ARMACON / Privacy Policy

Privacy Policy

1. General provisions

This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006, "On Personal Data" (the Personal Data Law). It defines the procedures for processing personal data and the measures taken by ARMACON LLC (the Operator) to protect personal data.

The Operator regards respect for human and civil rights and freedoms in processing personal data, including the right to privacy and personal and family confidentiality, as a primary objective and condition of its activities.
This Policy applies to all information the Operator may obtain about visitors to https://armacon.su/.
The Policy does not apply to relationships arising from the processing of personal data of the Operator's employees, employees' relatives, former employees or applicants for vacant positions.
The Policy defines the Operator's actions in processing Users' personal data, the procedures and conditions for such processing, procedures to prevent violations of Russian law, and measures to remedy the consequences of violations relating to personal data processing.
The Policy applies, without limitation, to browsing the Website, using the services offered on the Website, and other use of the Website.

2. Definitions used in this Policy

Automated processing of personal data: processing using computer equipment.
Blocking personal data: temporarily suspending processing, except where processing is necessary to clarify the data.
Website: the collection of graphical and informational materials, computer programs and databases that make them accessible on the Internet at https://armacon.su/.
Personal data information system: personal data contained in databases, together with the information technologies and technical equipment used to process them.
Depersonalization of personal data: actions that make it impossible, without additional information, to attribute personal data to a particular User or other data subject.
Processing of personal data: any action or combination of actions performed with or without automation, including collection, recording, systematization, accumulation, storage, clarification (updating or alteration), extraction, use, transfer (dissemination, provision or access), depersonalization, blocking, deletion and destruction.
Operator: ARMACON LLC, registered address: 123098, Moscow, Shchukino Municipal District, 12 Rogova Street, premises 2P, Russia. Taxpayer Identification Number (INN): 7706809861. Primary State Registration Number (OGRN): 1147746572302.
In this Policy, an operator may also mean a public authority, municipal authority, legal entity or individual that, independently or jointly with others, organizes or carries out personal data processing and determines its purposes, the data to be processed and the actions to be performed.
Personal data: any information relating directly or indirectly to an identified or identifiable User of https://armacon.su/.
Personal data authorized for dissemination: personal data made accessible to an unlimited number of persons by the data subject through consent given in accordance with the Personal Data Law.
User: any visitor to https://armacon.su/.
Data subject (the Subject): an individual whose personal data have been provided to the Operator for processing.
Provision of personal data: actions intended to disclose personal data to a specified person or specified group of persons.
Dissemination of personal data: actions intended to disclose personal data to an unspecified group of persons or make them available to an unlimited number of persons, including publication in the media, placement on information and telecommunications networks, or access by any other means.
Cross-border transfer of personal data: transfer of personal data to a foreign public authority, foreign individual or foreign legal entity in the territory of a foreign state.
Destruction of personal data: actions that permanently destroy personal data without the possibility of restoring their contents in an information system, or destroy their physical media.
Cookies: small pieces of data sent by a web server and stored on a user's computer, which the web client or browser sends back to the server when requesting a page of the relevant website.

3. Main rights and obligations of the Operator

1. The Operator has the right to:

obtain accurate information and documents containing personal data from the Subject;
process the Subject's data for the stated purposes;
continue processing without consent after consent has been withdrawn or a request to stop processing has been submitted, where grounds specified by the Personal Data Law apply;
independently determine the measures necessary and sufficient to fulfil obligations under the Personal Data Law and related regulations, unless otherwise provided by that Law or other federal laws.

2. The Operator must:

provide the Subject, on request, with information about the processing of their personal data;
organize processing in accordance with current Russian law;
respond to requests from Subjects and their legal representatives in accordance with the Personal Data Law;
provide information requested by the authorized authority for protection of data subjects' rights within 10 days of receiving the request;
publish or otherwise provide unrestricted access to this Policy;
maintain confidentiality: the Operator and others with access to personal data must not disclose or disseminate them without the Subject's consent unless required by law;
take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions;
stop transfer, access and processing and destroy personal data in the cases and manner required by the Personal Data Law;
fulfil other obligations under the Personal Data Law.

4. Main rights and obligations of data subjects

1. Data subjects have the right to:

provide their personal data and consent to processing;
receive information about processing, except in cases provided by federal law. Information must be accessible and must not contain other subjects' personal data unless lawful grounds for disclosure exist. The information available and the procedure for obtaining it are established by the Personal Data Law;
require clarification, blocking or destruction of incomplete, outdated, inaccurate, unlawfully obtained or unnecessary data and take measures provided by law to protect their rights;
require prior consent to processing for the promotion of goods, works or services;
withdraw consent and request that processing stop;
appeal unlawful actions or omissions by the Operator to the authorized data protection authority or a court;
exercise other rights under Russian law.

2. Data subjects must provide accurate information about themselves, notify the Operator of updates or changes, obtain consent from third parties whose data they provide, and fulfil other obligations under Russian law.

3. Persons who provide inaccurate information about themselves or another Subject's data without that Subject's consent are liable under Russian law.

5. Principles of personal data processing

Processing is lawful and fair.
Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes of collection is prohibited.
Databases containing data processed for incompatible purposes must not be combined.
Only data relevant to the purposes of processing are processed.
The content and volume of the data correspond to the stated purposes and must not be excessive.
Data must be accurate, sufficient and, where necessary, up to date for the processing purposes. The Operator takes or ensures measures to remove or clarify incomplete or inaccurate data.
Data are stored in an identifiable form no longer than necessary for the processing purposes, unless a retention period is established by federal law or a contract to which the Subject is a party, beneficiary or guarantor. Data are destroyed or depersonalized when the purposes have been achieved or are no longer necessary, unless otherwise required by federal law.

6. Purposes of personal data processing

Purpose 1: providing the User with access to Website services, information and materials; providing feedback, including notices and requests concerning Website use and services, handling User requests and applications, and using Website services.

Data for purpose 1: surname, first name, patronymic, email address and telephone numbers.

Purpose 2: ensuring uninterrupted operation of the Website and its functions and compiling customer statistics on use of Website sections and services.

Data for purpose 2: requested web pages, browser information, IP address, location data, software and hardware specifications, access time, cookies and information collected by analytics programs.

Legal basis for both purposes: Federal Law No. 149-FZ of 27 July 2006, "On Information, Information Technologies and Protection of Information".

Processing operations for both purposes: collection, recording, systematization, accumulation, storage, destruction and depersonalization.

Processing and storage method: automated.

Processing and storage period: until the purpose has been achieved, consent has been withdrawn, or the period established by Russian law has expired.

Destruction: erasure or another method that prevents recovery.

7. Conditions for personal data processing

Personal data, including data collected by Yandex.Metrica, Google Analytics and other analytics or automated services, are processed with the Subject's consent.
Processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, or to perform functions, powers and obligations imposed on the Operator by Russian law.
Processing is necessary for the administration of justice or execution of a court order or an act of another authority or official enforceable under Russian enforcement law.
Processing is necessary to perform a contract to which the Subject is a party, beneficiary or guarantor, or to conclude a contract at the Subject's initiative or under which the Subject will be a beneficiary or guarantor.
Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided the Subject's rights and freedoms are not infringed.
Processing concerns personal data made accessible to an unlimited number of persons by the Subject or at the Subject's request (publicly available personal data).
Processing concerns data that must be published or disclosed under federal law.

8. Collection, storage, transfer and other processing

The security of data processed by the Operator is ensured through legal, organizational and technical measures necessary to fulfil all applicable personal data protection requirements.

The Operator safeguards personal data and takes all possible measures to prevent unauthorized access.
Users' personal data are not transferred to third parties except to comply with applicable law or where the Subject has consented to transfer for performance of a civil-law contract.
The Operator applies and ensures legal, organizational and technical measures against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions. These comply with Russian Government requirements for information systems, physical media and storage technologies outside information systems. Protection measures are established by the Operator's internal regulations, orders, instructions and other documents.
The Operator takes the measures necessary and sufficient to fulfil obligations under Russian laws and related regulations.
Unless otherwise provided by law, the Operator independently determines the necessary and sufficient measures. These include appointing a person responsible for organizing processing; issuing a policy and internal processing rules; informing or training employees directly involved in processing about Russian legislation, protection requirements and internal policies; and other security measures applied by the Operator.
Users may correct inaccurate data by emailing info@armacon.su with the subject "Updating personal data".
The processing period is determined by achievement of the purposes for which the data were collected, unless another period is established by contract or law.
Users may withdraw consent at any time by emailing info@armacon.su with the subject "Withdrawal of consent to personal data processing".
Following withdrawal, the Operator stops processing or ensures that a processor acting on its behalf stops processing. If retention is no longer required, the Operator destroys the data or ensures their destruction within 30 days of receipt of the withdrawal, unless a contract or other agreement provides otherwise, or lawful grounds permit processing without consent.
Information collected by third-party services, including payment systems, communications services and other providers, is stored and processed by those parties under their user agreements and privacy policies. The Operator is not responsible for third-party actions, including those of these providers.
Restrictions imposed by the Subject on transfer (other than access), processing or processing conditions (other than obtaining access) for data authorized for dissemination do not apply where processing serves state, social or other public interests defined by Russian law.
The Operator maintains confidentiality when processing personal data.
The Operator stores data in an identifiable form no longer than necessary for its purposes, unless a retention period is established by federal law or a contract to which the Subject is a party, beneficiary or guarantor.
Processing may end when its purposes have been achieved, consent expires or is withdrawn, the Subject requests cessation, or unlawful processing is identified.

9. Operations performed with personal data

The Operator collects, records, systematizes, accumulates, stores, clarifies (updates or alters), extracts, uses, transfers (disseminates, provides or grants access to), depersonalizes, blocks, deletes and destroys personal data.
The Operator performs automated processing with or without receiving or transmitting information over information and telecommunications networks.

10. Cross-border transfer

Before beginning cross-border transfers, the Operator must notify the authorized authority for protection of data subjects' rights of its intention to do so. This notification is separate from the notification of the intention to process personal data.
Before submitting that notification, the Operator must obtain the relevant information from the foreign public authorities, individuals or legal entities to which data are to be transferred.

11. Confidentiality of personal data

The Operator and others with access to personal data must not disclose them to third parties or disseminate them without the Subject's consent, unless otherwise provided by federal law.

12. Security

13. Final provisions

Users may request clarification about the processing of their personal data by emailing info@armacon.su.
Changes to the Operator's Personal Data Processing Policy will be reflected in this document. The Policy remains effective indefinitely until replaced by a new version.