Legal

Personal Data Processing Policy

This document explains what personal data Ingruppa LLC receives from visitors of ingru.ru, for what purposes and on what legal grounds it is processed, and how you can update your data or withdraw your consent to its processing.

Operator: Ingruppa LLC

Based on Federal Law No. 152-FZ

Valid indefinitely until replaced

Русский English

Please note

This is a courtesy translation of the Russian original. In the event of any discrepancy between this English text and the Russian version published at ingru.ru/privacy-policy/, the Russian version shall prevail.

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law of the Russian Federation 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 Ingruppa LLC (hereinafter — the Operator) to ensure the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data — including the protection of the rights to privacy and to personal and family confidentiality — to be its most important objective and a condition of carrying out its activities.

1.2. This policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors of the website https://ingru.ru/.

Operator details:

Legal name	Ingruppa LLC (ООО «Ингруппа»)
TIN (ИНН)	5835101706
KPP	583601001
Registered address	ul. Kulakova 2-26, Penza, Penza Region, 440008, Russia
Actual and postal address	ul. Chkalova 52, Penza, Penza Region, 440052, Russia
Settlement account	40702810229170000052
Bank	Nizhegorodsky branch of Alfa-Bank JSC
Correspondent account	30101810200000000824
BIC	042202824
Phone	+7 (499) 380-80-30; +7 (8412) 22-31-61
E-mail	welcome@ingru.ru
General Director	Mikhail S. Vasyanin

2. Key terms used in the Policy

2.1. Automated processing of personal data — the processing of personal data by means of computer technology.

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

2.3. Website — a set of graphic and information materials, as well as computer programs and databases, that ensures their availability on the internet at the network address https://ingru.ru/.

2.4. Personal data information system — a set of personal data contained in databases together with the information technologies and technical means enabling their processing.

2.5. Anonymisation of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belong to a particular User or other data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools in relation to personal data, including collection, recording, systematisation, accumulation, storage, updating (renewal, alteration), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of processing, the composition of the personal data to be processed, and the actions (operations) performed with such personal data.

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

2.9. Personal data permitted by the data subject for distribution — personal data to which access by an unlimited number of persons has been granted by the data subject through consent to the processing of personal data permitted for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor of the website https://ingru.ru/.

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

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data known to an unlimited number of persons, including publication in the mass media, placement in information and telecommunication networks, or granting access to personal data by any other means.

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

2.14. Destruction of personal data — any actions as a result of which personal data are irrevocably destroyed with no possibility of further restoration of the content of the personal data in the personal data information system, and/or as a result of which the material carriers of the personal data are destroyed.

3. Principal rights and obligations of the Operator

3.1. The Operator has the right to:

receive from the data subject accurate information and/or documents containing personal data;

continue processing personal data without the consent of the data subject — where the data subject has withdrawn consent to the processing of personal data or has sent a request to cease processing — if the grounds specified in the Personal Data Law are present;

independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations set out in the Personal Data Law and the regulations adopted thereunder, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

provide the data subject, at their request, with information concerning the processing of their personal data;

organise the processing of personal data in the manner established by the current legislation of the Russian Federation;

respond to appeals and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

provide the authorised body for the protection of the rights of data subjects with the information it requires, at the request of that body, within 10 days from the date of receipt of such request;

publish, or otherwise provide unrestricted access to, this Policy on the processing of personal data;

take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or distribution, as well as against other unlawful actions in relation to personal data;

cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;

fulfil other obligations provided for by the Personal Data Law.

4. Principal rights and obligations of data subjects

4.1. Data subjects have the right to:

receive information concerning the processing of their personal data, except in the cases provided for by federal laws. Such information is provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

demand that the Operator update, block or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take the measures provided by law to protect their rights;

require prior consent as a condition for the processing of personal data for the purposes of promoting goods, works and services on the market;

withdraw consent to the processing of personal data, and to send a request to cease the processing of personal data;

appeal against unlawful actions or omissions of the Operator in the processing of their personal data to the authorised body for the protection of the rights of data subjects or in court;

exercise other rights provided for by the legislation of the Russian Federation.

4.2. Data subjects are obliged to:

provide the Operator with accurate information about themselves;

inform the Operator of any clarification (renewal, alteration) of their personal data.

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

5. Principles of personal data processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of their collection is not permitted.

5.3. It is not permitted to merge databases containing personal data that are processed for purposes incompatible with one another.

5.4. Only personal data that correspond to the purposes of their processing are subject to processing.

5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Redundancy of the personal data processed in relation to the stated purposes of processing is not permitted.

5.6. When processing personal data, the accuracy, sufficiency and, where necessary, the currency of the personal data in relation to the purposes of processing are ensured. The Operator takes, and/or ensures that others take, the necessary measures to delete or update incomplete or inaccurate data.

5.7. Personal data are stored in a form that permits identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. The personal data processed are destroyed or anonymised once the purposes of processing have been achieved, or in the event that the need to achieve those purposes is lost, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing	providing the User with access to the services, information and/or materials contained on the website
Personal data	surname, first name, patronymic e-mail address phone numbers year, month, date and place of birth photographs
Legal grounds	the Operator’s constituent (founding) documents contracts concluded between the Operator and the data subject
Types of processing	collection, recording, systematisation, accumulation, storage, destruction and anonymisation of personal data sending of information letters to the e-mail address

7. Conditions for the processing of personal data

7.1. Personal data are processed with the consent of the data subject to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice and for the enforcement of a judicial act or of an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or of a contract under which the data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or of third parties, or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the data subject.

7.6. Processing is carried out in relation to personal data to which access by an unlimited number of persons has been granted by the data subject or at their request (hereinafter — publicly available personal data).

7.7. Processing is carried out in relation to personal data subject to publication or mandatory disclosure in accordance with federal law.

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

The security of the personal data processed by the Operator is ensured through the implementation of the legal, organisational and technical measures necessary to fully comply with the requirements of the applicable legislation on personal data protection.

8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfilment of applicable law, or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.

8.3. If inaccuracies in the personal data are discovered, the User may update them independently by sending the Operator a notification to the Operator’s e-mail address welcome@ingru.ru marked “Personal data update”.

8.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or by applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by e-mail to the Operator’s address welcome@ingru.ru marked “Withdrawal of consent to the processing of personal data”.

8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by those persons (Operators) in accordance with their own user agreements and privacy policies. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions established by the data subject on the transfer (other than the granting of access), as well as on the processing or the conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in state, public and other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that permits identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.

8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of processing, the expiry of the data subject’s consent, the withdrawal of consent by the data subject or a request to cease processing, as well as the detection of unlawful processing of personal data.

9. List of actions performed by the Operator with the personal data obtained

9.1. The Operator carries out the collection, recording, systematisation, accumulation, storage, updating (renewal, alteration), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.

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

10. Cross-border transfer of personal data

10.1. Before commencing any activity involving the cross-border transfer of personal data, the Operator is obliged to notify the authorised body for the protection of the rights of data subjects of its intention to carry out such transfer (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to 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 them to third parties and not to distribute personal data without the consent of the data subject, unless otherwise provided by federal law.

12. Final provisions

12.1. The User may obtain any clarification on questions of interest concerning the processing of their personal data by contacting the Operator by e-mail at welcome@ingru.ru.

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

12.3. The current version of the Policy is freely available on the internet at https://ingru.ru/privacy-policy/.

13. Language of the document

This English text is provided for the convenience of international visitors. The legally binding version of the Policy is the Russian one, published at https://ingru.ru/privacy-policy/. In the event of any discrepancy between the two versions, the Russian version prevails.