Policy on personal data processing

1.General provisions

This policy of personal data processing is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure of personal data processing and measures to ensure personal data security taken by RTSoft-Project LLC (hereinafter - the Operator).

• The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.
• This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors of the rtsoft-energy.com

2 . Basic concepts used in the Policy

• Automated processing of personal data - processing of personal data by means of computer
• Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).
• Website - a set of graphic and informational materials, as well as computer programmes and databases, ensuring their availability on the Internet at the network address rtsoft-energy.com.
• Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their
• Personal data depersonalization - actions, as a result of which it is impossible to determine without using additional information whether personal data belong to a particular user or other subject of personal
• Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal

2.7. Operator - a state authority, municipal authority, legal entity or natural person, independently or jointly with other persons organizing and/or carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.

2.8 Personal data - any information relating directly or indirectly to a specific or identifiable user of the rtsoft-energy.com website.

• Personal data authorized by the personal data subject for dissemination - personal data, access to which is provided by the personal data subject to an unlimited number of persons by giving consent to the processing of personal data authorized by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data authorized fordissemination).
• User - any visitor of the rtsoft-energy.com website.
• Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
• Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number 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.
• Cross-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal
• Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or material carriers of personal data are

3.The Operator's basic rights and obligations

• The Operator shall have the right to:

• receive from the subject of personal data reliable information and/or documents containing personal data;
• in case the personal data subject withdraws consent to personal data processing, as well as submits a request to stop personal data processing, the Operator has the right to continue personal data processing 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 the fulfilment of the obligations stipulated 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
  • The Operator shall:
• provide the personal data subject, upon his/her request, with information regarding the processing of his/her personal data;
• organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• to inform the authorized authority for the protection of the rights of personal data subjects, upon request of this authority, of the necessary information within 10 days from the date of receipt of such 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 unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
• cease transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Personal Data Law;
• fulfil other obligations stipulated by the Personal Data Law.

4. Basic rights and obligations of personal data subjects

• The subject of personal data has the right to:

• receive information regarding the processing of his/her personal data, except in cases provided for by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining are established by the Law on Personal Data;
• demand from the Operator to clarify his/her personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his/her rights;
• impose a condition of prior consent when processing personal data for the purpose of marketing goods, works and services;
• to withdraw consent to the processing of personal data, as well as to send a request to stop processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of his/her personal data;
• to exercise other rights stipulated by the legislation of the Russian Federation.
  • The subject of personal data is obliged to:
• provide the Operator with true data about himself/herself;
• to inform the Operator about the clarification (update, change) of his/her personal data.
  • Persons who have passed to the Operator false information about themselves or information about another subject of personal data without the consent of the latter shall be held liable in accordance with the legislation of the Russian
  • The Operator shall:
    • Use the received personal data exclusively for the purposes specified in clause 6 of this Privacy
    • Ensure that personal data are kept confidential, not to disclose without prior written permission of the User, as well as not to sell, exchange, publish or disclose by other possible means the transferred personal data of the
    • Take precautionary measures to protect the confidentiality of the User's personal data in accordance with the procedure normally used to protect such information in the existing business
    • Delete personal data related to the respective User from the moment of application or request of the User or his/her legal representative or authorized body for protection of the rights of personal data

5.Principles of personal data processing

• The processing of personal data shall be carried out on a lawful and fair
• The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not
• It is not allowed to merge databases containing personal data processed for purposes incompatible with each
• Only personal data that fulfils the purposes for which it is processed shall be processed.
• The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not
• When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate
• The website rtsoft-energy.com protects the personal data of Users, which are automatically transferred in the process of viewing advertising blocks and when visiting pages on which the codeof statistical data collection Yandex Metrica, Bitrix 24 is installed:

• IP address;
• cookie information;
• information about your browser (or other programme that accesses the adverts);
• access time;
• address of the page where the ad unit is located;
• referrer (address of the previous page).

This information is used to identify and resolve technical problems and to monitor the legality of the use of website content. Any other personal information not specified above will be stored securely and not disclosed.

• In case of loss or disclosure of personal data, the Operator informs the User about the loss or disclosure of personal

5.9. When processing personal data, the Operator uses only Russian software products.

6.Purposes of personal data processing

Purpose of processing	Establishing feedback with the User, including sending notifications, requests regarding the use of the website rtsoft-energy.com, provision of services, processing requests and applications from the User; Providing counselling; Providing the User with effective customer and technical support in case of problems related to the use of the Operator's products and services; Providing the User with product and service updates, special offers, price information, newsletters and other information on behalf of the Operator; Promotion of the Operator's products and services.
Personal data	· Surname, first name, patronymic · Email address · Phone numbers
Legal grounds	Federal Law "On Information, Information Technologies and Information Protection" dated 27.07.2006 N 149-FZ

• Conditions of personal data processing

• The processing of personal data is carried out with the consent of the subject of personal data to the processing of his/her personal data. Consent to the processing of personal data may be given by the subject of personal data in any form that allows confirming the fact of obtaining consent, unless otherwise provided for by federal law: in writing, orally or in any other form provided by applicable law, including through the performance by the subject of personal data of exclusive
• The processing of personal data is necessary to achieve the purposes provided by the international treaty of the Russian Federation or by law, to fulfil the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.
• The processing of personal data is necessary for the fulfilment of a contract to which the personal data subject is a party or a beneficiary or 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
• The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially important goals, provided that the rights and freedoms of the personal data subject are not

8. Procedure for collection, storage, transfer and other types of personal dataprocessing

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary for full compliance with the requirements of theapplicable legislation in the field of personal data protection.

• The Operator shall ensure safety of personal data and take all possible measures to exclude access to personal data by unauthorized
• User's personal data will never, under no circumstances, be transferred to third parties, except for cases related to the execution of the applicable law or in case the subject of personal data has given his/her consent to the Operator to transfer the data to a third party for the fulfilment of obligations under a civil law
• In case of identifying inaccuracies in personal data, the user may update them independently by sending a notice to the Operator via the Operator's e-mail address ilek_ayu@rtsoft.ru with the note "Personal Data Update".
• The term of personal data processing is not limited, unless another term is stipulated by the contract or the applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address ilek_ayu@rtsoft.ru, labelled «Withdrawal of consent to the processing of personal data".
• All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons(Operators) in accordance with their user agreement and The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
• The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than access) of personal data authorized for dissemination shall not apply in cases of processing personal data in the state, public and other public interest as defined by the legislation of the Russian
• When processing personal data, the Operator shall ensure confidentiality of personal
• The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal

9.List of actions performed by the Operator with the received personal data

• The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (provide, access), depersonalize, block, delete and destroy personal data.
• The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Cross-border transfer of personal data

• Prior to commencement of transborder transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out transborder transfer of personal data (such notification shall be sent separately from thenotification of intention to carry out personal data processing).
• The Operator does not perform trans-border transfer of personal

11. Confidentiality of personal data

The operator and other persons who have obtained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final provisions

12.1. The User may obtain any clarifications on the issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail address  ilek_ayu@rtsoft.ru.

• This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
• The current version of the Policy is freely available on the Internet at https://www.rtsoft-energy.com/police/.