Our policy on privacy and the processing of personal data of Independent Energy LLC site users, version dating 30/12/2020

1. General Provisions

1.1. The following Policy for working with personal data of the website www.encmglobal.ru (hereinafter referred to as the “Policy”) was developed in accordance with the Federal Law of the Russian Federation No. 152-ФЗ dated July 27, 2006 “About Personal Data”, as well as other regulatory legal acts governing the activities of operators for the processing of personal data and applies to all personal data that can be obtained from the subject of personal data using the above mentioned site (hereinafter referred to as the Site).

1.2. The policy defines the procedure for processing personal data, the procedure and conditions for processing personal data of individuals who have transferred their personal data for processing, as well as measures and procedures to ensure the safety of personal data of users of the Site in order to protect the rights and freedoms of a person and citizen when processing their personal data.

1.3.   Use of the Site implies the unconditional consent of the User with this Policy and the conditions for receiving and processing of their personal data specified therein. In the case of disagreement with these conditions, the User must refrain from using the Site.

2.     Terms and accepted abbreviations

2.1.  Personal data – any information relating directly or indirectly to an identified or identifiable individual (subject of personal data) using the Site.

2.2.  Operator – Independent Energy LLC (TIN 9729274662).

2.3. Personal data subject (User) – a person who has access to the Site via the Internet and uses the information, materials and products of the Site.

2.4. Site – a set of interconnected web pages located on the Internet at a unique address: www.encmglobal.ru and/or its subdomains.

2.5. IP address – a unique network address of a node in a computer network through which the User gains access to the Site.

2.6. Cookies – a piece of data sent by a web server and stored on the user’s computer, which the web client or web browser sends to the web server (in an HTTP request) each time when trying to open the page of the corresponding site.

2.7. Service – a list of products and services sold by the Operator.

2.8. Personal data processing – any action (operation) or a set of actions (operations) performed with or without using automation tools with personal data, including receiving, recording, systematizing, accumulating, storing, clarifying (updating, changing), extracting, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.9. Automated processing of personal data – processing of personal data using computer technology.

2.10.       Blocking of personal data – a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).

2.11.       Destruction of personal data –actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which physical carriers of personal data are destroyed.

3.     Receiving and processing personal data

3.1. The operator receives personal data of personal data subjects:

3.1.1.      by their provision by the User (subject of personal data) when filling out registration forms on the Site, when submitting applications, requests, questionnaires, sending an e-mail message to the Operator;

3.1.2.      by way of automatic collection services of the Site (metric programs) in the process of their use by the User using the software installed on the User’s device, including the IP address, cookie data, information about the User’s browser (or other program with which the services are accessed ), the technical characteristics of the hardware and software used by the User, the date and time of access to the services, the addresses of the requested pages.

3.1.3.      in other ways that do not contradict the legislation of the Russian Federation on protection of personal data.

3.2. The Operator receives personal data directly from the User. The Operator does not verify the accuracy of the Personal Data provided by the User. Personal data is provided voluntarily.

3.3. The Operator receives and processes the User’s personal data from the moment the User’s consent is received in the form of a consent statement presented in Addendum 1 to this Policy. Consent is deemed to have been received from the starting  moment of using the Site, or by any implicit action of the User that would confirm his readiness to use the site.

3.4. The Operator protects the processed personal data from unauthorized access and disclosure, misuse or loss in accordance with the requirements of the Federal Law of The Russian Federation dated July 27, 2006 No. 152-ФЗ “About Personal Data”.

3.5. The Operator, with the consent of the User, with or without the use of automation tools, processes the User’s personal data.

3.6. Personal data that the Operator receives (can receive) from the User;

3.6.1.      First name and / or Last name and / or Middle name;

3.6.2.      Telephone number;

3.6.3.      E-mail address;

3.6.4.      Data that is automatically transmitted to the services of the Site in the course of their use through software installed on the User’s device, including the IP address, cookie data, information about the User’s browser (or other program through which the services are accessed), technical characteristics of the hardware and software used by the User, the date and time of access to the services, the addresses of the requested pages and other similar information.

3.7. The purpose of processing personal data is:

3.7.1.      identification of the party as part of the use of the of Site services;

3.7.2.      establishing feedback with the User, including sending notifications, notification requests regarding the use of the Site, services rendered, processing requests and applications from the User;

3.7.3.      evaluation and improvement of the quality of services rendered;

3.7.4.      marketing research;

3.7.5.      collection and analysis of statistical data.

3.8. The Operator is not entitled to transfer the User’s personal data to third parties without obtaining additional consent of the User, unless otherwise specifically provided by the legislation of the Russian Federation.

3.9. The processing of personal data is carried out on the territory of the Russian Federation, cross-border transfer of personal data is not carried out.

3.10.       The storage of personal data is carried out on electronic media in a manner that excludes unauthorized access to them.

3.11.       The destruction of personal data contained on electronic media is carried out by erasing. The medium is destroyed if necessary.

3.12.       The operator is not entitled to use personal data outside the purposes specified in this Policy.

3.13.       The processing of the User’s personal data is carried out without any time limit.

3.14.       The subject of personal data (User) has the right to withdraw his consent to the processing of personal data at any time by sending a message via the communication channels specified in this Policy. In this case, the Operator will stop the processing of personal data.

4.     Protection of personal data

4.1. In accordance with the requirements of regulatory documents, the Operator takes organizational, legal and technical measures to protect personal data.

4.2. The main measures of protection of personal data used by the Operator are:

4.2.1.      appointment of personnel responsible for  personal data  processing, who organizes the processing of personal data, training and instruction, internal control over compliance by his employees with the requirements for the protection of personal data.

4.2.2.      identification of threats to  personal data  security during processing, development of measures to protect personal Data.

4.2.3.      Establishing rules for access to processed personal data.

4.2.4.      setting individual passwords for employees’ access to the information system in accordance with their production responsibilities

4.2.5.      compliance with conditions ensuring the safety of personal data and excluding unauthorized access.

4.2.6.      training of employees directly involved in the processing of personal data, the provisions of the legislation of the Russian Federation on Personal data, including the requirements for the protection of personal data, documents defining the Operator’s policy regarding the processing of personal data, local acts on the processing of personal data.

4.2.7.      implementation of internal control and audit in the field of personal data protection.

5.     Other conditions

5.1. The operator has the right to make changes to this Policy without the consent of the User.

5.2. When making changes in the heading of the Policy, the date of the last revision is indicated. The new version of the Policy comes into effect from the moment it is posted on the Site, unless otherwise provided by the new version of the Policy.

5.3. Any suggestions or questions regarding this Privacy Policy should be directed to: @encmglobal.ru

5.4. The current version of the Privacy Policy is posted on the page at: www.encmglobal.ru/privacy

5.5. The law of the Russian Federation shall apply to this Policy and the relationship between the User and the Operator arising in connection with the application of the Policy.

Addendum 1

User consent form for the processing of personal data

Consent to the processing of personal data

I, the subject of personal data, in accordance with Russiam Federal Law No. 152 dated July 27, 2006 “About Personal Data”, give consent to Independent Energy LLC, TIN: 9729274662 (hereinafter referred to as the Operator) to process personal data transferred by me when using the website www.encmglobal.ruon the Internet, owned by the Operator.

The personal data of the subject of personal data means the information listed in the Policy on privacy and the processing of personal data of users of the site of Independent Energy LLC (hereinafter – the “Privacy policy”), including but not limited to: Last name and/or First name and/or Middle name, email address, phone number.

By Continuing to use this Site, I accept this Agreement and the Privacy Policy, I understand and give full consent that the processing of personal data may include the following actions: collection, systematization, accumulation, storage, clarification (update, change), use, transfer (provision, access), blocking, deletion, destruction, carried out both with the use of automation tools (automated processing) and without the use of such means (non-automated processing).

I confirm that I am not a resident of countries comprising the EU.

Consent is valid upon achievement of the processing goals or in case of the loss of need to achieve these goals, unless otherwise provided by Russian federal law.

Consent can be withdrawn by me at any time on the basis of my written statement.

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