1. General Provisions
The personal data operator, within the meaning of Russian Federal Law No. 152-FZ, is Razvitie-Lipetsk Limited Liability Company (the “Operator”):
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Primary State Registration Number (OGRN): 1164827065622.
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Taxpayer Identification Number (INN): 4802004021.
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Address: Premises 3, 32 Oktyabrskaya Street, Lipetsk, Lipetsk Region, Russian Federation.
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Email: lipetsk.razvitie@mail.ru.
This Policy sets out the terms governing the processing of personal data relating to users of https://razvitielipetsk.ru/, including its English-language version, and individuals who submit enquiries through the website.
The Operator processes personal data in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable provisions of the laws of the Russian Federation.
This Policy is publicly available on the website. Visiting the website or reading this Policy does not, in itself, constitute consent to the processing of personal data.
2. Purposes of Processing and Categories of Personal Data
2.1. Handling Enquiries and Service Requests
Personal data relating to individuals submitting enquiries or requests, and to customer representatives, is processed to respond to enquiries, provide information about services, calculate costs and prepare commercial proposals.
The data processed comprises the user’s name or full name, including patronymic where provided, telephone number, email address, job title, information about the organisation represented, the content of enquiries and correspondence, and necessary information contained in attached documents, to the extent provided by the user.
The legal basis for processing is the user’s consent or another applicable legal basis under Article 6 of Federal Law No. 152-FZ.
2.2. Entering into and Performing Contracts
Personal data relating to customers and their representatives is processed to prepare and perform contracts, communicate regarding the work to be carried out and prepare the necessary documentation.
The data processed comprises full name, including patronymic where provided, contact details, job title, information establishing the representative’s authority, details required for contractual purposes and personal data contained in business correspondence.
The legal basis for processing is entering into or performing a contract with the data subject, compliance with legal obligations, consent or another applicable lawful basis.
2.3. Website Analytics
The website uses Yandex Metrica to assess traffic and improve the website, including its Webvisor session replay feature where enabled.
The data processed may include IP addresses, cookie identifiers, device and browser information, referral sources, pages visited and actions taken on the website.
Information constituting personal data may be processed only where a legal basis under Article 6 of Federal Law No. 152-FZ exists. A cookie notice does not, in itself, constitute such a legal basis.
2.4. Website Operation and Security
Necessary technical information, including IP addresses, access times and information about technical events, may be processed to maintain website functionality and prevent misuse.
The legal basis for processing is the pursuit of the Operator’s legitimate interests, provided that users’ rights and freedoms are respected, or another applicable legal basis provided by law.
3. Processing Procedures and Retention
Personal data is processed by automated and non-automated means. Processing includes, as necessary for the relevant purpose, collection, recording, systematisation, accumulation, storage, updating and correction, retrieval, use, granting access on a lawful basis, blocking, deletion and destruction.
The Operator does not collect excessive personal data or use it for purposes incompatible with the original purpose of processing.
Personal data contained in enquiries is processed until the relevant interaction is completed, but for no longer than one year after the most recent interaction. If the purpose is achieved earlier, processing ceases unless another lawful basis permits it to continue.
Contractual documents are retained throughout the performance of the contract and for any subsequent retention periods required by law.
Technical and analytics data is retained for no longer than necessary for the relevant purpose. Retention periods are determined by internal documents and the settings of the systems used, in compliance with legal requirements.
Once the purpose has been achieved or the legal basis for processing no longer applies, personal data is destroyed within the time limits prescribed by law. Destruction is carried out in a manner that prevents the content from being reconstructed and is documented in accordance with the applicable requirements.
4. Cookies and Analytics Tools
The website uses cookies and Yandex Metrica to support certain website functions, assess traffic and analyse users’ interactions with the website.
Cookies are small pieces of data stored by the user’s browser. They may contain technical information and identifiers used by the website and analytics tools.
A cookie notice is displayed on the website. Dismissing the notice acknowledges that it has been read and does not constitute consent to the processing of personal data.
Users may restrict the use of cookies or delete them through their browser settings. These settings may affect certain website functions and do not prevent processing that does not rely on cookies.
Deleting cookies does not automatically delete data previously collected and stored in information systems. Questions about data processing may be sent to lipetsk.razvitie@mail.ru.
5. Access to Data and Services Used
The Operator’s employees are granted access to personal data to the extent required to perform their duties.
The Operator may use Bitrix24 and other customer relationship management (CRM) systems to organise its work and communicate with customers. Only data necessary for the purposes specified in this Policy is processed in those systems.
The Operator may engage technical service providers and other persons processing personal data on its behalf where a lawful basis exists. Processing on the Operator’s instructions is governed by a contract containing the terms required by law.
Personal data is disclosed to public authorities in the circumstances prescribed by law.
Consent to the processing of a service request does not authorise making personal data publicly available to an indefinite number of persons or using contact details to send advertising messages.
When collecting personal data relating to citizens of the Russian Federation, the Operator complies with the statutory requirements concerning the localisation of databases.
If a cross-border transfer is necessary, the Operator fulfils the requirements of Article 12 of Federal Law No. 152-FZ before commencing the transfer. This Policy does not, in itself, authorise such a transfer.
6. Personal Data Protection
The Operator is required to ensure the confidentiality and security of personal data, restrict access to it and implement the necessary legal, organisational and technical measures, taking into account the systems used and the relevant threats.
Procedures for processing, storing, accessing and destroying personal data are established in the Operator’s internal documents.
Where violations are identified, the Operator takes the measures required by law, including notifying the competent authorities where required.
7. Users’ Rights
Users have the right to:
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obtain information about the processing of their personal data;
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request that their personal data be corrected, blocked or destroyed where lawful grounds exist;
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withdraw consent and request that processing cease in the circumstances provided by law;
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challenge the Operator’s acts or omissions before Roskomnadzor, the Russian Federal Service for Supervision of Communications, Information Technology and Mass Media, or a court.
Requests should be sent to lipetsk.razvitie@mail.ru or to the Operator’s address. A request must contain sufficient information to establish the requester’s identity and identify the personal data concerned.
The Operator considers requests and complies with applicable requirements within the time limits prescribed by law. Withdrawal of consent does not preclude further processing where another lawful basis exists.
8. Changes to this Policy
The current version of this Policy is published on the website.
Changes to this Policy do not automatically extend the scope of consent previously obtained. Where consent is required for new processing arrangements, the Operator obtains it before commencing the relevant processing.
