RU

Privacy Policy

1. General Provisions

This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Granula LLC (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and personal and family confidentiality, to be its primary objective and a prerequisite for its activities.

1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://grancem.ru.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

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

2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, making them accessible on the Internet at https://grancem.ru.

2.4. Personal data information system means a collection of personal data contained in databases and the information technologies and technical equipment used to process such data.

2.5. Depersonalization of personal data means actions that make it impossible to determine, without additional information, whether personal data belongs to a particular User or another personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data, with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity, or individual who, independently or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.

2.8. Personal data means any information directly or indirectly relating to an identified or identifiable User of the website https://grancem.ru.

2.9. Personal data authorized by the personal data subject for distribution means personal data to which the personal data subject has granted access to an unlimited number of persons by consenting to the processing of personal data authorized for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data authorized for distribution).

2.10. User means any visitor to the website https://grancem.ru.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. 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 mass media, posting on information and telecommunications networks, or granting access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore their content in a personal data information system, and/or the destruction of physical media containing personal data.

3. Main 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 personal data subject;
  • continue processing personal data without the consent of the personal data subject, if grounds specified in the Personal Data Law exist, where the subject withdraws consent to processing or submits a request to cease processing personal data;
  • independently determine the composition and list of measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

  • provide the personal data subject, upon request, with information concerning the processing of their personal data;
  • organize the processing of personal data in accordance with the applicable legislation of the Russian Federation;
  • respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the Personal Data Law;
  • provide the authority responsible for protecting the rights of personal data subjects with the necessary information within 10 days of receiving a request from that authority;
  • publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
  • take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions involving personal data;
  • cease the transfer (distribution, provision, access) and processing of personal data and destroy personal data in the manner and circumstances stipulated by the Personal Data Law;
  • fulfill other obligations stipulated by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

  • receive information concerning the processing of their personal data, except in cases stipulated by federal laws. The Operator must provide this information in an accessible form, and it must not contain personal data relating to other personal data subjects unless there are lawful grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • require the Operator to clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and take measures prescribed by law to protect their rights;
  • require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
  • withdraw consent to the processing of personal data and submit a request to cease such processing;
  • appeal against unlawful actions or inaction of the Operator in processing personal data to the authority responsible for protecting the rights of personal data subjects or to a court;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with accurate information about themselves;
  • inform the Operator of any clarification (update or change) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that subject’s consent shall be liable under the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed on a lawful and fair basis.

5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing personal data in a manner incompatible with the purposes for which it was collected is not permitted.

5.3. Databases containing personal data processed for mutually incompatible purposes shall not be combined.

5.4. Only personal data relevant to the purposes of its processing shall be processed.

5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Personal data processed shall not be excessive in relation to those purposes.

5.6. When processing personal data, its accuracy, sufficiency, and, where necessary, relevance to the purposes of processing shall be ensured. The Operator shall take and/or ensure the adoption of necessary measures to delete or correct incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than necessary for the purposes of processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or the need to achieve those purposes has ceased, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

6.1. Purpose of processing:

  • informing the User by sending emails.

6.2. Personal data:

  • surname, first name, and patronymic;
  • email address;
  • telephone numbers.

6.3. Legal grounds:

  • the Operator’s charter (constituent) documents.

6.4. Types of personal data processing:

  • Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
  • Sending informational emails to an email address.

7. Conditions for Personal Data Processing

7.1. Personal data shall be processed with the consent of the personal data subject.

7.2. Processing of personal data is necessary to achieve purposes stipulated 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.

7.3. Processing of personal data is necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official enforceable under the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, or for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data 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.

7.6. Personal data to which access has been granted to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data) may be processed.

7.7. Personal data subject to publication or mandatory disclosure under federal law may be processed.

8. Procedure for Collecting, Storing, Transferring, and Otherwise Processing Personal Data

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 applicable legislation on personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except where required by applicable legislation or where the personal data subject has consented to the Operator transferring the data to a third party to fulfill obligations under a civil law agreement.

8.3. If inaccuracies in personal data are identified, the User may update the data independently by sending a notification to the Operator at granula@granula-ural.ru with the subject line “Personal Data Update”.

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is stipulated by an agreement or applicable legislation.
The User may withdraw consent to the processing of personal data at any time by sending an email notification to the Operator at granula@granula-ural.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.

8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access), of personal data authorized for distribution shall not apply where personal data is processed in state, social, or other public interests defined by the legislation of the Russian Federation.

8.7. The Operator shall ensure the confidentiality of personal data during its processing.

8.8. The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than necessary for the purposes of processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, submission of a request to cease processing, or identification of unlawful processing of personal data.

9. Actions Performed by the Operator with Personal Data Obtained

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing cross-border transfers of personal data, the Operator shall notify the authority responsible for protecting the rights of personal data subjects of its intention to carry out such transfers (this notification shall be submitted separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator shall obtain the relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator via email at granula@granula-ural.ru.

12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at https://grancem.ru/en/policy-en.

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