PERSONAL DATA PROCESSING POLICY

1. General Provisions

This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (hereinafter, the Personal Data Law) and sets out the procedure for processing personal data and the measures taken by LEVAGRO LLC (hereinafter, the Operator) to ensure the security of personal data.
1.1. The Operator's most important goal and condition for conducting its activities is respect for the rights and freedoms of individuals and citizens when processing their personal data, including protection of the rights to privacy and to personal and family secrets.
1.2. This Operator's policy regarding personal data processing (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website https://www.ltdplant.ru/.

2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://www.ltdplant.ru/.
2.4. Personal data information system — the totality of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data and determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://www.ltdplant.ru/.
2.9. Personal data authorized by the subject for dissemination — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized for dissemination in the manner prescribed by the Personal Data Law (hereinafter, personal data authorized for dissemination).
2.10. User — any visitor to the website https://www.ltdplant.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system, and/or the destruction of the physical media of personal data.

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 the personal data subject;
— where the personal data subject withdraws consent to the processing of personal data or submits a request to stop processing personal data, continue processing personal data without the subject's consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to fulfil the obligations stipulated by the Personal Data Law and the 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 personal data subject, at their request, with information concerning the processing of their personal data;
— organize personal data processing in the manner established by the current legislation of the Russian Federation;
— respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, at its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision and dissemination, as well as from other unlawful actions with respect to personal data;
— stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the Operator clarify, block or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and take measures provided for by law to protect their rights;
— set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data and submit a demand to stop processing personal data;
— appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects 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 reliable information about themselves;
— inform the Operator of any clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of its collection is not permitted.
5.3. Combining databases containing personal data processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes of processing is not permitted.
5.6. When processing personal data, its accuracy, sufficiency and, where necessary, relevance in relation to the purposes of processing are ensured. The Operator takes and/or ensures the taking of necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: clarification of order details
Personal data:
— email address
— telephone numbers
— surname and first name
Legal grounds:
Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" dated 27.07.2006
Types of personal data processing:
Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data.

7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, or the execution of a judicial act or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding 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.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter, publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are found in personal data, the User may update them independently by sending a notice to the Operator's email address partners@ltdplant.ru marked "Updating personal data".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by a contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator's email address partners@ltdplant.ru marked "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should review these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures its confidentiality.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Grounds for terminating personal data processing may include achievement of the purposes of processing, expiry of the personal data subject's consent, withdrawal of consent by the personal data subject or a demand to stop processing personal data, as well as detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the information obtained via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notice is sent separately from the notice of intention to process personal data).
10.2. Before submitting the above notice, the Operator is obliged to obtain relevant information from the foreign state authorities, foreign individuals and foreign legal entities to which cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Destruction of Personal Data
12.1. Personal data is destroyed (deleted) by responsible persons in the manner provided for by current legislation and the Operator's internal regulations:

• in cases provided for by law;
• at the request of the personal data subject, a state body or a court;
• upon expiry of the storage periods;
• upon achievement of the purposes of processing.

12.2. Personal data is destroyed in a manner that excludes the possibility of its theft and unauthorized use.
12.3. Paper documents are destroyed using a paper shredder by cutting them into pieces that guarantee the text cannot be restored, or by other means.
12.4. Machine-readable media containing personal data, if any (except for hard drives of PCs and servers), are kept in a safe. Machine-readable media are physically destroyed so that they cannot be restored or used further. This is achieved by deforming the media, breaking its integrity or burning it.
12.5. Files subject to destruction located on the hard drive of a PC or server are deleted using operating system tools, followed by emptying the recycle bin. Data in information systems is deleted using the tools and functionality of those information systems; in any case, the possibility of restoring personal data is not envisaged.
12.6. If the personal data subject, on their own initiative, provides additional personal data not required to achieve the purpose of processing, such data will be destroyed by the Operator immediately after the appeal has been considered or other interaction with the subject has taken place.

13. Final Provisions
13.1. The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator by email at partners@ltdplant.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 it is replaced by a new version.
13.3. The current version of the Policy is freely available on the Internet at https://www.ltdplant.ru/politica_eng.