Personal Data Processing Policy

1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law dd. 27 July 2006 No. 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures ensuring security of personal data taken by ERA-GLONASS LLC (hereinafter referred to as the Operator).
1.1. The most important objective of the Operator is adherence to the rights and freedoms of a person and a citizen in the processing of their personal data including protection of private life, and personal and family privacy. The above is the prerequisite for the Operator’s business.
1.2. This Operator’s policy regarding the personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator can receive about the https://eraglonass-gmt.ru/website visitors.

2. Key Terms of the Policy
2.1. Automated personal data processing is processing of personal data with computer technology.
2.2. Blocking of personal data is a temporary suspension of the personal data processing (unless the processing is necessary to clarify personal data).
2.3. Website is a set of graphic and informational materials, as well as computer software and databases that ensure their availability on the Internet at the following network address: https://eraglonass-gmt.ru/.
2.4. Personal data information system is a set of personal data contained in the databases, and information technologies and technical means supporting their processing.
2.5. Depersonalization of personal data means actions that make it impossible to determine the ownership of personal data by a specific User or other subject of personal data without additional information.
2.6. Personal data processing means any action (operation) or a set of actions (operations) performed with or without automation tools containing personal data including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator is a state body, municipal body, legal entity or an individual, independently or jointly with other persons organizing and (or) carrying out personal data processing, as well as determining the purposes of personal data processing, composition of personal data to be processed, the actions (operations) performed with personal data.
2.8. Personal data is any information relating directly or indirectly to a specific or identifiable User of the following website: https://eraglonass-gmt.ru/.
2.9. Personal data permitted by the subject of personal data for dissemination is personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as the personal data allowed for dissemination).
2.10. User is any visitor of the https://eraglonass-gmt.ru/ website.
2.11. Personal data provision means the actions aimed at disclosing personal data to a certain person or a certain pool of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite pool of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons including disclosure of personal data in the 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 is the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions resulted in irretrievable destruction of personal data making it impossible to further restore the content of personal data in the personal data information system and (or) destruction of material carriers of personal data.

3. Main Rights and Obligations of the Operator
3.1 The Operator has the following rights:
– receive from the subject of personal data reliable information and/or documents containing personal data; - in the event that the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data; - independently determine the composition and list of measures necessary and sufficient to ensure fulfilment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator has the following obligations:
- provide the subject of personal data with information regarding the processing of their personal data against their request;
– organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation; – respond to the requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- report to the authorized body responsible for protection of the rights of personal data subjects against a request of such body the necessary information within 30 days from the date of receipt of such a request; – publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
- take legal, organizational and technical measures to protect personal data from any unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data; - stop the transfer (distribution, provision, access to) of personal data, stop processing personal data and destroy it in the manner and cases provided for by the Law on Personal Data ;
– perform other duties provided for by the Law on Personal Data.

4. Main Rights and Obligations of the Personal Data Subjects
4.1. Personal Data Subjects has the following rights:
- receive information regarding the processing of their personal data, except as otherwise provided by the federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data unless there are legal grounds for disclosing such personal data. The list of information and the procedure for its obtaining is established by the Law on Personal Data;
- personal data subjects have the right to request the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take legal measures provided by the legislation to protect their rights;
– put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market; – to withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of subjects of personal data or through the courts against illegal actions or inaction of the Operator when processing their personal data; – to exercise other rights provided for 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 about any clarifications (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter are liable in accordance with the legislation of the Russian Federation.

5. The Operator has the right to process the following personal data of a User
5.1. First, middle and last name.
5.2. Phone numbers
5.3 The website collects and processes anonymous data about its visitors (through, among other means, the “cookie” files), using Internet statistics services (Yandex Metrika, Google Analytics, and other).
5.4. The above data further in the text of the Policy are united by the general concept of Personal data.
5.5. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
5.6. It is allowed to process personal data that belong to the special categories of personal data and are permitted for distribution as specified in Cl.1 Art. 10 of the Law on Personal Data subject to the prohibitions and conditions provided for in Art. 10.1 of the Law on Personal Data.
5.7. The User’s consent to processing personal data permitted for dissemination shall be issued separately from any other consents on personal data processing. At the same time, the conditions provided for in Art. 10.1 of the Personal Data Law shall be met. Requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.7.1 The consent on processing of personal data permitted for distribution shall be provided by the User directly to the Operator.
5.7.2 The Operator is obliged to publish information on conditions of the processing, on existence of any prohibitions and conditions for the processing by an unlimited number of persons of the personal data permitted for dissemination no later than in three working days from the date of receipt of the specified consent of the User.
5.7.3 The transfer (distribution, provision, access to) of personal data permitted by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This request should include the last name, first name, patronymic (if any), contact details (telephone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. Only the Operator indicated as the receiving Operator of the personal data is allowed to process personal data specified in such request.
5.7.4 Consent to the processing of personal data permitted for dissemination terminates from the moment the Operator receives the request specified in clause 5.7.3 of this Policy regarding the processing of personal data.

6. Personal Data Processing Principles
6.1. The processing of personal data is carried out on legal and fair grounds.
6.2. The processing of personal data is limited to achievement of specific, predetermined and legitimate objectives. It is not allowed to process personal data that does not match the objectives of personal data collecting.
6.3. It is not allowed to unite databases containing personal data that are processed for the objectives that are incompatible with each other.
6.4. Only personal data that meet the objectives of their processing are subject to processing.
6.5. The content and scope of personal data subject to processing meets the declared processing objectives. No redundancy of the processed personal data in relation to the stated objectives of their processing is allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is ensured. The operator takes the necessary measures and/or ensures their adoption in order to delete or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows determining the subject of personal data no longer than it is required by the purposes of the personal data processing. If the period for storing personal data is not established by the federal law, such period shall be determined by an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achieving objectives of the processing or in case of loss of the need to achieve these objectives unless otherwise provided by the federal law.

7. Personal Data Processing Purposes
7.1. Purposes of User Personal Data Processing:
– conclusion, execution and termination of civil law contracts.
7.2. The Operator has the right to send notifications to the User about new products and services, special offers and various events. The User can at any time refuse to receive informational messages by sending an email to the Operator at info@eraglonass.ru with the "Refusal of notifications about new products and services and special offers" note.
7.3 Impersonal data of Users collected through Internet statistics are used to collect information about the actions of Users on the site, improve the quality of the site and its content.

8. Legal grounds for personal data processing
8.1. Legal grounds for the processing of personal data by the Operator are the following:
- list the legal acts governing the relations related to your activities, for example, if your activities are related to information technology, in particular the creation of websites, then you can indicate Federal Law “On Information, Information Technologies and Information Protection” dated July 27, 2006 N 149-FZ; – statutory documents of the Operator;
– agreements concluded between the Operator and the subject of personal data;
– federal laws and other regulatory legal acts in the field of personal data protection;
– Users' consent to the processing of their personal data, to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User’s personal data only if they are self-filled in and/or self-sent by the User through special forms located on the following website: https://eraglonass-gmt.ru/ or sent to the Operator by e-mail. By filling out the relevant forms and/or sending their personal data to the Operator, the Users express their consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (cookies and JavaScript technology).
8.4. The subject of personal data independently decides on the provision of their personal data and gives consent freely, of their own free will and in their own interest.

9. Personal Data Processing Conditions
9.1. The processing of personal data is carried out based on the consent of the subject of personal data to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the objectives provided for by the international treaty of the Russian Federation or the law in order to carry out the functions, powers and obligations assigned by the legislation of the Russian Federation to the Operator.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Personal data processing is required to execute a contract where the subject of personal data is a party, a beneficiary or a guarantor, and for the purposes of closing a contract initiated by the subject of personal data where such subject shall be a beneficiary or a guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Subject of the personal data provided consent for processing of personal data to unlimited number of persons or requested such processing (hereinafter referred to as publicly available personal data).
9.7. The personal data subjected to processing is published or disclosed in line with a Federal Law.

10. The procedure for collecting, storing, transferring and otherwise processing personal data
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 the current legislation in the field of personal data protection.
10.1. The Operator ensures security of personal data and takes all possible measures to prevent access of any unauthorized persons to personal data.
10.2. The User’s personal data will never, under no circumstances, be transferred to third parties, except for the cases related to implementation of the applicable legislation or cases when the subject of personal data has given consent to the Operator to transfer data to a third party to fulfil obligations under a civil law contract.
10.3. In case of detection of any inaccuracies in personal data, the User can update them by sending the Operator a notification to the Operator’s e-mail address: info@eraglonass.ru with the “Personal data update” note.
10.4. The term for personal data processing is determined by the fact of achieving the objectives for which the personal data were collected unless a different period is provided by the contract or applicable legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator by e-mail to the Operator’s email address: info@eraglonass.ru with the “Withdrawal of consent to the processing of personal data” note.
10.5. All information that is collected by third-party services including payment systems, means of communication and other service providers is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
10.6. The prohibitions established by the subject of personal data on transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for dissemination are inapplicable in cases of processing personal data in state, social and other public interests determined by legislation of the Russian Federation.
10.7. The Operator ensures confidentiality of personal data when processing it.
10.8. The Operator stores personal data in a form that allows to determine the subject of personal data for the period that is no longer than the period required to achieve the objectives of the personal data processing if the period for storing personal data is not established by the federal law or an agreement to which the subject of personal data is a party, beneficiary or guarantor.
10.9. The condition for terminating the personal data processing may be one of the following: achievement of the objectives of personal data processing; expiration of the consent of the subject of personal data or withdrawal of consent by the subject of personal data; identification of unlawful personal data processing.

11. List of actions performed by the Operator with the received personal data
11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (disseminates, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
11.2. The operator carries out automated processing of personal data with the receiving and/or transmitting of the received information via information and telecommunication networks or without it.

12. Cross-border transfer of personal data
12.1. Before commencing a cross-border personal data transfer, the Operator is obliged to make sure that the foreign state intended for such transfer of personal data provides reliable protection of the rights of the subjects of personal data.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of their personal data and/or execution of an agreement to which the subject of personal data is a party.

13. Confidentiality of personal data
The Operator and other entities who have gained access to personal data are obliged to avoid disclosing it to third parties and avoid distributing personal data without the consent of the subject of personal data unless otherwise provided by the federal law.

14. Final provisions
14.1. The User can receive any clarifications on the issues regarding processing of their personal data by contacting the Operator via the following e-mail: info@eraglonass.ru.
14.2. This document will reflect any changes in the policy of personal data processing by the Operator. The Policy is valid for an indefinite term until it is replaced by a new version.
14.3. Current version of the Policy is publicly available in the Internet at https://gogas.tech/
privacy-policy/