1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data implemented by JSC “NPO "AHTUBA" (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of privacy, personal and family secrets, to be the most important goal and condition for the Operator's activities.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website npo-ahtuba.ru.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computing technology.

2.2. Blocking of personal data — temporary suspension of personal data processing (except for cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address npo-ahtuba.ru.

2.4. Information system of personal data — a set of personal data contained in databases, and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions resulting in the inability to determine, without the use of additional information, the association of personal data with a specific User or other subject of personal data.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a state authority, municipal authority, legal or natural person who organizes and/or performs the processing of personal data independently or together with other persons, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information related directly or indirectly to a specific or identifiable User of the website npo-ahtuba.ru.

2.9. Personal data permitted by the subject of personal data for distribution — personal data made available to an unlimited number of persons by the subject of personal data by providing consent for the processing of personal data for distribution as prescribed by the Personal Data Law.

2.10. User — any visitor to the website npo-ahtuba.ru.

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

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an indefinite number of persons, including publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign government authority, foreign natural or foreign legal person.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data in information systems and/or the destruction of the physical media on which personal data are stored.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

— Receive accurate information and/or documents containing personal data from the subject of personal data;

— Continue processing personal data without the consent of the subject of personal data if the subject withdraws their consent to the processing of personal data or submits a request to cease processing, provided that there are grounds specified in the Personal Data Law;

— Independently determine the necessary and sufficient measures to ensure compliance with obligations under the Personal Data Law and regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— Provide the subject of personal data with information regarding the processing of their personal data upon request;

— Organize the processing of personal data in accordance with the current legislation of the Russian Federation;

— Respond to requests and inquiries from subjects of personal data and their authorized representatives in accordance with the Personal Data Law;

— Notify the authorized body for the protection of personal data subjects' rights, upon request, within 10 days of receiving such a request;

— Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions with personal data;

— Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;

— Fulfill other obligations provided for by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— Receive information regarding the processing of their personal data, except in cases provided for by federal law. Information is provided by the Operator to the subject of personal data in an accessible form and should not contain personal data related to other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;

— Require the Operator to clarify their personal data, block or destroy personal data if the personal data is incomplete, outdated, inaccurate, obtained illegally, or is not necessary for the stated purposes of processing, as well as take the measures provided by law to protect their rights;

— Condition their consent to the processing of personal data for the promotion of goods, works, and services on the market;

— Withdraw consent to the processing of personal data, as well as submit a request to cease the processing of personal data;

— Appeal against unlawful actions or inaction of the Operator regarding the processing of their personal data to the authorized body for the protection of personal data subjects' rights or in court;

— Exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

— Provide the Operator with accurate data about themselves;

— Notify the Operator of updates (changes, modifications) to their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without their consent bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a legal and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. It is prohibited to combine databases containing personal data whose processing is carried out for purposes that are incompatible with each other.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and volume of processed personal data must correspond to the stated purposes of processing. The processing of excessive personal data that is not necessary for the stated purposes is not permitted.

5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured during the processing of personal data. The Operator shall take the necessary measures and/or ensure the taking of measures to remove or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the identification of the subject of personal data for no longer than is required by the purposes of the personal data processing, unless a longer retention period is established by federal law, a contract to which the personal data subject is a party, or in which the personal data subject is a beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing objectives or if the need to achieve these objectives is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing:

— informing the User by sending emails.

Personal data:

— last name, first name, patronymic,

— email address,

— phone numbers.

Legal basis:

— Federal Law "On Information, Information Technologies, and Information Protection" dated July 27, 2006 No. 149-FZ.

Types of personal data processing:

— Transfer of personal data.

7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

7.2. The processing of personal data is necessary for achieving purposes stipulated by an international treaty of the Russian Federation or a law, for fulfilling functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another authority, or official to be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, a beneficiary, or a guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the realization of the legitimate interests of the Operator or third parties or for the attainment of socially significant goals, provided that the rights and freedoms of the personal data subject are not infringed.

7.6. Processing of personal data made available to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures required for the full compliance with the requirements of applicable legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of applicable legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party for the performance of obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User can independently update them by sending a notification to the Operator at the email address info@npo-ahtuba.ru with the subject "Update of personal data."

8.4. The duration of personal data processing is determined by achieving the purposes for which the personal data were collected unless another period is provided by contract or applicable legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@npo-ahtuba.ru with the subject "Withdrawal of consent for personal data processing."

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is obligated to familiarize themselves with the documents governing the handling of such data by third-party providers. The Operator is not responsible for the actions of third parties, including service providers mentioned in this section.

8.6. The restrictions established by the personal data subject on the transfer (except for providing access) and processing of personal data allowed for dissemination do not apply in cases of processing personal data in the state, public, and other public interests as defined by Russian legislation.

8.7. The Operator ensures the confidentiality of personal data during its processing.

8.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than is required by the purposes of the personal data processing, unless the retention period is established by federal law, a contract to which the personal data subject is a party, or in which the personal data subject is a beneficiary or guarantor.

8.9. The condition for the termination of personal data processing may be the achievement of the objectives of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject, or a request for termination of personal data processing, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Collected Personal Data

9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information via telecommunication networks or without such networks.

10. Cross-border Transfer of Personal Data

10.1. Before starting the cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of personal data subjects' rights of its intention to transfer personal data across borders (this notification is sent separately from the notification of intention to process personal data).

10.2. Before submitting the above notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Collection of Cookies by Analytical Systems

12.1. The Operator uses cookies on the website for the operation of analytical systems such as Yandex.Metrica and Google Analytics for the purpose of analyzing user behavior and improving the website's performance.

12.2. The Yandex.Metrica and Google Analytics systems automatically collect and process anonymized data, including information on page visits, time spent on the site, traffic sources, and other behavioral metrics.

12.3. Data is collected through the use of cookies — small text files stored on the user's device, which allow analytical systems to track the user's actions on the website.

12.4. The Operator does not collect or store data that allows the identification of the user through analytical cookies.

12.5. The User can configure the use of cookies by changing browser settings to block or delete them or refuse the use of cookies on the website through the cookie preferences management interface available on the website.

12.6. Detailed information on the privacy policy and data processing by analytical systems is available on the websites:

• Yandex.Metrica Privacy Policy

• Google Analytics Privacy Policy

13. Final Provisions

13.1. The User can obtain any clarifications regarding questions of interest concerning the processing of their personal data by contacting the Operator via email at info@npo-ahtuba.ru.

13.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is valid indefinitely until replaced by a new version.

13.3. The current version of the Policy is freely available on the Internet at the address: npo-ahtuba.ru/en/privacy