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Personal data processing policy

1. General provisions

This Personal data processing policy has been prepared in accordance with requirements of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” and specifies the personal data processing procedure and measures to ensure security of personal data by SRDI O&G Peton LLC (hereinafter referred to as the Operator).

1.1. The critical objective and condition for operation specified by Operator is observation of human and civil rights and freedoms during processing of personal data, including protection of the rights for privacy, personal and family secret.

1.2. This Operator’s Personal data processing policy (hereinafter referred to as the Policy) is applied to all information that may be obtained by Operator about the visitors of website http://www.peton.ru/.

2. Main terms and definitions used in the Policy

2.1. Automated processing of personal data means processing of personal data using computer equipment;

2.2. Blocking of personal data means temporary suspension of personal data processing (except for the cases when such processing is required for personal data clarification);

2.3. Website means a complex of graphical and informational materials together with the computer software and databases that ensure their availability in Internet network at the network address http://www.peton.ru/;

2.4. Personal data information system means a complex of personal data contained in the databases and information technologies and technical means that ensure their processing;

2.5. Anonymization of personal data means actions that make it impossible to identify affiliation of personal data to the particular User or other owner of personal data without the use of additional information;

2.6. Personal data processing means any action (operation) or a complex of actions (operations) performed with personal data using automation means or without usage of such means including collection, recording, systemization, accumulation, storage, clarification (updating, changing), extraction, usage, transfer (distribution, submission, provision of access), anonymization, blocking, deleting, destruction of personal data;

2.7. Operator means the government body, municipal body, legal entity or individual person, that independently or in cooperation with other bodies organizes and/or performs processing of personal data and that identifies objectives of personal data processing, composition of personal data to be processed, actions (operations) to be performed with personal data;

2.8. Personal data means any information directly or indirectly related to a particular or identifiable User of website http://www.peton.ru/;

2.9. User means any visitor of website http://www.peton.ru/;

2.10. Provision of personal data means actions aimed at disclosure of personal data to a particular person or range of persons;

2.11. Distribution of personal data means any actions aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or at reviewing personal data by an unlimited range of persons, including public disclosure of personal data in mass media, allocation of data in information and telecommunications network or provision of access to personal data by any other means;

2.12. Cross-border transfer of personal data means the transfer of personal data to the territory of the foreign sate to the foreign state authority, foreign individual person or foreign legal entity;

2.13. Destruction of personal data means any actions that result in irrevocable destruction of personal data with no possibility of further restoration of personal data contents in the personal data information system and/or result in destruction of personal data physical storage media.

3. The Operator may process the following User’s personal data

3.1. Full Name;

3.2. E-mail address;

3.3. Phone numbers;

3.4. The website also collects and processes anonymized data about the visitors (including “cookie” files) with the use of Internet statistics services (Yandex Metrics, Google Analytics, etc.).

3.5. The above mentioned data hereafter in the Policy are collectively referred to as a general notion Personal data.

4. Personal data processing objectives

4.1. The objective of the User’s personal data processing is to provide access to services, information and/or materials contained at the website to the User.

4.2. The Operator is also entitled to send notifications to the User about new products and services, special proposals and different events. The User can refuse from receiving information messages at any time by sending a message to the Operator’s e-mail address peton@peton.ru with the remark “Refusal from notifications on new products, services and special proposals”.

4.3. The Users’ anonymized data collected with the use of Internet statistics services serve for collection of information about the Users’ actions on the website, improvement of the website quality and its contents.

5. Personal data processing legal basis

5.1. The Operator processes User’s personal data only if they are filled-in and/or independently submitted by User through special forms located at the website http://www.peton.ru/. By completing the relevant forms and/or by sending his personal data to the Operator, the User expresses consent with this Policy.

5.2. The Operator processes anonymized data about the User in case it is allowed in the User’s browser settings (saving of “cookie” files and usage of JavaScript technology are enabled).

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

Security of personal data that are processed by Operator is ensured by means of execution of legal, organizational and technical measures required for full compliance with the requirements of the applicable legislation in the field of personal data protection.

6.1. The Operator ensures security of personal data and takes all possible measures to exclude accessing personal data by unauthorized persons.

6.2. The User’s personal data will not be ever transferred under any conditions to the third parties except for the cases connected with execution of applicable legislation.

6.3. In case any inaccuracies are found in personal data, the User can update them independently by sending notification to the Operator’s e-mail address peton@peton.ru with the remark “Personal data update”.

6.4. The period of personal data processing is not limited. The User may recall his consent for processing personal data at any time by sending notification to the Operator by means of e-mail to the Operator’s e-mail address peton@peton.ru with the remark “Recalling of consent for personal data processing”.

7. Cross-border transfer of personal data

7.1. Prior to start cross-border transfer of personal data, the Operator shall ascertain that the foreign state where the personal data are supposed to be transferred ensures secure protection of rights of the personal data owner.

7.2. Cross-border transfer of personal data to the territory of states that do not conform to the above mentioned requirements may be executed only with the written consent of the personal data owner for cross-border transfer of his personal data and/or execution of the contract in which one of the parties is the personal data owner.

8. Final provisions

8.1. The User may receive any explanations for the concerned issues related to processing of his personal data by means of addressing the Operator using the e-mail address peton@peton.ru.

8.2. This document will reflect any changes in the Policy of personal data processing by the Operator. The Policy is valid indefinitely until it is substituted by a new revision.

8.3. The recent revision of the Policy is located in the Internet network with free access at the address http://www.peton.ru/privacy/.