Personal data processing policy

1. General information
This personal data processing policy is made in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FL "On Personal Data" (hereinafter, the "Personal Data Law") and defines the personal data processing procedure and measures to ensure security of personal data taken by Okto Coal LLC (hereinafter, the "Operator ").
1.1. The Operator's most important purpose and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of rights to personal and family privacy.
1.2. This Operator's personal data processing policy (hereinafter the "Policy") applies to all information that the Operator may receive about visitors to the https://okto-coal.com website.
2. General terms used in the Policy
2.1. Automated processing of personal data means the processing of personal data by means of computer technology.
2.2. Blocking of personal data means a temporary interruption of the personal data processing (except if the processing is necessary to clarify the personal data).
2.3. A website means a combination of graphic and informational material, as well as computer programs and databases, making them available on the Internet at the network address https://okto-coal.com.
2.4. Personal data information system means a set of personal data contained in databases of personal data and information technologies and technical means ensuring its processing.
2.5. Depersonalization of personal data means actions as a result of which it is impossible to determine whether personal data belongs to a certain User or another subject of personal data without the use of additional information.
2.6. Personal data processing means any action (operation) or a set of actions (operations) performed with or without the use of automation means to process personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, utilization, transfer (dissemination, provision, access), depersonalization, blocking, deletion, erasure of personal data.
2.7. The Operator means a state body, municipal authority, legal entity or physical entity, independently or together with other persons arranging and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the https://okto-coal.com website.
2.9. Personal data permitted by the personal data subject for dissemination mean personal data, access to which is granted to an unlimited number of persons by the personal data subject by giving consent to personal data processing, permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for dissemination).
2.10. A User is any visitor to the https://okto-coal.com website.
2.11. Provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain group of persons.
2.12. Dissemination of personal data means any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited circle 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 personal data transfer means personal data transfer to the territory of a foreign state to a foreign state authority, a foreign physical entity or a foreign legal entity.
3. General rights and obligations of the Operator
3.1. The operator has the right:
- to obtain valid information and/or documents containing personal data from the subject of personal data;
- In case the personal data subject withdraws his/her consent to the processing of personal data, the Operator shall be entitled to continue the processing of personal data without the consent of the personal data subject if there is basis specified in the Personal Data Law;
- to independently determine the composition and list of measures, necessary and sufficient to ensure fulfillment of obligations provided by the Personal Data Law and regulatory legal acts approved in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The operator shall:
- provide information relating to the processing of his or her personal data to the personal data subject at his or her request;
- arrange the processing of personal data in accordance with the procedure established by the applicable laws of the Russian Federation;
- respond to requests and enquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authority responsible for the protection of the rights of subjects of personal data, at the request of this body, with the necessary information within 30 days after receipt of such request;
- publish or otherwise ensure unrestricted access to this Personal data processing policy;
- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful acts on personal data
- stop the transfer ( dissemination, provision, access) of personal data, stop processing and disseminate personal data in the manner and cases provided by the Personal Data Law;
- perform other responsibilities stipulated by the Personal Data Law.
4. General rights and obligations of personal data subjects
4.1. Personal data subjects have the right:
- to receive information relating to the processing of their personal data, with the exception of cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except in cases where there is legitimate basis for disclosing such personal data. The list of information and the procedure for obtaining it are set out in the Personal Data Law;
- to require the Operator to clarify its personal data, to block or erase them if the personal data is incomplete, obsolete, inaccurate, obtained illegally or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
- to condition prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw the consent to the processing of personal data;
- to complain to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the operator in the processing of her/his personal data
- to exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects shall
- provide the Operator with accurate data about themselves;
- inform the Operator of the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about other personal data subjects without their consent shall be held accountable in accordance with the laws of the Russian Federation.
5. The Operator may process the following personal data of the User:
5.1. Surname, name, patronymic.
5.2. E-mail address.
5.3. Telephone numbers.
5.4. The website also collects and processes anonymized visitor data (including cookies) using internet statistics services (Yandex Metrika and Google Analytics and others).
5.5. The above-mentioned data are hereinafter collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs or intimate life.
5.7. Processing of personal data, authorized for dissemination, of the special categories of personal data specified in Article 10.1 of the Personal Data Law shall be permitted if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are complied with.
5.8. The User's consent to the processing of personal data authorized for dissemination shall be executed separately from other consents to the processing of his/her personal data. The conditions stipulated, in particular, by Article 10.1 of the Personal Data Act shall be complied with. The requirements for the content of such consent shall be established by the authority responsible for the protection of personal data subjects' rights.
5.8.1 The User consents to the processing of personal data authorized for dissemination directly to the Operator.
5.8.2 The Operator shall, within three working days after the receipt of the above consent of the User, publish information about the conditions of processing, the existence of prohibitions and conditions on the processing of personal data permitted for dissemination by an unlimited number of persons.
5.8.3 Transfer (dissemination, provision, access) of personal data, authorized by the personal data subject for dissemination, shall be terminated at any time on the request of the personal data subject. This request shall include the surname, name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data processing of which is to be terminated. The personal data specified in this request may only be processed by the Operator to whom the request is sent.
5.8.4 The consent for the processing of personal data authorized for dissemination shall be terminated upon receipt by the Operator of the request referred to in clause 5.8.3 of this Policy for the processing of personal data.
6. Principles of personal data processing
6.1. Personal data shall be processed lawfully and fairly.
6.2. Processing of personal data shall be limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.
6.3. It shall not be permitted to combine databases containing personal data which are being processed for purposes incompatible with each other.
6.4. Processing shall only include personal data that is suitable for the purposes for which these data are processed.
6.5. The content and amount of personal data being processed shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.
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 shall be ensured. The operator shall take the necessary measures and/or ensure that such measures are taken to erase or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than the purpose of personal data processing requires, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor. Processed personal data shall be erased or depersonalized upon achievement of the processing objectives or if it is no longer necessary to achieve such objectives, unless otherwise stipulated by federal law.
7. Purposes of personal data processing
7.1. The purpose of processing the User's personal data:
- informing the User by sending e-mails;
- concluding, executing and terminating civil law contracts;
- providing the User with access to the services, information and/or materials contained on the https://okto-coal.com website.
7.2. The Operator is also entitled to send notifications about new products and services, special offers and various events to the User. The User can always decline receiving information messages by sending an email to the Operator at privacy@oktogroup.ru marked "Unsubscribe from notifications about new products and services and special offers".
7.3. The depersonalized User data collected via Internet statistical services are used to collect information about Users' activities on the website and to improve the quality of the website and its content.
8. Legal basis for processing personal data
8.1. The legal basis for the processing of personal data by the Operator shall be:
- contracts between the Operator and the subject of personal data;
- federal laws and other laws and regulations in the field of personal data protection;
- Users' consent to the processing of their personal data and to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User's personal data only in case the User fills them in and/or sends them by him/herself through the special forms on https://okto-coal.com website or sends them directly to the Operator by e-mail. By filling in the relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to this Policy.
8.3. The Operator processes depersonalized User data if this is permitted in the User's browser settings (cookie saving and the use of JavaScript technology are enabled).
8.4. The personal data subject shall independently decide whether to provide his/her personal data and shall give consent freely, of his/her own free will and in his/her own interest.
9. Conditions for the processing of personal data
9.1. Processing of personal data is performed with the consent of the personal data subject to the processing of his/her personal data.
9.2. Processing of personal data is necessary in order to achieve the purposes set out in an international agreement of the Russian Federation or by law, to perform the functions, powers and responsibilities imposed on the Operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another authority or an official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary in order to fulfil an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as to make 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 for the exercise of the rights and lawful interests of the Operator or third parties or for the achievement of socially important purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.
9.6. Processing of personal data to which access is granted to an unlimited number of persons by the subject of personal data or at his/her request (hereinafter "publicly accessible personal data") shall be carried out.
9.7. Processing of personal data to be published or disclosed in accordance with federal law shall be carried out.
10. Procedure for the collection, storage, transfer and other processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.
10.1. The Operator shall ensure the security of personal data and shall take all possible measures to exclude access to personal data by unauthorized persons.
10.2. The personal data of the User will never, under any circumstances, be disclosed to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party to fulfil obligations under a civil law contract.

10.3. If inaccuracies in the personal data are identified, the User may update the personal data on his/her own by sending a notification to the Operator's email address privacy@oktogroup.ru marked "Personal data update".
10.4. The period of processing of personal data is determined by achieving the purposes for which the personal data were collected, unless a different period is stipulated by the contract or applicable law.
The User may withdraw his/her consent to the processing of personal data at any time by sending a notification via e-mail to the Operator's e-mail address privacy@oktogroup.ru, marked "Withdrawal of consent to personal data processing".
10.5. All information collected by third party services, including payment systems, means of communication and other service providers, is stored and processed by designated persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to acquaint himself/herself with the documents mentioned above in due time. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
10.6 .The prohibitions on transfer (other than granting access) and on processing or conditions of processing (other than obtaining access) of personal data authorized for dissemination established by the personal data subject shall not be applicable in cases of processing of personal data in state, civil and other public interests as defined by the legislation of the Russian Federation.
10.7. The Operator shall ensure the confidentiality of personal data when processing personal data.
10.8. The Operator shall store personal data in a form enabling the identification of the personal data subject for no longer than the purposes of personal data processing require, unless the storage period of personal data is prescribed by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor.
10.9. A condition for the termination of personal data processing may be the achievement of the personal data processing purposes, expiry of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as the detection of unlawful personal data processing.
11. List of actions performed by the Operator with the personal data received
11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, utilization, transfer (dissemination, provision, access), depersonalization, blocking, deletion, erasure of personal data.
11.2. The Operator shall carry out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunication networks.
12. Cross-border personal data transfer
12.1. Before cross-border personal data transfer, the Operator shall verify that the foreign country to whose territory the transfer of personal data is to take place provides reliable protection of the rights of personal data subjects.
12.2. The cross-border personal data transfer to foreign countries that do not meet the above requirements may only take place if the personal data subject consents in writing to the cross-border transfer of his/her personal data and/or to the performance of the agreement to which the personal data subject is a party.
13. Confidentiality of personal data
The Operator and other persons granted access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise stipulated by federal law.

14. Final provisions
14.1. The User may obtain any clarification on questions of interest regarding the processing of their personal data by contacting the Operator by email at privacy@oktogroup.ru.
14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy shall be valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at the address https://okto-coal.com/privacy_policy.