1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) and establishes the procedure for processing personal data and the measures taken by Lider-2004 LLC to ensure the security of personal data (hereinafter referred to as the Operator).

1.1.The Operator considers the protection of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and personal and family confidentiality, to be one of its highest priorities and an essential condition of its activities.
1.2.This Personal Data Processing Policy of the Operator (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website of Lider-2004 LLC.

2. Key Terms Used in this Policy

2.1. Automated processing of personal dataProcessing of personal data using computer technology.
2.2. Blocking of personal dataThe temporary suspension of personal data processing, except where processing is required to clarify or update the personal data.
2.3. WebsiteA collection of graphic and informational materials, computer software and databases that make such materials available on the Internet at the website address of Lider-2004 LLC.
2.4. Personal data information systemA collection of personal data contained in databases, together with the information technologies and technical means used to process such data.
2.5. Anonymization of personal dataActions that make it impossible to determine, without the use of additional information, whether personal data relates to a particular User or another personal data subject.
2.6. Processing of personal dataAny action or operation, or combination of actions or operations, performed on personal data with or without the use of automated means, including:
  • collection;
  • recording;
  • systematization;
  • accumulation;
  • storage;
  • clarification, including updating or amendment;
  • retrieval;
  • use;
  • transfer, including distribution, provision or granting access;
  • anonymization;
  • blocking;
  • deletion;
  • destruction.
2.7. OperatorA government authority, municipal authority, legal entity or individual that, independently or jointly with other persons, arranges and/or carries out the processing of personal data and determines:
  • the purposes of personal data processing;
  • the categories of personal data to be processed;
  • the actions or operations performed with personal data.
2.8. Personal dataAny information relating directly or indirectly to an identified or identifiable User of the website of Lider-2004 LLC.
2.9. Personal data authorized by the data subject for public distributionPersonal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized for distribution, in accordance with the procedure established by the Personal Data Law.
Such data is hereinafter referred to as personal data authorized for distribution.
2.10. UserAny visitor to the website of Lider-2004 LLC.
2.11. Provision of personal dataActions intended to disclose personal data to a specific person or a specific group of persons.
2.12. Distribution of personal dataAny actions intended to disclose personal data to an indefinite group of persons or to make personal data available to an unlimited number of persons, including:
  • publication in the mass media;
  • publication on information and telecommunications networks;
  • granting access to personal data by any other means.
2.13. Cross-border transfer of personal dataThe transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual or foreign legal entity.
2.14. Destruction of personal dataAny actions resulting in the permanent destruction of personal data, making it impossible to restore the contents of such personal data in a personal data information system, and/or resulting in the destruction of physical media containing personal data.

3. Principal Rights and Obligations of the Operator

3.1. The Operator has the right to:obtain accurate information and/or documents containing personal data from the personal data subject;
  • continue processing personal data without the consent of the personal data subject where grounds provided for by the Personal Data Law apply, including after the data subject has withdrawn consent or submitted a request to cease processing;
  • independently determine the composition and scope of measures necessary and sufficient to fulfil the obligations established by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.
  • 3.2. The Operator is required to:provide the personal data subject, upon request, with information relating to the processing of their personal data;
  • arrange the processing of personal data in accordance with the applicable 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;
  • provide the competent authority responsible for protecting the rights of personal data subjects with the necessary information within ten days of receiving a request from that authority;
  • publish this Policy or otherwise provide unrestricted access to it;
  • take legal, organizational and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, provision or distribution, as well as against other unlawful actions involving personal data;
  • discontinue the transfer, distribution, provision of or access to personal data, cease processing and destroy personal data in the manner and circumstances provided for by the Personal Data Law;
  • fulfil any other obligations established by the Personal Data Law.

4. Principal Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:obtain information relating to the processing of their personal data, except in cases provided for by federal law. The Operator must provide such information in an accessible form. It must not contain personal data relating to other data subjects unless there are lawful grounds for disclosing such information. The list of information to be provided and the procedure for obtaining it are established by the Personal Data Law;
  • require the Operator to clarify, block or destroy their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and to take other measures provided by law to protect their rights;
  • require prior consent before personal data is processed for the purpose of promoting goods, works or services;
  • withdraw consent to the processing of personal data or submit a request to cease the processing of personal data;
  • file a complaint with the competent authority responsible for protecting the rights of personal data subjects or bring legal proceedings against any unlawful act or omission by the Operator in connection with the processing of personal data;
  • exercise any other rights provided for by the legislation of the Russian Federation.
  • 4.2. Personal data subjects are required to:provide the Operator with accurate information about themselves;
  • notify the Operator of any clarification, update or change to their personal data.
4.3.Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that person’s consent, may be held liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1.Personal data shall be processed lawfully and fairly.
5.2.The processing of personal data shall be limited to specific, predetermined, and lawful purposes. Personal data shall not be processed in a manner incompatible with the purposes for which it was collected.
5.3.Databases containing personal data processed for purposes that are incompatible with one another shall not be merged.
5.4.Only personal data relevant to the stated purposes of processing shall be processed.
5.5.The scope and content of the personal data processed shall correspond to the stated purposes of processing. Personal data shall not be excessive in relation to those purposes.
5.6.When processing personal data, the Operator shall ensure that the data is accurate, sufficient and, where necessary, kept up to date with regard to the purposes of processing. The Operator shall take all necessary measures, or ensure that such measures are taken, to delete or correct incomplete or inaccurate personal data.
5.7.Personal data shall be stored in a form that allows the identification of the data subject for no longer than is necessary to achieve the purposes of processing, unless a longer retention period is required by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.
Personal data shall be destroyed or anonymized once the purposes of processing have been achieved or are no longer required, unless otherwise provided by applicable law.

6. Purposes of Personal Data Processing

Purpose of ProcessingThe Operator processes personal data for the following purposes:
  • processing inquiries and requests submitted through the website (including requests for price lists, quotations, product samples, callback requests, and product selection);
  • preparing and providing commercial quotations and consultations;
  • entering into and performing supply agreements;
  • informing customers about products, prices, and commercial terms (where consent has been obtained);
  • improving the operation of the website and analyzing website traffic.
Categories of Personal DataThe following categories of personal data may be processed:
  • name;
  • telephone number.
Legal BasisProcessing is carried out in accordance with:
  • Federal Law No. 149-FZ dated July 27, 2006, "On Information, Information Technologies and Information Protection."
Processing ActivitiesThe Operator may perform the following processing activities:
  • collection;
  • recording;
  • systematization;
  • accumulation;
  • storage;
  • anonymization;
  • destruction of personal data.

7. Conditions for Personal Data Processing

7.1.Personal data shall be processed only with the consent of the personal data subject, except where otherwise permitted by applicable law.
7.2.Personal data may be processed where such processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or for the performance of functions, powers and duties assigned to the Operator under Russian legislation.
7.3.Personal data may be processed where necessary for the administration of justice or for the enforcement of a judicial act or any act of another authority or official subject to enforcement under the legislation of the Russian Federation.
7.4.Personal data may be processed where necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, or for entering into a contract at the initiative of the data subject.
7.5.Personal data may be processed where necessary to protect the legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that such processing does not infringe the rights and freedoms of the personal data subject.
7.6.The Operator may process personal data that has been made publicly available by the data subject or at the data subject's request.
7.7.The Operator may process personal data that is required by law to be published or otherwise disclosed.


8. Collection, Storage, Transfer and Other 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 comply fully with the applicable legislation governing personal data protection.
8.1.The Operator shall ensure the security of personal data and take all reasonable measures to prevent unauthorized persons from accessing personal data.
8.2.The User's personal data will never be disclosed to third parties except:
  • where required by applicable law; or
  • where the data subject has given consent for such transfer in connection with the performance of obligations under a civil law contract.
8.3.If inaccuracies in personal data are identified, the User may update their personal data by sending a notification to the Operator via email at lider-2004@mail.ru with the subject line "Personal Data Update."
8.4.Personal data shall be processed only for as long as necessary to achieve the purposes for which it was collected, unless a different retention period is required by law or by contract.
The User may withdraw consent to the processing of personal data at any time by sending a notification to lider-2004@mail.ru with the subject line "Withdrawal of Consent to Personal Data Processing."
8.5.Any information collected by third-party service providers, including payment systems, communication services and other service providers, shall be stored and processed by those providers in accordance with their own Terms of Service and Privacy Policies.
The Operator shall not be liable for the actions of such third parties.
8.6.Restrictions imposed by the personal data subject on the transfer, processing or other use of personal data authorized for public distribution shall not apply where processing is carried out in the public interest as provided by the legislation of the Russian Federation.
8.7.The Operator shall maintain the confidentiality of all personal data processed.
8.8.Personal data shall be retained only for as long as necessary to achieve the purposes of processing, unless a longer retention period is required by applicable law or by contract.
8.9.Processing of personal data shall cease upon:
  • achievement of the purposes of processing;
  • expiration of the consent period;
  • withdrawal of consent by the personal data subject;
  • receipt of a request from the data subject to cease processing;
  • identification of unlawful processing of personal data.

9. Personal Data Processing Activities

9.1.The Operator may perform the following processing activities with personal data:
  • collection;
  • recording;
  • systematization;
  • accumulation;
  • storage;
  • updating (amendment and correction);
  • retrieval;
  • use;
  • transfer (including disclosure, provision or granting of access);
  • anonymization;
  • blocking;
  • deletion;
  • destruction.
9.2.The Operator may process personal data using automated means, with or without the transmission of data through information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1.Before carrying out any cross-border transfer of personal data, the Operator shall notify the competent authority responsible for protecting the rights of personal data subjects of its intention to carry out such transfers. This notification shall be submitted separately from the notification regarding the Operator's intention to process personal data.
10.2.Prior to submitting such notification, the Operator shall obtain the necessary information from the competent authorities, foreign individuals, or foreign legal entities to whom the personal data is intended to be transferred, as required by applicable law.

11. Confidentiality of Personal Data

The Operator and any other persons granted access to personal data shall maintain the confidentiality of such data and shall not disclose or distribute it to third parties without the consent of the personal data subject, unless otherwise required or permitted by applicable law.

12. Final Provisions

12.1.Users may obtain clarification regarding any matters related to the processing of their personal data by contacting the Operator via email at lider-2004@mail.ru.
12.2.Any amendments to this Personal Data Processing Policy will be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.
12.3.The current version of this Policy is publicly available at:
https://lider-2004.ru/en-politica
Privacy Policy