Personal data processing policy is drawn up in accordance with the requirements of the Federal Law No. 152-FZ On Personal Data dated 27 July 2006. It regulates the personal data processing procedure and measures to ensure personal data protection at Ural Steel (hereinafter referred to as the Operator).
1. General Provisions
1.1. The Operator shall regard the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family confidentiality, as an overriding priority and prerequisite for carrying out its activities.
1.2. The Operator’s policy regarding personal data processing (hereinafter referred to as the Policy) shall apply to any and all information that the Operator may receive about Users visiting Ural Steel website.
2. Basic Terms and Concepts Used in the Policy
2.1. Automated personal data processing means personal data processing through computer technology.
2.2. Blocking of personal data means temporarily suspending personal data processing (unless such processing is required for personal data clarification).
2.3. Ural Steel website means a collection of graphic and informational content, as well as software and databases ensuring their availability on the Internet at uralsteel.com
2.4. Personal data information system means the aggregate of the personal data contained in the databases, together with the information technology and technical means for processing thereof.
2.5. Depersonalisation of personal data means actions resulting in the impossibility to determine whether the personal data belongs to a specific User or another personal data subject without the use of additional information.
2.6. Personal data processing means any action (operation) or a group of actions (operations) performed with personal data, with or without using automated means, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data.
2.7. Operator means Ural Steel, which either independently or jointly with other persons arranges and/or carries out personal data processing, as well as specifies processing purposes, scope and content of personal data to be processed, actions (operations) carried out in relation to personal data.
2.8. Personal data means any information relating directly or indirectly to a specific or identifiable User visiting the Ural Steel website.
2.9. User means any visitor to the Ural Steel website.
2.10. Personal data provision means the act of disclosing personal data to a certain person or a certain group of persons.
2.11. Personal data distribution means any actions aimed at disclosure of personal data to an unlimited number of unspecified persons (personal data transfer) or making personal data available to an unlimited number of unspecified persons, including disclosure of personal data in mass media, posting in information and telecommunication networks or providing access to personal data in any other way.
2.12. International data transfer means the transfer of personal data to another country or jurisdiction, foreign individual, or foreign legal entity.
2.13. Destruction of personal data means any action resulting in the permanent destruction of personal data with no possibility of further restoration of personal data content in the personal data information system and/or resulting in the destruction of material media bearing the personal data.
3. User’s Personal Data to Be Processed by Operator
3.1. Last name, first name, phone number, e-mail address.
3.2. Ural Steel website also collects and processes depersonalised visitor data (including cookies) through Internet statistical services (Yandex.Metrica, Google Analytics, New Relic, etc.).
3.3. Hereinafter in this Policy, the above data is collectively referred to as Personal Data.
4. Personal Data Processing Purposes
4.1. The purpose of processing the User’s personal data:
· registration/authorisation of the User at Ural Steel website;
· contacting the User, including by sending SMS notifications, enquiries and information, as well as processing enquiries and requests received from the User, including possible informative and ads newsletters;
· any other purposes, other activities within the limits of the Russian legislation, subject to the requirements of the Russian personal data legislation.
5. Legal Basis for Personal Data Processing
5.1. The Operator shall process the User’s personal data only if the User fills in and/or submits them themselves via the special forms located at Ural Steel website. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
5.3. Cookie Consent
5.3.1. By continuing to work on the Ural Steel website, I hereby provide my consent to Ural Steel (hereinafter referred to as the Operator), registered address: 10 Malaya Sukharevskaya sq, 8th floor, Moscow, 127051, OGRN 1196733017546, INN 6732185689, for automated and manual processing of my personal data (cookies, information about user interaction with Ural Steel website, information about the User’s equipment, browsing session date and time, including using metric programmes Yandex.Metrica, Google Analytics, New Relic, etc.) with the performance of following actions: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, depersonalisation, blocking, deletion, destruction, transfer (provision, access) to the Operator’s partners providing the service related to the specified metric programmes.Personal data is processed to inform the User by sending SMS notification or making a direct call to the manager, improving the operation of Ural Steel website, enhancing the Operator’s products and services, determining the User’s preferences, providing targeted information on the products and services of the Operator and the Operator’s partners.
5.3.2. This consent shall be valid from the moment it is provided and during the entire period of use of Ural Steel website.
5.3.3. I am informed of the need to stop using Ural Steel website or disable cookies in the browser settings in case I refuse to process my personal data by metric programmes.
5.4. Personal Data Processing Consent
By continuing to work on the Ural Steel website, acting on my own free will and for my own benefit, I hereby give my consent to Ural Steel (hereinafter the Operator), registered address: 10 Malaya Sukharevskaya sq, 8th floor, Moscow, 127051, OGRN 1196733017546, INN 6732185689, to process my personal data, including by contracting third parties with the right to process personal data, for the following purposes:
● registration/authorisation of the User at Ural Steel website;
● contacting the User, including by sending notifications, enquiries and information, as well as processing enquiries and requests received from the Customer, including possible informative and ads newsletters;
● any other purposes, other activities within the limits of the Russian legislation, subject to the requirements of the Russian personal data legislation.
Personal data that I give my consent to process includes the following items:
● full name;
● contact number;
My consent to the personal data processing applies to all methods of processing, including collection, systematisation, accumulation, storage, clarification (updating, modification), use, depersonalisation, blocking, destruction, performed with or without using automated means.
I hereby certify that the personal data I have provided belong to me personally. I acknowledge and confirm that I have carefully and fully read and understood all the provisions of Processing Policy and the terms of processing my personal data provided in the form on Ural Steel website contained therein.
I accept the terms of personal data processing without any reservations or limitations.
This consent shall be deemed effective from the moment I provide my personal data and shall be valid for an indefinite period of time until I withdraw my consent in accordance with the established procedure.
I acknowledge that this consent may be withdrawn at any time by submitting an application prepared in any form to the Operator.
6. Procedure for the Collection, Storage, Transfer, and Other Processing Methods of Personal Data
6.1. Protection of personal data processed by the Operator shall be ensured by implementing legal, organisational, and technical measures essential for the full implementation of the requirements of applicable legislation in the field of personal data protection.
6.2. The Operator shall ensure the personal data protection and shall take all possible measures to exclude access to personal data by unauthorised persons.
6.3. The User’s personal data will under no circumstances be disclosed to third parties, except in compliance with the applicable law.
6.4. Should any inaccuracies in the personal data be identified, the User may update the personal data themselves by sending a notification to the Operator’s email address email@example.com with subject “Updating of personal data”.
6.5. The period of personal data processing is deemed to be indefinite. The User may withdraw their consent to the personal data processing at any time by sending a notice to the Operator’s e-mail address firstname.lastname@example.org with subject “Withdrawal of consent to personal data processing”.
7. International Data Transfer
7.1. Prior to the international data transfer, the Operator shall ensure that the foreign country of personal data intended destination provides adequate protection of personal data subjects’ rights.
7.2. International data transfer to foreign countries which do not meet the aforementioned requirements may only be carried out if the personal data subject consents in writing to the said international data transfer and/or to the performance of the contract to which the personal data subject is a party.
8.1. Any changes to the Operator’s personal data processing policy will be incorporated herein. The policy shall be valid indefinitely unless replaced by a new revision.
8.2. An updated, freely available Policy revision can be found at https://uralsteel.com/politic/