Privacy policy

This is an unofficial translation provided for convenience. The Russian version of this policy is the legally binding one; in case of any discrepancy, the Russian text prevails.

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken by the ARSOVENTUS team (hereinafter — the Operator) to ensure its security.

1.1. The Operator regards respect for human and civil rights and freedoms in the processing of personal data — including the right to privacy and to personal and family confidentiality — as the paramount aim and condition of its activity.

1.2. This policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information the Operator may obtain about those who complete this form.

2. Key terms used in the Policy

2.1. Automated processing of personal data — the processing of personal data by means of computing equipment.

2.2. Blocking of personal data — the temporary suspension of processing (except where processing is necessary to correct personal data).

2.3. Personal data information system — the totality of personal data held in databases together with the information technologies and technical means that process it.

2.4. Anonymisation of personal data — actions after which it is impossible, without additional information, to attribute personal data to a specific user or other data subject.

2.5. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation, including collection, recording, systematisation, accumulation, storage, correction, retrieval, use, transfer, anonymisation, blocking, deletion and destruction of personal data.

2.6. Operator — a legal or natural person who, alone or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of processing, the composition of the data and the actions performed on it.

2.7. Personal data — any information relating directly or indirectly to a specified or identifiable participant who completed the form.

2.9. Provision of personal data — actions aimed at disclosing personal data to a specific person or a defined group of persons.

2.10. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons, including publication on information and telecommunication networks.

2.12. Destruction of personal data — actions after which personal data is irretrievably destroyed and its content cannot be restored.

3. Principal rights and obligations of the Operator

3.1. The Operator has the right to obtain accurate information and/or documents containing personal data from the data subject, and to determine independently the composition and list of measures necessary to fulfil the obligations laid down by the Personal Data Law.

3.2. The Operator is obliged to provide the data subject, upon request, with information concerning the processing of their data; to organise the processing of personal data in the manner established by the legislation of the Russian Federation; to respond to enquiries from data subjects; to take legal, organisational and technical measures to protect personal data from unlawful access, destruction, alteration, blocking, copying and dissemination; and to cease processing and destroy personal data in the cases provided for by law.

4. Principal rights and obligations of data subjects

4.1. Data subjects have the right to obtain information concerning the processing of their data; to demand the correction, blocking or destruction of data that is incomplete, out of date or unlawfully obtained; to withdraw consent to the processing of personal data; and to appeal against the Operator’s actions to the authorised body or in court.

4.2. Data subjects are obliged to provide the Operator with accurate information about themselves and to notify the Operator of any corrections to it.

4.3. Persons who have provided the Operator with inaccurate information about themselves or about another data subject without that person’s consent bear liability in accordance with the legislation of the Russian Federation.

5. What data the Operator processes

5.1. Surname, first name and patronymic.

5.2. Email address.

5.3. Telephone numbers.

5.4. The site also collects and processes anonymised data about visitors (including cookies) using web analytics services.

5.6. The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious beliefs or sex life.

6. Principles of personal data processing

6.1. Personal data is processed on a lawful and fair basis and is limited to the achievement of specific, predetermined and lawful purposes.

6.5. The content and volume of the personal data processed correspond to the stated purposes of processing; excessive data is not permitted.

6.7. Personal data is stored for no longer than the purposes of its processing require, unless another period is established by law or by contract.

7. Purposes of personal data processing

7.1. Informing the participant who completed the form by sending emails; concluding, performing and terminating civil-law contracts; providing the participant with access to ARSOVENTUS services, information and materials.

8. Legal grounds for processing personal data

8.1. Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and the Protection of Information”; other regulatory acts in the field of personal data protection; and the consent of data subjects to the processing of their personal data.

8.2. The Operator processes the personal data of a participant only where that participant has entered and/or submitted it themselves through the dedicated forms or by email. By completing the forms and sending data to the Operator, the participant expresses their agreement with this Policy.

9. Conditions for processing personal data

9.1. Personal data is processed with the consent of the data subject.

9.4. Processing is necessary for the performance of a contract to which the data subject is a party, or for its conclusion at the subject’s initiative.

9.5. Processing is necessary for the exercise of the rights and legitimate interests of the Operator or of third parties, provided that the rights and freedoms of the data subject are not infringed.

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

The security of personal data is ensured through the implementation of legal, organisational and technical measures.

10.1. The Operator ensures the safekeeping of personal data and prevents access to it by unauthorised persons.

10.2. A participant’s personal data will never be transferred to third parties, except in cases connected with compliance with the law or where the data subject has consented to the transfer of data for the performance of a contract.

10.3. If inaccuracies are discovered, the participant may update their data by sending the Operator a notice to arsoventus@arsoventus.com marked “Update of personal data”.

10.4. The participant may withdraw consent to the processing of personal data at any time by sending a notice to arsoventus@arsoventus.com marked “Withdrawal of consent to the processing of personal data”.

10.6. The Operator maintains the confidentiality of personal data when processing it.

11. List of actions performed by the Operator with personal data

11.1. Collection, recording, systematisation, accumulation, storage, correction, retrieval, use, transfer, anonymisation, blocking, deletion and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of information over information and telecommunication networks.

12. Cross-border transfer of personal data

12.1. Before beginning any cross-border transfer of personal data, the Operator must satisfy itself that the receiving state provides reliable protection of the rights of data subjects.

13. Confidentiality of personal data

The Operator and other persons who have obtained access to personal data are obliged not to disclose it to third parties and not to disseminate it without the consent of the data subject, unless otherwise provided by federal law.

14. Final provisions

14.1. A participant may obtain clarification on matters concerning the processing of personal data by contacting the Operator at arsoventus@arsoventus.com.

14.2. Any changes to the personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.