This Policy (hereinafter referred to as the Personal Data Processing Policy) defines the terms of processing personal data received via website https://suldukar.ru (hereinafter referred to as the Website) owned by «SyuldyukarNefteGaz» JSC (Primary State Registration Number (OGRN) 1137746302462, Taxpayer Identification Number (INN) 7702812630) in order to protect the rights and freedoms of individuals and citizens while processing their personal data, including protection of their rights to privacy, personal and family secrecy. The use of the Website services implies that the User unconditionally agrees with this Policy and the terms of processing his/her personal data specified herein; in case of disagreement with these terms, the User shall abstain from using the services.

1. GENERAL

1.1. The following terms are used in this Personal Data Processing Policy:

personal data – any information relating to a directly or indirectly identified or identifiable individual (personal data subject);

personal data operator (operator) – state authority, municipal authority, legal entity or individual, who independently or jointly with other persons organizes and (or) performs personal data processing, as well as determines the purposes of personal data processing, composition of personal data to be processed, actions (operations) performed with personal data;

personal data subject (user) — a person (individual) to whom the personal data applies and who can be identified by it;

personal data processing – any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation tools. Personal data processing includes, but is not limited to: collection; recording; systematization; accumulation; storage; clarification (update, modification); retrieval; use; transfer (distribution, provision, access); depersonalization; blocking; deletion; destruction;

automated personal data processing – processing of personal data by means of computer equipment;

distribution of personal data – actions aimed at disclosure of personal data to an indefinite number of persons;

provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain number of persons;

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 material storage media of personal data are destroyed;

depersonalization of personal data – actions, as a result of which it becomes impossible to determine the belonging of personal data to a particular personal data subject without using additional information;

personal data information system – a set of information technologies and technical means contained in personal data databases and ensuring their processing;

cookies — a small piece of data sent by a web server and stored on the User’s computer, which a web client or web browser sends to the web server in an HTTP request whenever it tries to open a page on the relevant website;

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

1.2. For the purposes of this Policy, the User’s personal information shall mean:

1.2.1. Personal information that the User provides about himself/herself when filling out the feedback form on the Website, including the name (surname and patronymic) of the User; contact phone number of the User; e-mail address and other information related to the User’s personal data.

1.2.2. Data that are automatically transmitted to the Website services during their use via the software installed on the User’s device, including IP-address, cookie data, information about the User’s browser (or other program to access the services), technical characteristics of equipment and software utilized by the User, date and time of access to the services, addresses of requested pages and other similar information.

1.3. This Personal Data Processing Policy applies only to the Website www.suldukar.ru. The Website www.suldukar.ru shall not control and shall not be responsible for third party websites which the User can access via links available on the Website www.suldukar.ru.

2. PURPOSES OF PROCESSING USERS’ PERSONAL INFORMATION

2.1. The Website collects and stores only the personal information that is necessary for the provision of services or conclusion, execution of agreements and contracts with the User, except where the laws provide for mandatory storage of personal information for a specified period of time.

In case of receipt of a notice from the User on withdrawal of consent to personal data processing, the Website shall cease processing of the User’s personal data within a period not exceeding 10 business days from the date of receipt.

2.2. The Website processes User’s personal information for the following purposes:

2.2.1. Collection of the User’s data required for feedback.

3. CONDITIONS OF PROCESSING USERS’ PERSONAL INFORMATION

AND ITS TRANSFER TO THIRD PARTIES

3.1. The legal basis for processing the User’s personal information shall be the User’s consent.

3.2. The Website stores personal information of the Users in accordance with the internal regulations of specific services.

3.3. The User’s personal information shall be kept confidential, except for cases when the User voluntarily provides information about himself/herself for general access of an unlimited number of persons.

3.4. The Website shall have the right to transfer the User’s personal information to third parties when:

3.4.1. The User expressed his/her consent to such actions.

3.4.2. The transfer is provided for by Russian or other applicable law under a procedure established by the law.

3.4.3. Transfer of data is performed to contractors providing hosting, technical support or other services necessary for the Website operation, provided that they comply with the requirements on confidentiality and protection of personal data.

3.4.4. In the event of sale of the Website, the buyer shall be transferred all obligations to comply with the terms of this Policy in relation to the personal information received by it.

3.5. Processing of the User’s personal data shall be performed using the following methods: collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data, including in personal data information systems with or without the use of automation tools. Processing of Users’ personal data shall be performed in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006.

3.6. Personal data transmitted through the feedback form shall be stored until the processing of the personal data subject’s request is completed and a response to his/her request is provided, but no longer than 90 days from the date of receipt of the data. After the expiration of the specified period, personal data will be automatically deleted.

3.6. Storage of user data shall be performed in the Russian Federation.

3.7. In case of loss or disclosure of personal data, the Website Administration shall inform the User of the loss or disclosure of personal data.

3.8. The Website Administration shall undertake necessary organizational and technical measures to protect the User’s personal information from illegal or unintentional access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

3.9. The Website Administration together with the User shall take all necessary measures to prevent losses or other negative consequences caused by loss or disclosure of the User’s personal data.

4. OBLIGATIONS OF THE PARTIES

4.1. The User shall:

4.1.1. Not provide knowingly false information, including personal data of other persons.

4.2. The Website Administration shall:

4.2.1. Use the information obtained exclusively for the purposes specified in this Personal Data Processing Policy.

4.2.2. Ensure confidentiality of confidential information, not disclose without prior written authorization of the User, as well as not sell, exchange, publish or disclose by other possible means the transferred personal data of the User, except as provided for in this Personal Data Processing Policy.

4.2.3. The Website Administration shall undertake necessary organizational, legal and technical measures to protect the User’s personal information from illegal or unintentional access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

4.2.4. Perform blocking of personal data related to the respective User from the moment of application or request of the User or his/her legal representative or the authorized body for protection of the rights of personal data subjects for the period of verification in case of detection of unreliable personal data or unlawful actions.

5. LIABILITY OF THE PARTIES

5.1. The Website Administration, which has not fulfilled its obligations, shall be liable for losses incurred by the User in connection with the unauthorized use of personal data, in accordance with the laws of the Russian Federation.

5.2. In case of loss or disclosure of confidential information, the Website Administration shall not be held liable if such confidential information:

5.2.1. Became public domain prior to its loss or disclosure.

5.2.2. Was received from a third party before it was received by the Website Administration.

5.2.3. Was disclosed with the consent of the User.

6. DISPUTE RESOLUTION

6.1. Before appealing to the court with a claim on disputes arising from the relations between the Website User and the Website Administration, it is required to submit a claim (a written proposal for voluntary settlement of the dispute).

6.2. The claim recipient shall notify the claimant in writing of the results of the claim review within 30 calendar days of receipt of the claim.

6.3. In case of failure to reach an agreement, the dispute shall be referred to the court for consideration in accordance with the effective laws of the Russian Federation.

6.4. The effective laws of the Russian Federation shall apply to this Personal Data Processing Policy and relations between the User and the Website Administration.

7. ADDITIONAL TERMS AND CONDITIONS

7.1. The Website Administration shall have the right to make amendments to this Personal Data Processing Policy without the User’s consent.

7.2. New Personal Data Processing Policy shall come into effect from the moment of its publication on the Website, unless otherwise provided by the new revision of the Personal Data Processing Policy.

7.4. Current Personal Data Processing Policy is available at https://suldukar.ru/en/personal-data-processing-policy.