Privacy Policy
Policy on the Processing of Personal Data
1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "SP Trade" (hereinafter referred to as the Operator).
1.1. The Operator's paramount objective and condition for conducting its activities is to uphold the rights and freedoms of individuals and citizens during the processing of their personal data, including the protection of rights to privacy, personal, and family confidentiality.
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://liyuenergy.ru.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary for the clarification of personal data).
2.3. Website — a collection of graphic and informational materials, as well as software for computers and databases, ensuring their availability on the internet at the network address https://liyuenergy.ru.
2.4. Personal data information system — a collection of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions that result in the impossibility of determining, without the use of additional information, the association of personal data with a specific User or other subject of personal data.
2.6. Personal data processing — any action (operation) or a set of actions (operations) performed using automation tools or without such tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state agency, municipal agency, legal entity, or individual that, independently or jointly with others, organizes and/or performs the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information related directly or indirectly to a specific or identifiable User of the website https://liyuenergy.ru.
2.9. Personal data allowed by the subject of personal data for dissemination — personal data to which an unlimited circle of persons is provided access by the subject of personal data through consent to the processing of personal data allowed by the subject for dissemination in accordance with the Personal Data Law (hereinafter — personal data allowed for dissemination).
2.10. User — any visitor to the website https://liyuenergy.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including making personal data public in the media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — the 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 that result in personal data being irreversibly destroyed with no possibility of further recovery of the personal data content in the personal data information system and/or the destruction of personal data carriers.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data or submits a request for the cessation of personal data processing, the Operator is entitled to continue processing personal data without the consent of the personal data subject if 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 stipulated by the Personal Data Law and 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 obligated to:
— provide the personal data subject, upon request, with information regarding 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 requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of personal data subjects, upon request of this body, the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Fundamental Rights and Obligations of Data Subjects
4.1. Subjects of personal data have the right to:
— receive information regarding the processing of their personal data, except in cases provided 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, 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;
— demand that the operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purposes, and also to take 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, as well as to submit a demand to stop the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in a legal manner against unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator regarding the clarification (updating, changing) 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 their consent, are liable in accordance with the legislation of the Russian Federation.
5. Legal Grounds for Processing Personal Data
5.1. The legal basis for processing personal data is the set of normative legal acts in execution and accordance with which the Operator processes personal data, including:
· The Constitution of the Russian Federation;
· The Civil Code of the Russian Federation;
5.2. The legal basis for the processing of personal data also includes:
· The Charter of the Operator;
· Agreements concluded between the Operator and personal data subjects;
· Consent of personal data subjects for processing their personal data.
Principles of Personal Data Processing
5.1. Processing of personal data is conducted on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, pre-defined, and lawful objectives. Processing of personal data that is incompatible with the purposes of data collection is not allowed.
5.3. The amalgamation of databases containing personal data processed for purposes incompatible with each other is not permissible.
5.4. Only personal data that meets the objectives of their processing is subject to processing.
5.5. The content and volume of processed personal data comply with the stated purposes of processing. Excessive personal data processing relative to the declared purposes of processing is not allowed.
5.6. Accuracy, sufficiency, and, in necessary cases, relevance of personal data with respect to processing purposes are ensured during personal data processing. The Operator takes necessary measures and/or ensures the adoption of measures to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the personal data subject no longer than the purposes of processing require unless the personal data storage period is established by federal law, by a contract to which the personal data subject is a party, a beneficiary, or a guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or in case the necessity to achieve these purposes is lost unless otherwise stipulated by federal law.
6. Objectives of Personal Data Processing
Purpose of processing — informing the User by sending emails
Personal Data
last name, first name, middle name
email address
contact phone number
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
Sending informational emails to the email address
Purpose of processing — Consultation on services provided to Company client representatives
Personal Data
last name, first name, middle name
email address
contact phone number
place of work
position held
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
7. Terms of Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, for the fulfillment of functions, powers, and duties imposed on the operator under the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court decision, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is either a party, a beneficiary, or a guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of rights and legitimate interests of the operator or third parties or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data is carried out when access to the personal data is provided by the personal data subject to an unlimited number of persons or at his request (hereinafter — publicly accessible personal data).
7.7. The processing of personal data is carried out when the data is 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 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 current legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized access to 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 if the data subject has provided consent to the Operator for transferring data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator's email address: sales@sptrd.ru with the subject line "Update of personal data".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected unless another period is specified by contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address: sales@sptrd.ru with the subject line "Withdrawal of consent for personal data processing".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. The prohibitions set by the personal data subject on transfer (except for granting access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, 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. The Operator ensures the confidentiality of personal data during the processing of personal data.
8.8. The Operator stores personal data in a form that allows for the identification of the personal data subject no longer than is required for the purposes of processing personal data, unless the period for storing personal data is established by federal law or a contract of which the subject is a party, beneficiary, or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject, or a requirement to stop processing personal data, as well as the identification of unlawful processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The operator performs automated processing of personal data with receiving and/or transferring of received information via information and telecommunication networks or without them.
9.3. The operator uses metric programs on the website for statistical and research purposes.
9.4. The methods of personal data destruction by the operator are:
· For paper-based personal data carriers – cutting, hydroprocessing, burning, mechanical destruction;
· For electronic media – erasing on a device that ensures guaranteed information destruction, physical destruction of disk chips, etc.
The destruction of personal data is confirmed by an act of destruction and unloading from the event log in the personal data information system. The act and unloading from the log are stored for three years from the date of personal data destruction.
10. Cross-border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the operator is required to notify the authorized body for the protection of personal data subjects' rights about their intention to conduct such a cross-border transfer of personal data (this notification is sent separately from the notification of intention to process personal data).
10.2. Prior to submitting the aforementioned notification, the operator must obtain the relevant information from foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Personal Data Confidentiality
The operator and other persons who have access to personal data are obliged not to disclose or distribute 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 can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email: sales@sptrd.ru.
12.2. This document will reflect any changes in the Operator's personal data processing policy. The policy remains in effect indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely accessible on the Internet at: https://liyuenergy.ru/policy.