Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter, the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure personal data security taken by ATOMEXPO LLC (hereinafter, the Operator).
1.1. The Operator considers 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, to be its primary goal and a condition of its activities.
1.2. This Operator’s Personal Data Processing Policy (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website https://spbth.ru/en.

2. Basic Concepts Used in the Policy
2.1. 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 where processing is necessary to clarify the personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the internet at the network address https://spbth.ru/en.
2.4. Personal data information system — the totality of personal data contained in databases, together with the information technologies and technical means that ensure its processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether the personal data belongs to a specific User or other data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, 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, and also determines the purposes of processing, the composition of the personal data to be processed, 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://spbth.ru/en.
2.9. Personal data permitted by the data subject for dissemination — personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data permitted by the data subject for dissemination, in the manner prescribed by the Personal Data Law (hereinafter, personal data permitted for dissemination).
2.10. User — any visitor to the website https://spbth.ru/en.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in the mass media, posting 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 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, making it impossible to restore the content of the personal data in the personal data information system, and/or the physical media of the personal data are destroyed.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the data subject accurate information and/or documents containing personal data;
— if the data subject withdraws consent to the processing of personal data or submits a request to stop processing, continue processing personal data without the data subject’s consent where there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the data subject, at their request, with information concerning the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to appeals and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of data subjects, at its request, with the necessary information within 10 days of receiving such a request;
— publish this Personal Data Processing Policy or otherwise ensure unrestricted access to it;
— take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions with respect to personal data;
— stop the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Data Subjects
4.1. 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 data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take the measures provided by law to protect their rights;
— set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data and submit a request to stop processing personal data;
— appeal to the authorized body for the protection of the rights of 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. Data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of any clarification (update, change) to their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or with information about another data subject without that person’s consent, bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. 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 its collection is not allowed.
5.3. Merging databases containing personal data that is processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessiveness of the personal data processed in relation to the stated purposes of processing is not allowed.
5.6. In the processing of personal data, its accuracy, sufficiency and, where necessary, relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. The personal data processed is destroyed or depersonalized upon achievement of the purposes of processing or when the need to achieve these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails
Personal data:

• surname, first name, patronymic
• email address
• phone numbers
• year, month, date and place of birth

Legal grounds:

• the Operator’s charter (constituent) documents
• contracts concluded between the Operator and the data subject

Types of personal data processing:

• Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
• Sending informational emails to an email address

7. Conditions for Processing Personal Data
7.1. Personal data is processed with the consent of the data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act or of an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. 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 data subject are not violated.
7.6. Personal data is processed to which an unlimited number of persons has been given access by the data subject or at their request (hereinafter, publicly available personal data).
7.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring and Other Types of Processing of Personal Data
The security of the personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation, or where the data subject has given the Operator consent to transfer the data to a third party in order to perform obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update it independently by sending a notice to the Operator’s email address mail@atomexpo.com marked “Updating personal data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by a contract or current legislation.
The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator by email at mail@atomexpo.com marked “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or [the text is incomplete in the original] with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions set by the data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than obtaining access), of personal data permitted for dissemination do not apply in cases of processing personal data in state, public and other public interests as defined by the legislation of the Russian Federation.
8.7. In the processing of personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.
8.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing, the expiry of the data subject’s consent, the withdrawal of consent by the data subject or a request to stop processing, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data
10.1. Before starting any cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of data subjects of its intention to carry out such a transfer (this notice is sent separately from the notice of intention to process personal data).
10.2. Before submitting the above notice, the Operator is obliged to obtain the relevant information from the foreign state authorities, foreign individuals and foreign legal entities to which cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain any clarification on questions concerning the processing of their personal data by contacting the Operator by email at mail@atomexpo.com.
12.2. This document will reflect any changes to 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 freely available on the internet at https://spbth.ru/en/privacy.