1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 ‘On the Personal Data’ (hereinafter referred to as the Personal Data Law) and defines the procedures for processing the personal data as well as measures aimed at security of the personal data to be taken by OOO Polyarnaya Zvezda (hereinafter referred to as the Operator).
1.1. The Operator shall set the observance of the rights and freedoms of persons and citizens as its most important goal and condition for the implementation of its activities when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding the processing of the personal data (hereinafter referred to as the Policy) shall be applied to all information on visitors of https://polar-star.ru that the Operator may receive.

2. Main Concepts of the Policy
2.1. Automated processing of the Personal Data – processing of the Personal Data using computer technology.
2.2. Blocking of the Personal Data – temporary termination of processing of the Personal Data (except for cases when processing is necessary to clarify the Personal Data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://polar-star.ru.
2.4. the Personal Data information system — a set of the Personal Data contained in databases, and information technologies and technical means ensuring their processing.
2.5. Depersonalization of the Personal Data — actions resulting in impossibility to determine, without the use of additional information, the ownership of the Personal Data to a specific User or other Subject of Personal Data.
2.6. Personal Data processing – any action (operation) or a set of actions (operations) performed with the Personal Data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of the Personal Data.
2.7. Operator – a state body, a municipal body, a legal entity or an individual, which/who independently or jointly with other persons organizes and (or) carries out the processing of the Personal Data, as well as determines the purposes of processing the Personal Data, the composition of the Personal Data to be processed, actions (operations) to be performed with the Personal Data.
2.8. Personal Data – any information related directly or indirectly to a specific or identifiable User of the website https://polar-star.ru.
2.9. Personal Data authorized for distribution by the Subject of Personal Data - the Personal Data, access to which is granted to an unlimited number of persons by the Subject of Personal Data by giving consent to the processing of the Personal Data authorized for distribution by the Subject of Personal Data in accordance with the procedure provided for by the Law on the Personal Data (hereinafter - the Personal Data authorized for distribution).
2.10. User – any visitor of the website https://polar-star.ru.
2.11. Provision of the Personal Data – actions aimed at disclosing the Personal Data to a certain person or a certain circle of persons.
2.12. Distribution of the Personal Data – any actions aimed at disclosure of the Personal Data to an indefinite circle of persons (transfer of the Personal Data) or at familiarization with the Personal Data of an unlimited circle of persons, including the publication of the Personal Data in the mass media, placement in information and telecommunications networks or providing access to the Personal Data in any other way.
2.13. Cross-border transfer of the Personal Data – the transfer of the 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 the Personal Data – any actions as a result of which the Personal Data is permanently destroyed with the inability to further restore the content of the Personal Data in the Personal Data information system and (or) the material carriers of the Personal Data are destroyed.

3. Main Rights and Obligations of the Operator
3.1. The Operator shall have the right to:
- receive reliable information and / or documents containing the Personal Data from the Subject of Personal Data;
- if the Subject of Personal Data withdraws consent to the processing of the Personal Data, the Operator shall have the right to continue processing the Personal Data without the consent of the Subject of Personal Data, if there are grounds specified in the Law on the Personal Data;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on the Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on the Personal Data or other federal laws.
3.2. The Operator is obliged to:
- provide the Subject of Personal Data, at their request, with information concerning the processing of their Personal Data;
- organize the processing of the Personal Data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to requests and applications from Subjects of Personal Data and their legal representatives in accordance with the requirements of the Law on the Personal Data;
- inform the authorized body for the protection of the rights of Subjects of Personal Data at the request of this body of the necessary information within 30 days upon receipt of such;
- publish or otherwise provide unrestricted access to this Policy regarding the processing of the Personal Data;
- take legal, organizational and technical measures to protect the Personal Data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of the Personal Data, as well as from other illegal actions in relation to the Personal Data;
- stop the transfer (distribution, provision, access) of the Personal Data, stop processing and destroy the Personal Data in the manner and in the cases provided for by the Law on the Personal Data;
- perform other duties provided for by the Law on the Personal Data.

4. Main Rights and Obligations of Subjects of Personal Data
4.1. Subjects of Personal Data shall have the right to:
- receive information concerning the processing of their Personal Data, except in cases provided for by federal laws. The information shall be provided to the Subject of Personal Data by the Operator in an accessible form, and it shall not contain the Personal Data related to other the Personal Data subjects, except in cases where there are legal grounds for the disclosure of such the Personal Data. The list of information and the procedure for obtaining it is established by the Law on the Personal Data;
- require the Operator to clarify their Personal Data, block or destroy them if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- put forward the condition of prior consent when processing the Personal Data for the purpose of promoting goods, works and services on the market;
- revoke consent to the processing of the Personal Data;
- appeal to the authorized body for the protection of the rights of the Personal Data subjects or in court against illegal actions or inaction of the Operator when processing their Personal Data;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. The Subjects of Personal Data are obliged to:
- provide the Operator with reliable data about themselves;
- inform the Operator about the clarification (update, change) of their Personal Data.
4.3. Persons who have provided the Operator with false information on themselves or information on another Subject of Personal Data without the latter’s consent shall bear liability in accordance with the legislation of the Russian Federation.

5. The Operator may process the following the Personal Data of the User
5.1. Surname, given name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Also the website collects and processes anonymous data on visitors (including cookies) using Internet statistics (Yandex Metric and Google Analytics and others).
5.5. The above data are hereinafter referred to as the Personal Data.
5.6. The Operator shall not process special categories of the Personal Data related to race, nationality, political views, religious or philosophical beliefs, intimate life.
5.7. Processing of the Personal Data allowed for distribution from among the special categories of the Personal Data specified in Part 1 of Article 10 of the Law on the Personal Data is allowed if the prohibitions and conditions provided for in Article 10.1 of the Law on the Personal Data are observed.
5.8. The User’s consent to the processing of the Personal Data allowed for distribution is issued separately from other consents to the processing of their Personal Data. At the same time, the conditions provided for, in particular, by Article 10.1 of the Law on the Personal Data are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of the Personal Data subjects.
5.8.1 The User provides the Operator directly with the consent to processing of the Personal Data allowed for distribution.
5.8.2 The Operator is obliged to publish information on the processing conditions, on the presence of prohibitions and conditions for the processing of the Personal Data allowed for distribution by an unlimited number of persons within three business days upon receipt of the specified User’s consent.
5.8.3 The transfer (distribution, provision, access) of the Personal Data authorized for distribution by the Subject of Personal Data must be terminated at any time at the request of such the Personal Data subject. This requirement must include the surname, given name, patronymic (if any), contact information (phone number, email address or postal address) of the Subject of Personal Data, as well as a list of the Personal Data which processing is subject to termination. The Personal Data specified in this request can only be processed by the Operator – recipient of such.
5.8.4 The consent to the processing of the Personal Data allowed for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of the Personal Data.

6. Principles of Personal Data Processing
6.1. The processing of the Personal Data shall be carried out on a legal and fair basis.
6.2. The processing of the Personal Data shall be limited to the achievement of specific, predetermined and legitimate goals. Processing of the Personal Data that is incompatible with the purposes of collecting the Personal Data shall not be allowed.
6.3. It shall not be allowed to combine databases containing the Personal Data, the processing of which is carried out for purposes incompatible with each other.
6.4. Only the Personal Data that meet the purposes of their processing may be subject to processing.
6.5. The content and volume of the processed the Personal Data shall correspond to the stated purposes of processing. Redundancy of the processed the Personal Data in relation to the stated purposes of their processing shall not be allowed.
6.6. When processing the Personal Data, the accuracy of the Personal Data, their sufficiency, and, if necessary, relevance in relation to the purposes of the Personal Data processing shall be ensured. The Operator takes the necessary measures and / or ensures that they are taken to delete or clarify incomplete or inaccurate data.
6.7. the Personal Data shall be stored in a form that allows to determine the Subject of Personal Data no longer than the purposes of the Personal Data processing require, unless the period of the Personal Data storage is established by a federal law or an agreement to which the Subject of Personal Data is a party, beneficiary or guarantor. Upon achievement of the processing goals or if the need to achieve these goals is lost, the processed the Personal Data shall be destroyed or depersonalized, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing
7.1. The purpose of processing the User’s the Personal Data:
- informing the User about the Operator’s services, including by sending emails and calls to the Operator’s employees to the specified phone number.
7.2. The Operator shall also have the right to send notifications to the User about new products and services, special offers and various events. The user may always refuse to receive informational messages by sending an email to the Operator to info@polar-star.ru
7.3. Depersonalized User data collected using Internet statistics services shall be used to collect information on User actions on the website, improve the quality of the website and its content.

8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for processing the Personal Data by the Operator are as follows:
- Federal Law ‘On Information, Information Technologies and Information Protection’ No. 149-FZ of 27.07.2006;
- federal laws and other regulatory legal acts in the field of the Personal Data protection;
- Users’ consent to the processing of their Personal Data, to the processing of the Personal Data allowed for distribution.
8.2. The Operator processes the User’s the Personal Data only if they are filled in and / or sent by the User independently through special forms located on the website https://polar-star.ru or sent to the Operator via e-mail. By filling out the appropriate forms and / or sending their Personal Data to the Operator, the User agrees to this Policy.
8.3. The Operator processes depersonalized data on the User if this is allowed in the User’s browser settings (the storage of cookies and the use of JavaScript technology are enabled).
8.4. The Subject of Personal Data independently makes a decision on the provision of their Personal Data and gives consent freely, of their own will and in their own interest.

9. Terms and Conditions of Personal Data Processing
9.1. The processing of the Personal Data shall be carried out with the consent of the Subject of Personal Data to the processing of their Personal Data.
9.2. The processing of the Personal Data is necessary to achieve the goals stipulated by an international agreement of the Russian Federation or a law, to perform the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
9.3. The processing of the 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. The processing of the Personal Data is necessary for the execution of a contract to which the Subject of Personal Data is a party, a beneficiary or a guarantor, as well as for the conclusion of a contract on the initiative of the Subject of Personal Data or a contract under which the Subject of Personal Data will be a beneficiary or a guarantor.
9.5. The processing of the Personal Data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the Subject of Personal Data are not violated.
9.6. the Personal Data, access to which is granted to an unlimited number of persons by the Subject of Personal Data or at their request (hereinafter referred to as publicly available the Personal Data), shall also be processed.
9.7. the Personal Data subject to publication or mandatory disclosure in accordance with federal law shall also be processed.

10. The procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of the Personal Data processed by the Operator shall be ensured by implementing legal, organizational and engineering measures necessary to fully comply with the requirements of the current legislation in the field of the Personal Data protection.
10.1. The Operator shall ensure the safety of the Personal Data and take all possible measures in order to exclude access of unauthorized persons to the Personal Data.
10.2. The User’s Personal Data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the Subject of Personal Data has given the Operator’s consent to transfer their data to a third party in order to fulfill obligations under a civil contract.
10.3. In case of inaccuracies in the Personal Data, the User may update them independently by sending a notification to the Operator to the Operator’s email address info@polar-star.ru marked with «Актуализация персональных данных» (Personal Data Update).
10.4. The period of processing of the Personal Data shall be determined by the achievement of the purposes for which the Personal Data was collected, unless another period is provided for by the contract or the current legislation.
The User may withdraw their consent to the processing of the Personal Data at any time by sending a notification to the Operator via e-mail to the Operator’s e-mail address info@polar-star.ru marked with «Отзыв согласия на обработку персональных данных» (Withdrawal of consent to the Personal Data Processing).
10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, shall be stored and processed by such persons (Operators) in accordance with their
User Agreement and Privacy Policy. The Subject of Personal Data and / or the User are obliged to familiarize themselves with these documents in a timely manner. The Operator shall bear no liability for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the Subject of Personal Data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of the Personal Data allowed for distribution, shall not apply in cases of processing the Personal Data in the state, public and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator shall ensure the confidentiality of the Personal Data when processing the Personal Data.
10.8. The Operator shall store the Personal Data in a form that allows determining the Subject of Personal Data for no longer than the purposes of the Personal Data processing require, unless the period of the Personal Data storage is established by a federal law or an agreement to which the Subject of Personal Data is a party, beneficiary or guarantor.
10.9. The condition for the termination of the Personal Data processing may be the achievement of the purposes of the Personal Data processing, the expiration of the consent of the Subject of Personal Data or the withdrawal of consent by the Subject of Personal Data, as well as the detection of illegal processing of the Personal Data.

11. List of actions performed by the Operator with the received the Personal Data
11.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (distribution, provision, access), depersonalize, block, delete and destroy the Personal Data.
11.2. The Operator shall perform automated processing of the Personal Data with or without receiving and/or transmitting the received information via information and telecommunications networks.

12. Cross-border transfer of the Personal Data
12.1. Before the start of the cross-border transfer of the Personal Data, the operator is obliged to make sure that the foreign state to whose territory the transfer of the Personal Data is supposed to be carried out provides reliable protection of the rights of the Personal Data subjects.
12.2. The cross-border transfer of the Personal Data on the territory of foreign states that do not meet the above requirements may be carried out only if the Subject of Personal Data has written consent to the cross-border transfer of their Personal Data and/or the execution of the contract to which the Subject of Personal Data is a party.

13. Confidentiality of the Personal Data
The Operator and other persons who have obtained access to the Personal Data are obliged not to disclose or distribute the Personal Data to third parties without the consent of the Subject of Personal Data, unless otherwise provided by a federal law.

14. Final provisions
14.1. The User may receive any clarifications on issues of interest related to the processing of their Personal Data by contacting the Operator via e-mail info@polar-star.ru.
14.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy shall be valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://polar-star.ru/en.