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Грязинский Завод Цепей

Courtesy translation. The Russian version (/privacy) is the legally binding one.

Appendix to order
No. 38 dated 13 May 2025

APPROVED

Director
ООО ТД «Грязинский Завод Цепей»
V.V. Pozdnyakov
13 May 2025

OPERATOR'S POLICY REGARDING THE PROCESSING OF PERSONAL DATA

at the Limited Liability Company Trading House «Грязинский Завод Цепей»

1. GENERAL PROVISIONS

1.1. This Policy regarding the processing of personal data (hereinafter — the Policy) of the Limited Liability Company Trading House «Грязинский Завод Цепей» (ООО ТД «Грязинский Завод Цепей») has been developed pursuant to the requirements of clause 2, part 1, art. 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) in order to ensure the protection of the rights and freedoms of a person and citizen in the processing of their personal data, including the protection of the rights to privacy, personal and family secrecy.

1.2. The Policy applies to all personal data processed by the Limited Liability Company Trading House «Грязинский Завод Цепей» (hereinafter — the Operator, ООО ТД «Грязинский Завод Цепей»).

1.3. The Policy applies to relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.

1.4. In fulfilment of the requirements of part 2, art. 18.1 of the Personal Data Law, this Policy is published for free access on the information and telecommunications network Internet on the Operator's website.

2. TERMS AND ABBREVIATIONS

Personal data — any information relating to a directly or indirectly identified or identifiable natural person (personal data subject).

Personal data authorised by the personal data subject for dissemination — personal data to which access by an unlimited circle of persons has been granted by the personal data subject by giving consent to the processing of personal data authorised by the personal data subject for dissemination.

Personal data operator (operator) — a state body, municipal body, legal entity or natural person that, alone or jointly with other persons, organises and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.

Processing of personal data — any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools. Personal data processing includes, among other things:

  • collection;
  • recording;
  • systematisation;
  • accumulation;
  • storage;
  • rectification (updating, modification);
  • extraction;
  • use;
  • transfer (provision, access);
  • dissemination;
  • anonymisation;
  • blocking;
  • deletion;
  • destruction.

Automated processing of personal data — processing of personal data using computer technology.

Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle of persons.

Dissemination of personal data — actions aimed at disclosing personal data to an indefinite circle of persons;

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

Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or as a result of which the tangible media of personal data are destroyed.

Anonymisation of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine the ownership of personal data by a particular personal data subject.

Personal data information system — the aggregate of personal data contained in databases and the information technologies and technical means ensuring their processing.

Site — the Operator's website on the information and telecommunications network Internet, located at https://chain-factory.ru.

Site user (User) — a person who has access to the Site via the Internet and uses it.

Cookies — a small piece of data sent by a web server and stored on the user's device; the user's browser forwards it to the web server in an HTTP request when accessing a page of the corresponding website.

IP address — a unique network address of a node in a computer network built on the IP protocol.

3. PROCEDURE AND CONDITIONS OF PROCESSING AND STORAGE OF PERSONAL DATA

3.1. Personal data processing is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.

3.2. Personal data processing is carried out with the consent of the personal data subjects to the processing of their personal data, as well as without such consent in the cases provided for by the legislation of the Russian Federation.

3.3. Consent to the processing of personal data authorised by the personal data subject for dissemination is executed separately from other consents of the personal data subject to the processing of their personal data.

3.4. Consent to the processing of personal data authorised by the personal data subject for dissemination may be given to the operator:

  • directly;
  • using the information system of the authorised body for the protection of the rights of personal data subjects.

3.5. The Operator carries out both automated and non-automated processing of personal data.

3.6. Employees of the Operator whose job duties include the processing of personal data are allowed to process personal data.

3.7. Personal data processing is carried out by:

  • obtaining personal data orally and in writing directly with the consent of the personal data subject to the processing or dissemination of their personal data;
  • entering personal data into the Operator's journals, registers and information systems;
  • using other methods of personal data processing.

3.8. Disclosure to third parties and dissemination of personal data without the consent of the personal data subject is not allowed, unless otherwise provided by federal law.

3.9. The transfer of personal data to bodies of inquiry and investigation, to the Federal Tax Service, the Pension Fund, the Social Insurance Fund and other authorised executive authorities and organisations is carried out in accordance with the requirements of the legislation of the Russian Federation.

3.10. The Operator takes the necessary legal, organisational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, dissemination and other unauthorised actions, including:

  • identifies threats to the security of personal data during their processing;
  • adopts local regulations and other documents governing relations in the field of personal data processing and protection;
  • appoints persons responsible for ensuring the security of personal data in the Operator's structural units and information systems;
  • creates the necessary conditions for working with personal data;
  • organises the recording of documents containing personal data;
  • organises work with information systems in which personal data are processed;
  • stores personal data in conditions that ensure their preservation and exclude unlawful access to them;
  • organises training for the Operator's employees who process personal data.

3.11. The Operator stores personal data in a form that allows the personal data subject to be identified, no longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law, a contract or an agreement.

3.12. When collecting personal data, including via the information and telecommunications network Internet, the Operator ensures the recording, systematisation, accumulation, storage, rectification (updating, modification) and extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except in the cases specified in the Personal Data Law.

3.13. Purposes of personal data processing:

3.13.1. Only personal data that meet the purposes of their processing are subject to processing.

3.13.2. The Operator's processing of personal data is carried out for the following purposes:

  • maintaining HR and accounting records;
  • ensuring compliance with the labour legislation of the Russian Federation;
  • recruiting personnel (applicants) for the operator's vacant positions;
  • ensuring compliance with the tax legislation of the Russian Federation;
  • ensuring compliance with the pension legislation of the Russian Federation;
  • ensuring the access control regime on the operator's territory.

3.14.3. The processing of employees' personal data may be carried out exclusively for the purposes of ensuring compliance with laws and other regulatory legal acts.

3.14.4. Personal data processing is allowed in the following cases:

  • personal data processing is carried out with the consent of the personal data subject to the processing of their personal data;
  • personal data processing is necessary for the performance of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
  • personal data processing is necessary to protect the life, health or other vital interests of the personal data subject if obtaining the consent of the personal data subject is impossible;
  • personal data processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties, including in the cases provided for by Federal Law “On the protection of the rights and legitimate interests of natural persons in the course of activities to recover overdue debts and on amendments to the Federal Law ‘On microfinance activities and microfinance organisations’”, or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject;
  • personal data processing is carried out for statistical or other research purposes, except for the purposes specified in article 15 of the Federal Law “On Personal Data”, subject to the mandatory anonymisation of personal data;
  • personal data is processed to which access by an unlimited circle of persons has been granted by the personal data subject or at their request (hereinafter — personal data made public by the personal data subject);
  • personal data subject to publication or mandatory disclosure in accordance with federal law is processed;

The processing of special categories of personal data concerning health is allowed:

  • if the personal data subject has given written consent to the processing of their personal data;
  • in accordance with the legislation on state social assistance, labour legislation, pension legislation of the Russian Federation.

3.14.5. The Operator has the right to entrust the processing of personal data to another person on the basis of a contract concluded with that person, including a state or municipal contract.

The person processing personal data on the instructions of the operator is obliged to comply with the principles and rules of personal data processing provided for by Federal Law “On Personal Data”.

In addition, the operator has the right to transfer personal data to bodies of inquiry and investigation, and to other authorised bodies, on the grounds provided for by the current legislation of the Russian Federation.

3.15. Categories of personal data subjects.

The personal data of the following PD subjects are processed:

  • employees of the operator, former employees, applicants, as well as relatives of employees.

3.16. Personal data processed by the Operator:

  • data obtained in the course of labour relations. In this category of subjects the operator processes:

    • surname, name, patronymic;
    • gender;
    • citizenship;
    • date (day, month, year) and place of birth (country, republic, krai, oblast, district, city, town, village, other settlement);
    • address of residence (postal code, country, republic, krai, oblast, district, city, town, village, other settlement, street, house, building, apartment);
    • information on registration at the place of residence or stay (postal code, country, republic, krai, oblast, district, city, town, village, other settlement, street, house, building, apartment);
    • telephone numbers (home, mobile, work), e-mail address;
    • position held;
    • information on employment history (names of organisations (bodies) and positions held, duration of work (service) in these organisations (bodies));
    • taxpayer identification number (date (day, month, year) and place of registration, date (day, month, year) of issue of the certificate);
    • data of the document confirming registration in the individual (personalised) accounting system, including in the form of an electronic document;
    • data of the identity document;
    • information on military registration (series, number, date (day, month, year) of issue, name of the body that issued the military ID, military registration speciality, military rank, data on registration/deregistration, on military service, on being in the reserve, on medical examination and vaccinations);
    • information on education (name of the educational organisation, date (day, month, year) of graduation, speciality and qualification, academic degree, title, details of the document on education and qualifications);
    • information on additional professional education (date (day, month, year), place, programme, details of documents issued as a result);
    • information on knowledge of foreign languages (foreign language, level of proficiency);
    • information contained in a medical report of the established form;
    • information on marital status (marital status (single (unmarried), married, remarried, divorced, widower (widow), since when married, since when divorced, number of marriages, family composition, details of the marriage certificate);
    • information on close relatives (degree of kinship, surname, name, patronymic, date (day, month, year) and place of birth, address of residence);
    • bank account number;
    • photographs.

  • data obtained for the selection of job candidates.

3.17. Storage of personal data.

3.17.1. Personal data of subjects may be obtained, further processed and transferred for storage both on paper and in electronic form.

3.17.2. Personal data recorded on paper is stored in lockable cabinets or in lockable premises with restricted access.

3.17.3. Personal data of subjects processed using automation tools for different purposes is stored in different folders.

3.17.4. Storage and placement of documents containing PD in open electronic directories is not allowed.

3.17.5. Personal data is stored in a form that allows the PD subject to be identified no longer than the purposes of their processing require, and is subject to destruction upon achievement of the processing purposes or in case the need to achieve them is lost.

3.17. Destruction of personal data.

3.17.1. Destruction of documents (media) containing PD is carried out by burning, crushing (grinding), chemical decomposition, or conversion into a shapeless mass or powder. The use of a shredder is allowed for the destruction of paper documents.

3.17.2. Personal data on electronic media is destroyed by erasing or formatting the media.

3.17.3. The fact of destruction of personal data is confirmed by a document — an act on the destruction of media.

4. PROCEDURE AND CONDITIONS FOR PROCESSING BIOMETRIC PERSONAL DATA

4.1. Biometric personal data includes information that characterises the physiological and biological characteristics of a person, on the basis of which their identity can be established and which is used by the operator to establish the identity of the personal data subject.

4.2. The processing of biometric personal data may be carried out only with written consent of the personal data subject, except in cases related to the implementation of international treaties of the Russian Federation on readmission, in connection with the administration of justice and the execution of judicial acts, in connection with mandatory state fingerprint registration, as well as in the cases provided for by the legislation of the Russian Federation on defence, security, countering terrorism, transport security, countering corruption, operational-investigative activities, the state civil service, the criminal-executive legislation of the Russian Federation, the legislation of the Russian Federation on the procedure for exit from the Russian Federation and entry into the Russian Federation, and on citizenship of the Russian Federation.

4.3. The processing of biometric personal data is carried out by the operator in accordance with the requirements for the protection of biometric personal data established in accordance with article 19 of the Federal Law “On Personal Data”.

4.4. The use and storage of biometric personal data outside personal data information systems may be carried out only on such tangible information media and using such technology of its storage as ensure the protection of these data from unlawful or accidental access to them, their destruction, modification, blocking, copying, provision, dissemination.

4.5. A tangible medium means a machine-readable information medium (including magnetic and electronic) on which information characterising the physiological characteristics of a person and on the basis of which their identity can be established is recorded and stored.

4.6. The Operator approves the procedure for transferring tangible media to authorised persons.

4.7. The tangible medium must be used for the period established by the operator that recorded the biometric personal data on the tangible medium, but not longer than the service life established by the manufacturer of the tangible medium.

4.8. The Operator is obliged:

  • to keep records of the number of copies of tangible media;
  • to assign a tangible medium a unique identification number allowing the operator that recorded the biometric personal data on the tangible medium to be precisely identified.

5. UPDATING, RECTIFICATION, DELETION AND DESTRUCTION OF PERSONAL DATA, RESPONSES TO SUBJECTS' REQUESTS FOR ACCESS TO PERSONAL DATA

5.1. The Operator is obliged to inform, in the manner provided for by article 14 of the Federal Law “On Personal Data”, the personal data subject or their representative of the availability of personal data relating to the respective personal data subject, and to provide an opportunity to review these personal data upon request of the personal data subject or their representative, or within thirty days from the date of receipt of the request of the personal data subject or their representative.

5.2. The Operator is obliged to provide, free of charge, to the personal data subject or their representative an opportunity to review the personal data relating to that personal data subject. Within a period not exceeding seven working days from the day the personal data subject or their representative provides information confirming that the personal data is incomplete, inaccurate or outdated, the operator is obliged to make the necessary changes to it. Within a period not exceeding seven working days from the day the personal data subject or their representative provides information confirming that such personal data was obtained unlawfully or is not necessary for the stated purpose of processing, the operator is obliged to destroy such personal data. The Operator is obliged to notify the personal data subject or their representative of the changes made and the measures taken, and to take reasonable measures to notify third parties to whom the personal data of this subject was transferred.

5.3. If the fact of inaccuracy of personal data is confirmed, the operator, on the basis of information provided by the personal data subject or their representative or by the authorised body for the protection of the rights of personal data subjects, or other necessary documents, is obliged to rectify the personal data or ensure their rectification (if the processing of personal data is carried out by another person acting on the instructions of the operator) within seven working days from the day such information is provided, and to unblock the personal data.

5.4. The Operator is obliged to stop the processing of personal data or ensure that the processing of personal data is stopped by a person acting on the instructions of the operator:

  • in the event of detection of unlawful processing of personal data carried out by the operator or a person acting on the instructions of the operator, within a period not exceeding three working days from the date of such detection;
  • in the event of withdrawal by the personal data subject of consent to the processing of their personal data;
  • in the event of achieving the purpose of personal data processing — and to destroy the personal data or ensure their destruction (if the processing of personal data is carried out by another person acting on the instructions of the operator) within a period not exceeding thirty days from the date of achieving the purpose of personal data processing. If it is impossible to destroy personal data within the specified period, the operator blocks such personal data or ensures their blocking (if the processing of personal data is carried out by another person acting on the instructions of the operator) and ensures the destruction of personal data within a period of no more than six months, unless a different period is established by federal laws.

6. USE OF COOKIES, ANALYTICS AND MESSENGERS ON THE SITE

6.1. The Site uses cookies and the Yandex.Metrica service to improve performance and analyse traffic. Analytical tools are connected only after the user's consent; the cookie banner does not block content and does not cover action buttons. In the banner you can accept all cookies, reject them or configure categories (necessary and analytical). When visiting the Site, technical information is automatically processed to the extent necessary for its operation and protection: IP address, cookie data, information about the user's browser and device, date and time of access, addresses of requested pages. The collection of such information by analytical services is performed only after the user's consent.

6.2. Click maps and Webvisor are used to improve the interface. Form input fields are excluded from recording by service markup.

6.3. You can contact a manager by phone (clicking the number), as well as via the MAX and Telegram messengers (following a link or QR code to the bot). When contacting via messengers, the Operator does not collect or store personal data on the Site; processing is carried out in the respective messenger to the extent necessary to respond to the enquiry.

6.4. When a request is sent via the forms, the fact of consent to the processing of personal data is recorded (date, time, version of the policy) as evidence of consent.

6.5. The user may at any time opt out of analytical cookies: restrict or delete cookies using browser tools or contact us using the contacts listed on the Site. Refusal of analytical cookies does not restrict access to the content of the Site.

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