1. General ProvisionsThis personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27 July 2006 (hereinafter referred to as the "Law on Personal Data") and defines the procedure for the processing of personal data and the measures taken to ensure the security of personal data by LLC TD "TMZ " (hereinafter referred to as the "Operator").
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets.
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
https://td-tmz.com.2. Basic Concepts Used in the Policy2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases 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 that ensure their availability on the Internet at the network address
https://td-tmz.com.2.4. Personal data information system — a set of personal data contained in databases, and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, whether personal data belongs to 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 or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, 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, as well as determines the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website
https://td-tmz.com.2.9. Personal data authorized by the personal data subject for distribution — personal data, access of an unlimited number of persons to which is granted by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure provided for by the Law on Personal Data (hereinafter referred to as "personal data authorized for distribution").
2.10. User — any visitor to the website
https://td-tmz.com.2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited group of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunications networks, or granting 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 a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irretrievably destroyed with no possibility of further restoration of the content of the personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to:
– receive from the personal data subject reliable information and/or documents containing personal data;
– in the event that the personal data subject withdraws consent to the processing of personal data, the Operator is entitled to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
– provide the personal data subject, upon their request, with information concerning the processing of their personal data;
– organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
– respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
– report to the authorized body for the protection of the rights of personal data subjects, upon the request of this body, the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise provide 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 to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
– cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Law on Personal Data;
– fulfill other obligations provided for by the Law on Personal Data.
4. Main Rights and Obligations of Personal Data Subjects4.1. 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 it must not contain personal data relating to other personal data subjects, except in cases where there are lawful grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
– demand from the operator the clarification of their personal data, its blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
– put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
– withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
– 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 data about themselves;
– inform the Operator about the clarification (updating, modification) 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, bear responsibility in accordance with the legislation of the Russian Federation.
5. The Operator May Process the Following Personal Data of the User5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. The website also collects and processes anonymized data about visitors (including cookies) through internet statistics services (Yandex Metrica, Google Analytics and others).
5.5. The data listed above are hereinafter referred to in the text of the Policy under the general term "Personal data".
5.6. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data authorized for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is permitted if the prohibitions and conditions provided for in Article 10.1 of the Law on Personal Data are observed.
5.8. The User's consent to the processing of personal data authorized for distribution is executed separately from other consents to the processing of their personal data. In doing so, the conditions provided for, in particular, by Article 10.1 of the Law on Personal Data are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1. The User provides the Operator with consent to the processing of personal data authorized for distribution directly.
5.8.2. The Operator is obliged, no later than three working days from the moment of receiving the said consent of the User, to publish information on the terms of processing, on the existence of prohibitions and conditions on the processing of personal data authorized for distribution by an unlimited number of persons.
5.8.3. The transfer (distribution, provision, access) of personal data authorized by the personal data subject for distribution must be terminated at any time at the request of the personal data subject. This request must include the last name, first name, patronymic (if any), contact information (telephone number, email address or postal address) of the personal data subject, as well as a list of the personal data whose processing is to be terminated. The personal data specified in this request may be processed only by the Operator to whom it is addressed.
5.8.4. Consent to the processing of personal data authorized for distribution ceases to be effective from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.
6.3. The combination of databases containing personal data processed for purposes that are incompatible with each other is not allowed.
6.4. Only personal data that meets the purposes of its processing is subject to processing.
6.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of its processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing is ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in the event that the need to achieve these purposes is lost, unless otherwise provided for by federal law.
7. Purposes of Personal Data Processing7.1. Purposes of processing the User's personal data:
– informing the User by sending emails;
– conclusion, performance and termination of civil law contracts;
– providing the User with access to services, information and/or materials contained on the website
https://td-tmz.com.7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may always opt out of receiving informational messages by sending the Operator a letter to the email address
amulilina@td-tmz.com marked "Opt-out of notifications about new products and services and special offers".
7.3. Anonymized data of Users collected through internet statistics services serves to collect information about Users' actions on the website and to improve the quality of the website and its content.
8. Legal Grounds for Personal Data Processing8.1. The legal grounds for the processing of personal data by the Operator are:
– Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" dated 27 July 2006;
– federal laws and other regulatory legal acts in the field of personal data protection;
– the consent of Users to the processing of their personal data and to the processing of personal data authorized for distribution.
8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User independently through special forms located on the website
https://td-tmz.com or sent to the Operator by email. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (storage of cookies and use of JavaScript technology are enabled).
8.4. The personal data subject independently decides on the provision of their personal data and gives consent freely, of their own will and in their own interest.
9. Conditions for Personal Data Processing9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, 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.
9.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated thereby.
9.6. The processing of personal data is carried out where access of an unlimited number of persons to it is granted by the personal data subject or at their request (hereinafter referred to as "publicly available personal data").
9.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for the Collection, Storage, Transfer and Other Types of Personal Data ProcessingThe 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 in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of the current legislation or if the personal data subject has given the Operator consent to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. In the event of inaccuracies in personal data, the User may update it independently by sending the Operator a notification to the Operator's email address
amulilina@td-tmz.com marked "Updating of personal data".
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by the agreement or the current legislation. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification by email to the Operator's email address
amulilina@td-tmz.com marked "Withdrawal of consent to the processing of personal data".
10.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to independently and promptly familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the personal data subject on the transfer (except for the provision of access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases of personal data processing in state, public and other public interests determined by the legislation of the Russian Federation.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
10.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiry of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.
11. List of Actions Performed by the Operator with the Received Personal Data11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the received information via information and telecommunications networks.
12. Cross-Border Transfer of Personal Data12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.
12.2. The cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if there is written consent of the personal data subject to the cross-border transfer of their personal data and/or the performance of an agreement to which the personal data subject is a party.
13. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
14. Final Provisions14.1. The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator via email at
amulilina@td-tmz.com.
14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at
https://td-tmz.com.