numbers.
5.4. Also, the website collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrics and Google Analytics, and others).
5.5. The above data are hereinafter referred to as Personal Data.
5.6. The processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life, shall not be carried out by the Operator.
5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data shall be allowed if the prohibitions and conditions provided for in Art. 10.1 of the Law on Personal Data are complied with.
5.8. The User’s consent to the processing of personal data permitted for dissemination shall be executed separately from other consents to the processing of its personal data. In this case, the conditions provided for, in particular, by Art. 10.1 of the Law on Personal Data shall be complied with. The requirements for the content of such consent shall be established by the authorized body for the protection of the rights of subjects of personal data.
5.8.1 Consent to the processing of personal data permitted for dissemination shall be provided by the User directly to the Operator.
5.8.2 The Operator shall, no later than three business days from the date of receipt of the said consent of the User, publish information on the processing conditions, the existence of prohibitions and conditions for the processing by the general public of personal data permitted for dissemination.
5.8.3 The transfer of (distribution, provision, access to) personal data permitted by the personal data subject for dissemination shall be terminated at any time at the request of the personal data subject. Such request shall include the surname, name, patronymic (if any), contact information (phone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in such request may be processed only by the Operator to which it is sent.
5.8.4 Consent to the processing of personal data permitted for dissemination shall be terminated from the moment the Operator receives the request specified in Clause 5.8.3 hereof in relation to the processing of personal data.

6. Personal Data Processing Principles

6.1. The processing of personal data shall be carried out on a legal and fair basis.
6.2. The processing of personal data shall be limited to the achievement of specific, predetermined and legitimate purposes. No processing of personal data incompatible with the purposes of collecting personal data shall be allowed.
6.3. Combining databases containing personal data that may be processed for purposes incompatible between them shall be forbidden.
6.4. Only personal data that meet the purposes of their processing shall be processed.
6.5. The content and volume of the processed personal data shall correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing shall not be allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency and, if required, relevance in relation to the purposes of processing personal data shall be ensured. The Operator shall take the necessary measures and/or ensure they are taken to remove or clarify incomplete or inaccurate data.
6.7. Personal data shall be kept in a form allowing identification of a personal data subject for no longer than allowed in accordance with personal data processing purposes, unless the storage period for personal data is established by a federal law or an agreement to which a personal data subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided for by the federal law.

7. Purposes of Personal Data Processing

7.1. Purpose of processing the User’s personal data shall be:
- informing the User by sending e-mails;
- conclusion, fulfillment and termination of civil contracts;
- providing the User with access to the services, information and/or materials contained on the website https://lmk.group/.
7.2. Also, the Operator may send notices to the User of new products and services, special offers and various events. The User may always refuse to receive informational messages by sending a letter to the Operator at the e-mail address info@lmk.group with the note “Refusal of notices of new products and services and special offers”.
7.3. Anonymized data of Users collected using Internet statistics services shall be used to collect information about the actions of Users on the website, improve the quality of the website and its content.
8. Legal Grounds for Processing Personal Data
8.1. The legal grounds for the processing of personal data by the Operator shall be:
- statutory (constituent) documents of the Operator;
- contracts concluded between the operator and the subject of personal data;
- federal laws, other regulations in the field of personal data protection;
- the consent of the Users to the processing of their personal data, to the processing of personal data permitted for dissemination.
8.2. The Operator shall process the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://lmk.group/ or sent to the Operator by e-mail. By filling in the relevant forms and/or sending its personal data to the Operator, the User agrees with this Policy.
8.3. The Operator shall process anonymized data about the User if it is allowed in the settings of the User’s browser (saving of cookies and the use of JavaScript technology).
8.4. The personal data subject shall independently decide on the provision of its personal data and give its consent freely, willingly and in its interest.

9. Terms and Conditions of Personal Data Processing

9.1. The processing of personal data shall be carried out with the consent of the personal data subject to the processing of its personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation of the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is either a party or a beneficiary or a guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. The processing of personal data, access of the general public to which is provided by the subject of personal data or at its request (hereinafter referred to as publicly available personal data) is carried out.
9.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

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

The safety of personal data processed by the Operator shall be ensured by the implementation of legal, organizational and technical measures necessary to comply with the requirements of the current legislation in the field of personal data protection in full.
10.1. The Operator shall ensure the safety of personal data and take all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or in the event that the personal data subject has given consent to the transfer of data to a third party to fulfill obligations under a civil contract.
10.3. In case of identification of inaccuracies in personal data, the User may update them independently by sending a notice to the Operator at the Operator’s e-mail address info@lmk.group with the note “Updating personal data”.
10.4. The period for processing personal data shall be determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or the current legislation.
The User may at any time withdraw its consent to the processing of personal data by sending a notice to the Operator by e-mail to the e-mail address of the Operator info@lmk.group with the note “Withdrawal of consent to the processing of personal data”.
10.5 All information that is collected by third-party services, including payment systems, communication facilities and other service providers, shall be stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User shall independently familiarize themselves with the above documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
10.6. Prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for dissemination shall not apply in cases of personal data processing in the state and other public interests determined by the laws of the Russian Federation.
10.7. When processing personal data, the Operator shall ensure the confidentiality of personal data.
10.8. Personal data shall be kept by the Operator in a form allowing identification of a personal data subject for no longer than allowed in accordance with personal data processing purposes, unless the storage period for personal data is established by a federal law or an agreement to which a personal data subject is a party, beneficiary or guarantor.
10.9. The condition for the termination of the processing of personal data may be the achievement of the purposes for processing of personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the identification of illegal processing of personal data.

11. List of Actions Performed by the Operator with the Obtained Personal Data

11.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (distribute, provide, get access to), depersonalize, block, delete and destroy personal data.
11.2. The Operator shall carry out automated processing of personal data with the receipt and/or transmission of the information received via information and telecommunication networks or without it.

12. Cross-Border Transfer of Personal Data

12.1. Before the start of the cross-border transfer of personal data, the Operator shall ensure that the foreign state to whose territory it is intended to transfer personal data ensures reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data on the territory of foreign countries that do not meet the above requirements may be carried out only in case of the consent in writing of the personal data subject to the cross-border transfer of its personal data and/or execution of the agreement to which the subject of personal data is a party.

13. Confidentiality of Personal Data

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

14. Final Provisions

14.1. The User may receive any clarifications on issues of interest relating to the processing of its personal data by contacting the Operator via e-mail info@lmk.group
14.2. This document will reflect any changes in the personal data processing policy by the Operator. The Policy shall be valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://lmk.group/privacy-policy.