Personal Data Processing Policy

1. General Provisions

The current Personal Data Processing Policy is developed based on the requirements of the Federal Law No. 152-FZ on Personal Data dated July 27, 2006 to stipulate the order of personal data processing and measures on JSC UTLC ERA (thereinafter – Operator) personal data protection.

  1. The Operator sees respect for human and civic rights and liberties, including a right to personal and family privacy, while processing personal data its primary target and a prerequisite of activities.
  2. The current Personal Data Processing Policy (thereinafter – Policy) of the Operator is applied to all the information about visitors of website the Operator can obtain.

2. Basic terms used in the Policy

  1. Automated personal data processing – personal data processing by means of computer technology;
  2. Personal data blocking – temporary interruption of personal data processing (except where processing is required for personal data update);
  3. Website – a set of graphic and informational materials, as well as computer software and databases that provide their access to the Internet via web address;
  4. Personal data information systems – a set of personal data included into personal data databases, as well as the software and tools used for their processing;
  5. Personal data depersonalization – actions making it impossible to identify personal data as related to a certain User or other personal data subject without using additional information;
  6. Personal data processing – any action (operation) or a series of actions (operations) performed towards personal data with or without automated equipment, including personal data acquisition, recording, systematization, accumulation, storage, refinement (update and alteration), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deleting and annihilation;
  7. Operator – state authority, municipal authority, entity or person that independently or together with other entities or persons arranges and/or performs personal data processing, as well as defines the goals of personal data processing, the scope of personal data to be processed, actions (operations) to be performed with personal data;
  8. Personal data – any information which is directly or indirectly related to a certain or specified User of website;
  9. User – any visitor of website;
  10. Personal data provision – actions aimed at disclosure of personal data to a particular person or a certain group of persons;
  11. Personal data distribution – any actions aimed at disclosure of personal data to an uncertain group of persons (personal data transfer) or at insight into personal data for an unlimited range of persons, including personal data disclosure in mass media, distribution in information and telecommunication networks or provision of access to personal data by any other means;
  12. Trans-border transfer of personal data – transfer of personal data to the territory of a foreign country, to the government body of a foreign country, to a foreign legal entity or person;
  13. Personal data annihilation – any actions aimed at irreversible destruction of personal data making it impossible to restore personal data in the personal data information system and/or resulting in elimination of tangible personal data storage media.

3. The Operator may process the following personal data of the User

  1. Surname, name, patronymic name;
  2. Electronic mail;
  3. Also, depersonalized data about visitors (including cookies) are acquired and processed on the website with Internet statistics services (Yandex Metrika, Google Analytics and others).
  4. Abovementioned data are hereinafter referred to in the Policy as a general concept of Personal data.

4. Purposes of Personal Data Processing

  1. The purpose of personal data processing is to inform the User by sending electronic letters; to provide access to the services, information and/or materials the website contains to the User.
  2. Also, the Operator has a right to send notifications about new products and services, special offers and various events to the User. The User may always opt out of information messages by sending an electronic letter to the Operator to marked ‘Opt-out of notifications about new products and services, and special offers’.
  3. Users’ depersonalized data acquired via Internet statistics services serve to collect information about Users’ activities on the website in order to improve its quality and content.

5. Legal Basis for Personal Data Processing

  1. The Operator processes User’s personal data only if they are filled out and/or sent by the User him/herself via special forms published on the website By filling out relevant forms and/or sending one’s personal data to the Operator, the User signifies his/her agreement with the current Policy.
  2. The Operator processes User’s depersonalized data if it is allowed by the User’s browser settings (cookies are saved and JavaScript is used).

6. Order of Personal Data Acquisition, Storage, Transfer and Other Kinds of Processing

Protection of personal data processed by the Operator is ensured by implementation of legal, organizational and technical measures needed to fulfil the applicable statutory requirements regarding personal data protection to the full extent.

  1. The Operator ensures safety of personal data and takes all the possible measures to prevent unauthorized access to personal data.
  2. Under no circumstances shall personal data be transferred to the third parties except in cases related to execution of legislation in power.
  3. In case any inaccuracies of personal data are revealed, the User can update them by themselves by sending a notification to the Operator to the electronic mail address marked ‘Personal data update’.
  4. The time of personal data processing is unlimited. The User can withdraw consent to personal data processing by sending a notification to the Operator to the electronic mail address marked ‘Withdrawal of consent to personal data processing’.

7. Trans-Border Transfer of Personal Data

  1. Before starting trans-border transfer of personal data the Operator shall make sure that the foreign country to the territory of which personal data are supposed to be transferred provides reliable protection of rights of subjects of personal data.
  2. Trans-border transfer of personal data on the territory of a foreign country that doesn’t meet the abovementioned requirements can be performed only upon written consent of the relevant personal data subject to trans-border transfer of their personal data and/or execution of the contract with the subject of personal data as a party.

8. Concluding Provisions

  1. The User can get any explanations regarding points of interest about their personal data processing by addressing the Operator via electronic mail
  2. Any amendments to the Personal Data Processing Policy made by the Operator will be recorded in this document. The Policy remains in force indefinitely until it is replaced with a new version.
  3. The latest version of the Policy is available at free access on