Privacy Policy
1. General provisions
This Personal Data Processing Policy has been developed in accordance with the requirements of the Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the processes for processing personal data and the measures taken by LLC "Grain Terminal Labinskoy" to ensure the confidentiality and security of personal information (hereinafter referred to as the Operator).
1.1 As its most important goal and a condition for carrying out its activities, the Operator sets compliance with human and civil rights and freedoms when processing personal data, including the protection of the right to privacy and personal and family secrets.
1.2 This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may receive about visitors to its website https://gtlaba.com.
2. Definitions In this policy, the following terms are used:
2.1 Automated processing of personal information - the processing of personal data using computer technology.
2.2 Blocking of personal information - a temporary suspension of the processing of personal details (unless processing is necessary to clarify the data).
2.3. Website - a collection of
graphic and informational materials, as well as computer programs and databases
that ensure its availability on the Internet at the address: https://gtlaba.com
2.4. Personal Data Information System - a system of personal data stored in databases using information technologies and technical means that ensure their processing
2.5. Depersonalizing Personal Data - measures that make it impossible to identify whether the personal data pertains to a specific individual or other personal entity without additional information
2-6. Processing Personal Data - any act (operation) or series of acts (operations) performed using or without automated tools involving personal information, such as collecting, recording, organizing, accumulating, storing, updating, extracting, using, transmitting (disseminating, disclosing, transferring), de-identifying, blocking, deleting, or destroying personal information
2.7 The Operator is a state body, municipality, legal entity or individual who independently or jointly with other parties organizes and / or carries out the processing of personal information, as well as determines the purposes of processing personal data, the scope of processed personal data and the actions taken with personal information.
2.8 Personal information is any information directly or indirectly related to an identifiable user of https://gtlaba.com.
2.9 The personal data authorized for sharing by the data subject is personal data that may be accessed by an unlimited number of people with the consent of the data subject to the processing of their personal data for the purposes specified in the Personal Data Protection Act (hereinafter "personal data for sharing").
2.10 User - any visitor to the website https://gtlaba.com
2.11 Provision of personal information - actions aimed at making personal information available to a specific person or group of people
2.12 Disclosure of personal data - any action aimed at sharing personal data with unspecified groups of people (transferring personal data) or making it accessible to unlimited numbers of people, including publication in mass media, postings on information and communication networks, or any other way of providing access
2.13 Transborder transfer of personal data: transferring personal data to foreign countries, authorities, individuals, or legal entities.
2.14 Destruction of personal data – any action that results in the permanent removal of personal data from a personal data system, making it impossible to access the content of that data again, and/or permanently destroying the physical storage media on which the personal data was recorded.
3. Basic rights and obligations of the Operator
3.1 The operator has the right to: - Receive reliable information and / or documents containing personal data from a personal data subject; - If a personal data subjects withdraws their consent to the processing of their personal data or send a request to stop processing their personal data, the operator may continue processing personal data without consent if there are valid reasons specified in the law on personal data; - Independent determination of the composition and list of measures necessary and sufficient for fulfilling obligations under the law on Personal Data, other federal laws, and other regulatory acts in accordance therewith, unless the law or other Federal laws provide otherwise.
3.2 The operator is obligated to:
- provide the personal data subject with information related to the processing of their personal data upon request;
- organize the processing of personal data in accordance with the procedures established by current legislation of the Russian Federation;
- respond to requests and inquiries from personal data subjects and their authorized representatives according to requirements of the Law on Protection of Personal Data;
- inform the authorized body responsible for protecting personal data rights of necessary information upon receipt of request within 10 working days.
- Publish or otherwise make unrestricted access available to this Personal Data Processing Policy.
- Take legal, organizational, and technical measures to protect personal data from unauthorized access,
destruction, modification, blocking, copying, distribution, or other illegal actions.
- Stop transmitting, distributing, providing or accessing personal data and stop processing personal data in accordance with procedures specified in the law on personal data. Perform other duties specified in the relevant legislation.
4.1 Personal data subjects are entitled to:
- receive information related to the processing of their personal data, except in cases provided for by federal laws. The operator shall provide information to the personal data subject in an accessible form that does not contain personal data about other personal data subjects, unless there are legal reasons for disclosing such information. A list of information and a procedure for obtaining it shall be established by the Law on Personal Data.
- Request the operator to correct, block, or delete their personal data if they believe it is incomplete, outdated, inaccurate, obtained illegally, or unnecessary for the stated purpose of processing. They shall also have the right to take measures provided by law to protect their rights.
- Impose a condition of prior consent for processing personal data when promoting goods, works, or services in the market.
- Withdraw consent to processing personal data and send a request to terminate processing of their data.
- Appeal to relevant authorities for protection of personal data rights, or go to court against illegal actions or omissions by operators when processing data. And exercise other rights provided by Russian law.
4.2 Personal data subjects are required to:
- Provide the Operator with accurate and reliable information about themselves.
- Notify the Operator of any changes to their personal information.
4.3 Any person who provides false information to the Operator, or shares personal information about another person without their consent, will be held liable in accordance with Russian law.
5. Principles of Personal Data Processing
5.1 Personal data will be processed in a lawful and fair manner.
5.2 Processing of personal information will be limited to specific, predetermined, and legitimate purposes. Processing data that is not compatible with the stated purpose of data collection is prohibited.
5.3 Combining databases containing personal information processed for incompatible purposes is prohibited
5.4 Personal data that is only necessary for the purpose of processing will be used.
5.5 The content and scope of the personal data processed will be consistent with the stated objectives of the processing, and redundant personal data will not be processed for these stated objectives.
5.6 When processing personal data, the accuracy, completeness and relevance of the data are ensured in relation to the purposes of processing. The operator will take necessary measures to ensure that incomplete or inaccurate data is deleted or corrected. Personal data is stored in such a way that it is identifiable, for no longer than necessary for processing the data unless a longer storage period is specified by federal law or agreement between the individual and the person processing the data. Processed data is deleted or anonymised when processing goals are met or no longer required, unless otherwise required by federal laws.
6. Purposes of Personal Data Processing
The purpose of processing responses to user requests via phone calls or email is to collect, record, systemize, accumulate, store, destroy and de-identify personal data, including:
- Personal data such as names and phone numbers
- Electronic addresses
- Other personal information that may be relevant to the user's request
The legal basis for this processing is the Federal Law "On Information, Information Technologies and Information Protection" of July 27, 2006 No. 149-FZ
7. Terms and Conditions for Personal Data Processing
7.1. Personal data processing is carried out only with the express consent of the individual whose data is being processed.
7.2. Processing of personal data is necessary to achieve the objectives set out in an international treaty of the Russian Federation, or in accordance with a law. It is also necessary to carry out functions, powers and responsibilities assigned by the legislation of the Russian Federation to the operator. Processing of personal data may be necessary for other purposes such as administering justice or executing a judicial decision. It may also be required to implement an act of another body or official that is subject to enforcement under Russian legislation on enforcement proceedings.
7.3 Personal data processing may also be required to perform a contract in which the data subject is a party, beneficiary, or guarantor, or to conclude a contract at the initiative of the data subject, or under which they will be a beneficiary or guarantor.
7.4 Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant objectives provided that the individual's rights and freedoms are not violated. Processing of publicly available personal data which is information accessible to an unlimited number of people is carried out including personal data made available to the public by the individual or at their request. Personal data required to be published or disclosed under federal laws is also processed.
8. Procedures for the collection, storage,
transfer, and other types of processing of personal data.
The Operator ensures the security of personal data by implementing legal, organizational, and technical measures that fully comply with current legislation on personal data protection.
8.1. The Operator takes all necessary measures to ensure the security of the personal data and prevent unauthorized access.
8.2. Personal data of users is never transferred to third parties unless it is required by law or the user has given consent to the transfer of data to a third party for the fulfillment of obligations under a contract.
8.3. If inaccuracies are identified in personal data, the user may update them independently by sending an email to ztlab@inbox.ru with "Updating Personal Data" as the subject.
8.4 The term for processing personal data is determined by the achievement of the purpose for which the personal data was collected unless a different term is provided in the contract or applicable legislation. The user can withdraw their consent to processing personal data at any time by sending notification to the operator through email at ztlab@inbox.ru, with the subject "Revocation of Consent to Processing Personal Data."
8.5 All information collected by third-party services, such as payment systems and communication services, is stored and processed by those parties (operators) in accordance with their terms of use and privacy policies. The specific details of personal data are specified in those documents. The operator is not responsible for any actions taken by third parties, including the service providers mentioned here.
8.6 The prohibitions imposed by the person whose personal data are being processed on transfer (except for access), as well as on processing or conditions of processing (except obtaining access), personal data for distribution, do not apply in cases where processing of personal data is carried out for public interest defined by legislation of the Russian Federation.
8.7 Operator ensures confidentiality of personal data during processing. Operator shall store personal data so that it is possible to identify subject of data, for period no longer necessary for purpose of processing, unless longer period is specified by law or agreement between operator and subject of data.
8.8 Processing of personal data can be terminated upon achieving its intended purpose, expiry of the individual's consent, withdrawal of consent, or request to terminate processing as well as illegal processing.
9. The Operator collects, records, organises, stores, updates, extracts, uses, transmits and distributes personal data. It also de-identifies, blocks, deletes, and destroys data.
10. Personal data is processed automatically, with and without receiving and transmitting information through information and communication networks.
10.1. Before carrying out cross-border transfers of personal data, the operator must notify the relevant authorities for the protection of personal data rights about its intentions to do so. This notification must be separate from the notification regarding the processing of personal data.
10.2. Before submitting the aforementioned notification, the operator needs to obtain relevant information from authorities in a foreign country or from foreign individuals or legal entities to which the cross-border transfer of personal information is intended.
11. The operator and anyone else who has access to personal data must keep it confidential and not share it with third parties without permission from the data subject, unless permitted by law.
12. The user may seek clarification on any issues related to the processing of their personal data by contacting the operator via email at ztlab@inbox.ru
12.1 This document will be updated to reflect any changes to the operator’s personal data policy.
12.2 The current policy remains in effect until it is superseded by a new version.
This Personal Data Processing Policy has been developed in accordance with the requirements of the Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the processes for processing personal data and the measures taken by LLC "Grain Terminal Labinskoy" to ensure the confidentiality and security of personal information (hereinafter referred to as the Operator).
1.1 As its most important goal and a condition for carrying out its activities, the Operator sets compliance with human and civil rights and freedoms when processing personal data, including the protection of the right to privacy and personal and family secrets.
1.2 This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may receive about visitors to its website https://gtlaba.com.
2. Definitions In this policy, the following terms are used:
2.1 Automated processing of personal information - the processing of personal data using computer technology.
2.2 Blocking of personal information - a temporary suspension of the processing of personal details (unless processing is necessary to clarify the data).
2.3. Website - a collection of
graphic and informational materials, as well as computer programs and databases
that ensure its availability on the Internet at the address: https://gtlaba.com
2.4. Personal Data Information System - a system of personal data stored in databases using information technologies and technical means that ensure their processing
2.5. Depersonalizing Personal Data - measures that make it impossible to identify whether the personal data pertains to a specific individual or other personal entity without additional information
2-6. Processing Personal Data - any act (operation) or series of acts (operations) performed using or without automated tools involving personal information, such as collecting, recording, organizing, accumulating, storing, updating, extracting, using, transmitting (disseminating, disclosing, transferring), de-identifying, blocking, deleting, or destroying personal information
2.7 The Operator is a state body, municipality, legal entity or individual who independently or jointly with other parties organizes and / or carries out the processing of personal information, as well as determines the purposes of processing personal data, the scope of processed personal data and the actions taken with personal information.
2.8 Personal information is any information directly or indirectly related to an identifiable user of https://gtlaba.com.
2.9 The personal data authorized for sharing by the data subject is personal data that may be accessed by an unlimited number of people with the consent of the data subject to the processing of their personal data for the purposes specified in the Personal Data Protection Act (hereinafter "personal data for sharing").
2.10 User - any visitor to the website https://gtlaba.com
2.11 Provision of personal information - actions aimed at making personal information available to a specific person or group of people
2.12 Disclosure of personal data - any action aimed at sharing personal data with unspecified groups of people (transferring personal data) or making it accessible to unlimited numbers of people, including publication in mass media, postings on information and communication networks, or any other way of providing access
2.13 Transborder transfer of personal data: transferring personal data to foreign countries, authorities, individuals, or legal entities.
2.14 Destruction of personal data – any action that results in the permanent removal of personal data from a personal data system, making it impossible to access the content of that data again, and/or permanently destroying the physical storage media on which the personal data was recorded.
3. Basic rights and obligations of the Operator
3.1 The operator has the right to: - Receive reliable information and / or documents containing personal data from a personal data subject; - If a personal data subjects withdraws their consent to the processing of their personal data or send a request to stop processing their personal data, the operator may continue processing personal data without consent if there are valid reasons specified in the law on personal data; - Independent determination of the composition and list of measures necessary and sufficient for fulfilling obligations under the law on Personal Data, other federal laws, and other regulatory acts in accordance therewith, unless the law or other Federal laws provide otherwise.
3.2 The operator is obligated to:
- provide the personal data subject with information related to the processing of their personal data upon request;
- organize the processing of personal data in accordance with the procedures established by current legislation of the Russian Federation;
- respond to requests and inquiries from personal data subjects and their authorized representatives according to requirements of the Law on Protection of Personal Data;
- inform the authorized body responsible for protecting personal data rights of necessary information upon receipt of request within 10 working days.
- Publish or otherwise make unrestricted access available to this Personal Data Processing Policy.
- Take legal, organizational, and technical measures to protect personal data from unauthorized access,
destruction, modification, blocking, copying, distribution, or other illegal actions.
- Stop transmitting, distributing, providing or accessing personal data and stop processing personal data in accordance with procedures specified in the law on personal data. Perform other duties specified in the relevant legislation.
4.1 Personal data subjects are entitled to:
- receive information related to the processing of their personal data, except in cases provided for by federal laws. The operator shall provide information to the personal data subject in an accessible form that does not contain personal data about other personal data subjects, unless there are legal reasons for disclosing such information. A list of information and a procedure for obtaining it shall be established by the Law on Personal Data.
- Request the operator to correct, block, or delete their personal data if they believe it is incomplete, outdated, inaccurate, obtained illegally, or unnecessary for the stated purpose of processing. They shall also have the right to take measures provided by law to protect their rights.
- Impose a condition of prior consent for processing personal data when promoting goods, works, or services in the market.
- Withdraw consent to processing personal data and send a request to terminate processing of their data.
- Appeal to relevant authorities for protection of personal data rights, or go to court against illegal actions or omissions by operators when processing data. And exercise other rights provided by Russian law.
4.2 Personal data subjects are required to:
- Provide the Operator with accurate and reliable information about themselves.
- Notify the Operator of any changes to their personal information.
4.3 Any person who provides false information to the Operator, or shares personal information about another person without their consent, will be held liable in accordance with Russian law.
5. Principles of Personal Data Processing
5.1 Personal data will be processed in a lawful and fair manner.
5.2 Processing of personal information will be limited to specific, predetermined, and legitimate purposes. Processing data that is not compatible with the stated purpose of data collection is prohibited.
5.3 Combining databases containing personal information processed for incompatible purposes is prohibited
5.4 Personal data that is only necessary for the purpose of processing will be used.
5.5 The content and scope of the personal data processed will be consistent with the stated objectives of the processing, and redundant personal data will not be processed for these stated objectives.
5.6 When processing personal data, the accuracy, completeness and relevance of the data are ensured in relation to the purposes of processing. The operator will take necessary measures to ensure that incomplete or inaccurate data is deleted or corrected. Personal data is stored in such a way that it is identifiable, for no longer than necessary for processing the data unless a longer storage period is specified by federal law or agreement between the individual and the person processing the data. Processed data is deleted or anonymised when processing goals are met or no longer required, unless otherwise required by federal laws.
6. Purposes of Personal Data Processing
The purpose of processing responses to user requests via phone calls or email is to collect, record, systemize, accumulate, store, destroy and de-identify personal data, including:
- Personal data such as names and phone numbers
- Electronic addresses
- Other personal information that may be relevant to the user's request
The legal basis for this processing is the Federal Law "On Information, Information Technologies and Information Protection" of July 27, 2006 No. 149-FZ
7. Terms and Conditions for Personal Data Processing
7.1. Personal data processing is carried out only with the express consent of the individual whose data is being processed.
7.2. Processing of personal data is necessary to achieve the objectives set out in an international treaty of the Russian Federation, or in accordance with a law. It is also necessary to carry out functions, powers and responsibilities assigned by the legislation of the Russian Federation to the operator. Processing of personal data may be necessary for other purposes such as administering justice or executing a judicial decision. It may also be required to implement an act of another body or official that is subject to enforcement under Russian legislation on enforcement proceedings.
7.3 Personal data processing may also be required to perform a contract in which the data subject is a party, beneficiary, or guarantor, or to conclude a contract at the initiative of the data subject, or under which they will be a beneficiary or guarantor.
7.4 Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant objectives provided that the individual's rights and freedoms are not violated. Processing of publicly available personal data which is information accessible to an unlimited number of people is carried out including personal data made available to the public by the individual or at their request. Personal data required to be published or disclosed under federal laws is also processed.
8. Procedures for the collection, storage,
transfer, and other types of processing of personal data.
The Operator ensures the security of personal data by implementing legal, organizational, and technical measures that fully comply with current legislation on personal data protection.
8.1. The Operator takes all necessary measures to ensure the security of the personal data and prevent unauthorized access.
8.2. Personal data of users is never transferred to third parties unless it is required by law or the user has given consent to the transfer of data to a third party for the fulfillment of obligations under a contract.
8.3. If inaccuracies are identified in personal data, the user may update them independently by sending an email to ztlab@inbox.ru with "Updating Personal Data" as the subject.
8.4 The term for processing personal data is determined by the achievement of the purpose for which the personal data was collected unless a different term is provided in the contract or applicable legislation. The user can withdraw their consent to processing personal data at any time by sending notification to the operator through email at ztlab@inbox.ru, with the subject "Revocation of Consent to Processing Personal Data."
8.5 All information collected by third-party services, such as payment systems and communication services, is stored and processed by those parties (operators) in accordance with their terms of use and privacy policies. The specific details of personal data are specified in those documents. The operator is not responsible for any actions taken by third parties, including the service providers mentioned here.
8.6 The prohibitions imposed by the person whose personal data are being processed on transfer (except for access), as well as on processing or conditions of processing (except obtaining access), personal data for distribution, do not apply in cases where processing of personal data is carried out for public interest defined by legislation of the Russian Federation.
8.7 Operator ensures confidentiality of personal data during processing. Operator shall store personal data so that it is possible to identify subject of data, for period no longer necessary for purpose of processing, unless longer period is specified by law or agreement between operator and subject of data.
8.8 Processing of personal data can be terminated upon achieving its intended purpose, expiry of the individual's consent, withdrawal of consent, or request to terminate processing as well as illegal processing.
9. The Operator collects, records, organises, stores, updates, extracts, uses, transmits and distributes personal data. It also de-identifies, blocks, deletes, and destroys data.
10. Personal data is processed automatically, with and without receiving and transmitting information through information and communication networks.
10.1. Before carrying out cross-border transfers of personal data, the operator must notify the relevant authorities for the protection of personal data rights about its intentions to do so. This notification must be separate from the notification regarding the processing of personal data.
10.2. Before submitting the aforementioned notification, the operator needs to obtain relevant information from authorities in a foreign country or from foreign individuals or legal entities to which the cross-border transfer of personal information is intended.
11. The operator and anyone else who has access to personal data must keep it confidential and not share it with third parties without permission from the data subject, unless permitted by law.
12. The user may seek clarification on any issues related to the processing of their personal data by contacting the operator via email at ztlab@inbox.ru
12.1 This document will be updated to reflect any changes to the operator’s personal data policy.
12.2 The current policy remains in effect until it is superseded by a new version.
