Personal Data Processing Policy

1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" (hereinafter referred to as the "Law on Personal Data"), which determines the order of processing personal data and the measures to ensure the security of such data undertaken by LLC "PanChemicals" (hereinafter referred to as the "Operator"). No. 152-FZ "On Personal Data" (hereinafter referred to as the "Law on Personal Data"), and it establishes the procedures for processing personal data and the measures that LLC "PanChemicals" (hereinafter referred to as the "Operator") will take to ensure the security of personal data.
1.1. The Operator's primary goal and condition of its activity is to observe human and citizens' rights and freedoms when processing personal data, including the right to privacy and the right to personal and family secrecy.
1.2. This Operator's policy regarding the processing of personal data applies to all information that the Operator may obtain about visitors to the website https://panchem.ru.

2. Basic Concepts Used in the Policy
2.1. Automated Processing of Personal Data: Processing personal data using computer equipment.
2.2. Blocking of personal data: the temporary cessation of processing personal data (except when processing is necessary to clarify said 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://panchem.ru.
2.4. Personal Data Information System: A set of personal data contained in databases, as well as the information technologies and technical means that ensure its processing.
2.5. Personal data depersonalization: Actions resulting in the inability to determine, without the use of additional information, whether personal data belong to a particular 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 automated means on personal data, including collection, recording, systematization, accumulation, storage, clarification (update or change), extraction, use, transfer (distribution, provision, or access), depersonalization, blocking, deletion, or destruction.
2.7. Operator: A state authority, municipal authority, legal entity, or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, 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 https://panchem.ru.
2.9. Personal data authorized by the subject of personal data for dissemination: Personal data to which an unlimited number of persons has access when the subject of personal data gives consent to the processing of personal data authorized by the subject.
2.10. User - any visitor of the website https://panchem.ru.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number of persons, including disclosure of personal data in 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 country to a foreign government authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. Main 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.
- continue processing personal data without the consent of the personal data subject if the personal data subject revokes his or her consent to personal data processing or submits a request to stop processing personal data, provided that there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to fulfill obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise stipulated by the Personal Data Law or other federal laws;
3.2. The Operator shall:
- Provide the personal data subject with information regarding the processing of his or her personal data upon request;
- Organize the processing of personal data in accordance with the procedure established by current Russian Federation legislation. Respond to appeals and requests from data subjects and their legal representatives in accordance with the Law on Personal Data. Report to the authorized body for the protection of the rights of personal data subjects, providing the necessary information within ten days of receiving a request.
- publish or otherwise provide unrestricted access to this policy on personal data processing.
Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, or dissemination, as well as from other unlawful actions regarding personal data.
Cease the transfer, dissemination, provision, or access of personal data. Stop processing and destroy personal data in the manner and cases stipulated by the Personal Data Law. - Fulfill 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:
- to receive information regarding the processing of his/her personal data, except for cases provided for by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- demand from the operator to clarify his personal data, block or destroy it in case the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his rights;
- to impose a condition of prior consent when processing personal data in order to market goods, works and services;
- to withdraw consent to the processing of personal data, as well as to submit a request to stop the processing of personal data;
- to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of his/her personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2. The subjects of personal data shall be obliged to:
- provide the Operator with reliable data about themselves;
- notify the Operator about clarification (update, change) of their personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter shall be held liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing
5.1. Personal data processing is carried out lawfully and fairly.
5.2 The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing personal data for purposes incompatible with those for which the data was collected is not allowed.
5.3. Merging databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meet the stated processing purposes shall be processed.
5.6 The content and scope of the processed personal data must correspond to the stated processing purposes. Redundant processing of personal data in relation to the stated purposes is not allowed. When processing personal data, ensure the accuracy, sufficiency, and relevance of the data to the stated purposes of processing. The operator shall take the necessary measures to delete or clarify incomplete or inaccurate data, or ensure that these measures are taken.
5.7. Personal data is stored in a form that allows identification of the data subject for no longer than is required for the purposes of processing, unless a storage period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized once the processing purposes have been achieved or if the need to achieve these purposes is lost, unless otherwise provided for by federal law.
6. Purposes of personal data processing
The purpose of processing is to provide the user with access to the services, information, and/or materials contained on the website. Personal data: Surname, first name, patronymic, email address, and telephone numbers. Legal basis: Contracts concluded between the operator and the subject of personal data. Types of personal data processing: contacting users who have submitted a request through the website.

7. Conditions of personal data processing
7.1. Personal data processing shall only be carried out with the consent of the data subject.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law in order to fulfill the functions, powers, and duties imposed on the operator by Russian Federation legislation.
7.3. The processing of personal data is necessary for the administration of justice and the execution of judicial or other acts subject to enforcement in accordance with Russian Federation legislation on enforcement proceedings.
7.4. Processing of personal data is necessary for executing an agreement to which the data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the data subject's initiative or an agreement under which the data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties, or for achieving socially important purposes, provided that the rights and freedoms of the data subject are not violated.
7.6. The processing of personal data to which the data subject has granted access by an unlimited number of persons (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 processing of personal data
The Operator ensures the security of personal data by implementing the legal, organizational, and technical measures necessary for full compliance with current personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The user's personal data will never be transferred to third parties under any circumstances, except in cases related to the execution of current legislation or if the data subject has given consent to the operator to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3. If any inaccuracies in the personal data are detected, the user may update the data independently by sending a notice to the operator's email address, privacy@panchemicals.ru, with the remark "Personal Data Update."
8.4. The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another term is stipulated by the contract or applicable law. Users may withdraw their consent to the processing of their personal data at any time by sending a notice to the Operator via email at privacy@panchemicals.ru with the subject line "Withdrawal of Consent to Processing of Personal Data."
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by said parties (operators) in accordance with their user agreement and privacy policy. The personal data subject and/or said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions established by the data subject regarding the transfer (except granting access) or processing of personal data authorized for dissemination shall not apply to cases of processing personal data in state and public interests defined by Russian Federation legislation.
8.7. The Operator shall ensure the confidentiality of personal data when processing it.
8.8. The operator shall store personal data in a form that allows identification of the data subject for no longer than is required for the purposes of processing, unless a storage period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor.
The termination of personal data processing may be conditioned upon the achievement of the processing purposes, the expiration of the personal data subject's consent, the withdrawal of consent by the personal data subject, or a request to terminate processing, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update or change), extract, use, transfer (disseminate, provide access to, or make available), depersonalize, block, delete, or destroy personal data.
9.2. The Operator performs automated processing of personal data, whether or not information is received and/or transmitted via information and telecommunication networks.

10. Cross-border transfer of personal data
10.1. Prior to the commencement of a transborder transfer of personal data, the operator must notify the authorized body responsible for protecting the rights of data subjects of its intention to carry out such a transfer. This notification must be sent separately from the notification of the intention to process personal data.
10.2. Before submitting the above notification, the operator must obtain the relevant information from the foreign authorities, foreign natural persons, and foreign legal entities to whom the transborder transfer of personal data is planned.

11. Confidentiality of personal data
Operators and other individuals with access to personal data must not disclose or disseminate personal data to third parties without the consent of the data subject, unless otherwise stipulated by federal law.

12. Final Provisions
12.1. The user may request clarifications regarding the processing of their personal data by contacting the operator via email at privacy@panchemicals.ru.
12.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the policy is available online at https://panchem.ru/privacy.