Privacy Policy
OOO SMOLENSK FREEZER COMPANY (hereinafter referred to as “the Website Administration”, “Processor”, “we”, “our”, “us”), with the legal address at ul. Dokuchaeva 11a, office A, Smolensk, Smolensk region, 214000 Russia, attaches great importance to the protection of your privacy and the security of your personal data.
The policy is intended to inform you about our actions to collect, process and protect your personal data in order to achieve our stated purposes of data processing on the website.
We comply with the requirements of the Russian legislation in the field of personal data. When processing personal data, we adhere to the principles set out in Art. 5 of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter, “152-FZ”).
We kindly ask you to carefully examine the Privacy Policy (hereinafter, “the Policy”) to understand the purposes of processing your personal data and how you may exercise rights with respect to your personal data processed by us.
If you have questions related to the Policy, including suggestions to improve its understanding and navigation, or you have questions about our processing your personal data and their protection, you can send us a request using one of the methods indicated in the “Contacts” section.
The policy is intended to inform you about our actions to collect, process and protect your personal data in order to achieve our stated purposes of data processing on the website.
We comply with the requirements of the Russian legislation in the field of personal data. When processing personal data, we adhere to the principles set out in Art. 5 of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter, “152-FZ”).
We kindly ask you to carefully examine the Privacy Policy (hereinafter, “the Policy”) to understand the purposes of processing your personal data and how you may exercise rights with respect to your personal data processed by us.
If you have questions related to the Policy, including suggestions to improve its understanding and navigation, or you have questions about our processing your personal data and their protection, you can send us a request using one of the methods indicated in the “Contacts” section.
Terms
“Personal Data” (“Data”) means any information referring directly or indirectly to an identified or identifiable individual (“Data Subject”).
“Data Processor” (“Processor”) means a state, municipal body, legal or private entity, which independently or jointly with other parties organizes and (or) performs the Data Processing and determines the purposes of the Data Processing, the scope of the Data to be processed, actions (operations) performed with the Data.
“Data Processing” means any action (operation) or a set of actions (operations) performed with personal data, with or without the use of automation facilities. The Data Processing includes, but is not limited to, the following:
“Data Dissemination” means actions related to making the Data available to an indefinite group of persons.
“Data Provision” means actions related to making the Data available to a definite person or a definite group of persons.
“Data Blocking” means temporary cessation of the Data Processing (except for the cases when the processing is needed for the Data clarification).
“Data Destruction” means actions performed on the Data contained in the respective Information System that prevent the Data from being recovered and (or) actions leading to physical destruction of the tangible media containing the Data.
“Data Depersonalization” means actions performed in such a manner that the Data can no longer be attributed to a specific Data Subject without the use of additional information.
“Data Information System” means a set of personal data contained in databases and of information technologies and hardware used for Data Processing.
“Cross-border Data Transmission” means transmission of Data to a foreign state agency, a foreign legal entity or an individual located in a foreign state.
“Personal Data” (“Data”) means any information referring directly or indirectly to an identified or identifiable individual (“Data Subject”).
“Data Processor” (“Processor”) means a state, municipal body, legal or private entity, which independently or jointly with other parties organizes and (or) performs the Data Processing and determines the purposes of the Data Processing, the scope of the Data to be processed, actions (operations) performed with the Data.
“Data Processing” means any action (operation) or a set of actions (operations) performed with personal data, with or without the use of automation facilities. The Data Processing includes, but is not limited to, the following:
- collection;
- recording;
- systematization;
- accumulation;
- storage;
- clarification (update, change);
- extraction;
- use;
- transmission (dissemination, provision, access);
- depersonalization;
- blocking;
- deletion;
- destruction.
“Data Dissemination” means actions related to making the Data available to an indefinite group of persons.
“Data Provision” means actions related to making the Data available to a definite person or a definite group of persons.
“Data Blocking” means temporary cessation of the Data Processing (except for the cases when the processing is needed for the Data clarification).
“Data Destruction” means actions performed on the Data contained in the respective Information System that prevent the Data from being recovered and (or) actions leading to physical destruction of the tangible media containing the Data.
“Data Depersonalization” means actions performed in such a manner that the Data can no longer be attributed to a specific Data Subject without the use of additional information.
“Data Information System” means a set of personal data contained in databases and of information technologies and hardware used for Data Processing.
“Cross-border Data Transmission” means transmission of Data to a foreign state agency, a foreign legal entity or an individual located in a foreign state.
1. Applicability
The Policy is intended to inform you about our actions to collect, process and protect your personal data in order to achieve our stated purposes of data processing on the website.
The Processing of personal data to which the Policy applies is listed in the section “Why we process your personal data”.
Please note that our website may contain links to resources of other vendors that we do not control and which are not subject to the Policy.
The Policy is intended to inform you about our actions to collect, process and protect your personal data in order to achieve our stated purposes of data processing on the website.
The Processing of personal data to which the Policy applies is listed in the section “Why we process your personal data”.
Please note that our website may contain links to resources of other vendors that we do not control and which are not subject to the Policy.
2. Collection of non-adults' personal data
Our website is not intended to process non-adults' personal data. If you have reason to believe that a non-adult has provided us with his/her personal data through the website, please let us know by writing to privacy@ctsrus.com.
Our website is not intended to process non-adults' personal data. If you have reason to believe that a non-adult has provided us with his/her personal data through the website, please let us know by writing to privacy@ctsrus.com.
3. Why we process your personal data
The website processes your personal data to achieve the purposes described below. We kindly ask you to consider the text of each fragment numbered “3.1.1. Name" to be consent to the Data Processing information on the withdrawal of which is described in Clauses 4.9 and 4.10.
3.1.1 Feedback form
Purpose of Data Processing Incoming message processing
Your personal data that are processed for the specified purpose first and last name, your email, your phone number
What actions can we perform with your personal data collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transmission (provision, access), blocking, deletion, destruction
Legal grounds for your Data Processing: consent to the Data Processing
How long do we process your personal data: until the end of the correspondence as part of the response to an incoming message
The website processes your personal data to achieve the purposes described below. We kindly ask you to consider the text of each fragment numbered “3.1.1. Name" to be consent to the Data Processing information on the withdrawal of which is described in Clauses 4.9 and 4.10.
3.1.1 Feedback form
Purpose of Data Processing Incoming message processing
Your personal data that are processed for the specified purpose first and last name, your email, your phone number
What actions can we perform with your personal data collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transmission (provision, access), blocking, deletion, destruction
Legal grounds for your Data Processing: consent to the Data Processing
How long do we process your personal data: until the end of the correspondence as part of the response to an incoming message
4. What are your rights?
4.1. General information about your rights
In accordance with 152-FZ, you have the following rights regarding the Data Processing:
In the course of exercising your rights, we may request additional information that will allow us to reliably identify you. Such information will be required in rare cases.
We try to request the minimum required amount of additional information for your identification.
Your rights cannot be exercised if you do not provide additional information to identify you in response to our request.
4.3. Conditions for providing information on your rights
Information related to the exercise of your rights is provided free of charge. If your request is manifestly unfounded or excessive because of its repetitive nature in particular, we may refuse to respond you or charge you for providing the requested information.
4.4. Right to access your personal data
You have the right to receive reliable information about your personal data processing from us, and, if possible, access to personal data and to the following information:
We make efforts to identify inaccurate, incomplete or outdated data.
If the data are inaccurate, incomplete or outdated, you have the right to request us to correct the data concerning you without undue delay.
After correcting your personal data, we will notify you about it.
4.6. The right to appeal against our actions or our inaction
You have the right to object to your Data Processing in response to our actions or our inaction.
In this regard you can contact the local Roskomnadzor.
4.7. The right to appeal against decisions taken on the basis of exclusively Automated Data Processing
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects on you or similarly significantly affects you.
You have the right to contact us to appeal against our actions when we make decisions on the basis of exclusively Automated Data Processing, if any.
4.8. The right to withdraw consent
If your data are processed on the basis of consent, you have the right to withdraw it.
4.9. How can you exercise your rights?
We offer several ways of exercising rights:
We may limit the scope of our obligations and your rights (to access data, clarify it, block it or delete it) in the following cases:
If your right cannot be exercised at your request, then we write you a reasoned refusal.
4.1. General information about your rights
In accordance with 152-FZ, you have the following rights regarding the Data Processing:
- the right to access personal data;
- the right to clarify personal data;
- the right to appeal against our actions or our inaction;
- the right to appeal against decisions taken on the basis of exclusively Automated Data Processing;
- the right to withdraw consent.
In the course of exercising your rights, we may request additional information that will allow us to reliably identify you. Such information will be required in rare cases.
We try to request the minimum required amount of additional information for your identification.
Your rights cannot be exercised if you do not provide additional information to identify you in response to our request.
4.3. Conditions for providing information on your rights
Information related to the exercise of your rights is provided free of charge. If your request is manifestly unfounded or excessive because of its repetitive nature in particular, we may refuse to respond you or charge you for providing the requested information.
4.4. Right to access your personal data
You have the right to receive reliable information about your personal data processing from us, and, if possible, access to personal data and to the following information:
- confirmation of the Data Processing by the Processor;
- legal grounds for the Data Processing and purposes of it;
- purposes and ways of the Data Processing applied by the Processor;
- name and location of the Processor, information about the people (excluding Processor's employees) who have access to the Data or to whom the Data may be disclosed on the basis of an agreement with the Processor or on the basis of the Federal law;
- your personal data being processed, the source of their receipt;
- timelines for the Data Processing, including the timelines for their storage;
- procedure for exercising your rights in accordance with 152-FZ;
- information about the performed or supposed Cross-border Data Transmission;
- the name or surname, patronymic and address of the person performing the Data Processing on behalf of the Processor, if the Processing is entrusted or is supposed to be entrusted to such a person.
We make efforts to identify inaccurate, incomplete or outdated data.
If the data are inaccurate, incomplete or outdated, you have the right to request us to correct the data concerning you without undue delay.
After correcting your personal data, we will notify you about it.
4.6. The right to appeal against our actions or our inaction
You have the right to object to your Data Processing in response to our actions or our inaction.
In this regard you can contact the local Roskomnadzor.
4.7. The right to appeal against decisions taken on the basis of exclusively Automated Data Processing
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects on you or similarly significantly affects you.
You have the right to contact us to appeal against our actions when we make decisions on the basis of exclusively Automated Data Processing, if any.
4.8. The right to withdraw consent
If your data are processed on the basis of consent, you have the right to withdraw it.
4.9. How can you exercise your rights?
We offer several ways of exercising rights:
- write a request to our address: ul. Dokuchaeva 11a, office A, Smolensk, Smolensk region, 214000 Russia; indicating in it information about the document proving your identity or the identity of your representative (document type, series and number, by whom and when issued), your full name or full name of the representative, information about the relationship with you, which will confirm the fact of the Data Processing by us, your signature or the signature of your representative. Such a request may be sent to our e-mail in the form of an electronic document signed in accordance with the Russian Federation legislation on electronic signature;
- you can also contact us directly at privacy@ctsrus.com.
We may limit the scope of our obligations and your rights (to access data, clarify it, block it or delete it) in the following cases:
- the Data Processing, including the Data obtained as a result of operational-search, counterintelligence and intelligence activities, is carried out for the purposes of national defense, state security and law enforcement;
- the Data Processing is carried out by the authorities that have detained the Data Subject on suspicion of committing a crime, or have charged the Data Subject with a crime, or have applied preventive measures to the Data Subject before the charge is brought, except for cases provided for by the criminal procedure legislation of the Russian Federation, if it is allowed to familiarize the suspect or the accused with such Data;
- the Data Processing is carried out in accordance with the anti-money laundering legislation concerning proceeds from crime and the financing of terrorism;
- the Data Subject's access to his/her Data violates the rights and legitimate interests of third parties;
- the Data Processing is carried out in cases provided for by the Russian Federation legislation on transport security in order to ensure the stable and safe functioning of the transport system, to protect the interests of the individual, society and the state in the field of the transport system against acts of unlawful interference;
- when we have legitimate grounds for continuing to process your data.
If your right cannot be exercised at your request, then we write you a reasoned refusal.
5. Cookies and automatic logging
Cookies are one of the technologies which we use to automatically collect information and improve content. A cookie is a small text file that is stored on a device (computer, tablet, smartphone, etc.) and contains information about your browsing activity.
As well as most other information resources of organizations, our web servers and security systems store some temporary technical data in their log files from time to time.
Cookies collected on our website:
Name
Vendor
Lifetime
Cookies are one of the technologies which we use to automatically collect information and improve content. A cookie is a small text file that is stored on a device (computer, tablet, smartphone, etc.) and contains information about your browsing activity.
As well as most other information resources of organizations, our web servers and security systems store some temporary technical data in their log files from time to time.
Cookies collected on our website:
Name
Vendor
Lifetime
6. Data Security
The data we collect and store are considered confidential information. They are protected from loss, alteration or unauthorized access in accordance with the Russian Federation legislation on personal data. To do this, we use technical means and organizational measures. We are constantly improving our data protection systems.
The data we collect and store are considered confidential information. They are protected from loss, alteration or unauthorized access in accordance with the Russian Federation legislation on personal data. To do this, we use technical means and organizational measures. We are constantly improving our data protection systems.
7. Policy change
We reserve the right to make changes to our Policy at any time. We ask that you regularly review all updates to our Policy. We will send notices of changes to the Policy in the event that such changes are relevant, by all means available to us.
We reserve the right to make changes to our Policy at any time. We ask that you regularly review all updates to our Policy. We will send notices of changes to the Policy in the event that such changes are relevant, by all means available to us.
8. Contacts
Please note that the contacts indicated in this Clause are used only for interaction on the processing and protection of your personal data. Requests sent by you to the contacts specified in the Policy that are not related to data protection will not be considered. For questions related to the processing and protection of personal data, you can directly contact our person responsible for Data Processing: Alexey Yuryevich Kotelnikov, privacy@ctsrus.com
Last update: January 19, 2023
Please note that the contacts indicated in this Clause are used only for interaction on the processing and protection of your personal data. Requests sent by you to the contacts specified in the Policy that are not related to data protection will not be considered. For questions related to the processing and protection of personal data, you can directly contact our person responsible for Data Processing: Alexey Yuryevich Kotelnikov, privacy@ctsrus.com
Last update: January 19, 2023
CONTACT
ADDRESS
ul. Dokuchaeva 11a, office A
Smolensk, 214 000 Russia
BANK DETAILS
OOO Smolensk Freezer Company
INN 6732200383
OGRN 1206700014070
r/s 40702810300000166601
k/s 30101810200000000700
AO Raiffeisenbank
BIC 044525700