Policy on personal data processing

1. general provisions
The present policy of processing of personal data is made according to requirements of the Federal law from 27.07.2006. No. 152-FZ "About personal data" (hereinafter referred to as - the Law about personal data) and determines an order of processing of personal data and measures on providing security of personal data, undertaken by ENICS LLC (hereinafter - the Operator).

1.1 The operator sets the most important objective and condition of realization of its activity to observance of rights and freedoms of man and citizen at processing of his personal data, including protection of rights to privacy, personal and family secrets.

1.2 This Operator's policy regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may receive about visitors to the website https://tdc-drillfluid.ru.
2. BASIC CONCEPTS USED IN THE POLICY
2.1 Automated processing of personal data means processing of personal data by means of computer equipment.

2.2 Blocking of personal data means temporary termination of processing of personal data (except for cases when processing is necessary for clarification of personal data).

2.3 Website means aggregate of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://tdc-drillfluid.ru network address.

2.4 Personal Data Information System means an aggregate of personal data contained in databases of personal data, and information technologies and technical means ensuring their processing.

2.5 Anonymisation of personal data - is an action, as a result of which it is impossible to determine, without using additional information, whether the personal data belongs to a certain User or another subject of personal data.

2.6 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 (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7 Operator - a state body, municipal authority, legal entity or individual, independently or jointly with other persons, arranging and (or) carrying out processing of personal data, as well as determining the purpose 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 particular or defined User of the website https://tdc-drillfluid.ru.

2.9. Personal data, authorized by the subject of personal data for distribution - personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, authorized for distribution).

2.10. User - any visitor to the https://tdc-drillfluid.ru website.

2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

2.12. Distribution of personal data - any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize an unlimited number of persons with personal data, including publication of personal data in the media, placement in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.

2.14. Destruction of personal data means any actions, as a result of which personal data is irretrievably destroyed with impossibility to further restore the content of personal data in the information system of personal data and (or) material media of personal data are destroyed.
3. BASIC RIGHTS AND OBLIGATIONS OF THE OPERATOR
3.1. the operator has the right to

- to obtain from the subject of personal data reliable information and/or documents containing personal data;

- In case the personal data subject withdraws consent to the processing of personal data, the operator shall be entitled to continue the processing of personal data without the consent of the personal data subject on the grounds specified in the Personal Data Law;

- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.



3.2 The operator shall:

- Provide the personal data subject, at his/her request, with information relating to the processing of his/her personal data;

- Organize personal data processing in the manner prescribed by applicable laws of the Russian Federation;

- respond to requests and inquiries of personal data subjects and their legal representatives, in accordance with the requirements of the Personal Data Law

- Communicate to the authorized agency for protection of personal data subjects, on the request of such body, the necessary information within 30 days from the date of receipt of such request

- publish or otherwise ensure unrestricted access to this Policy on personal data processing

- To take legal, organizational and technical measures for protection of personal data against unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful acts in relation to personal data

- Cease transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided by the Personal Data Law

- Perform other duties provided by the Personal Data Law.
4. BASIC RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS
4.1 Personal data subjects shall have the right:

- To receive information relating to the processing of their personal data, except in cases provided for by federal laws. Information shall be provided to the personal data subject by the Operator in an accessible form, and shall not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

- to require the operator to clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights

- condition prior consent to the processing of personal data in order to promote products, works and services on the market

- to withdraw the consent to the processing of personal data

- To complain to the authorized body for protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of his personal data

- To exercise other rights provided by the legislation of the Russian Federation.



4.2 Personal data subjects shall

- Provide the Operator with reliable data about themselves;

- Inform the Operator of the specification (updating, modification) of their personal data.



4.3 Persons, who provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.
5. THE OPERATOR MAY PROCESS THE FOLLOWING PERSONAL DATA OF THE USER
5.1 Surname, first name, patronymic.

5.2 E-mail address.

5.3 Phone numbers.

5.4 The site also collects and processes impersonal visitor data (including cookies) using Internet statistical services (Yandex Metrika and Google Analytics, etc.).

5.5 The above-mentioned data hereinafter in the text of this Policy are combined with the general concept of Personal Data.

5.6 The Operator shall not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.

5.7 Processing of personal data, allowed for spreading, from special categories of personal data, specified in Part 1 of Article 10 of the Personal Data Law, is allowed, if the prohibitions and conditions, provided by Article 10.1 of the Personal Data Law, are observed.

5.8 The User's consent to the processing of personal data that is permitted for dissemination shall be executed separately from other consents to the processing of their personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. The requirements for the content of such consent shall be established by the competent authority for the protection of personal data subjects' rights.

5.8.1 The consent for processing of personal data allowed for dissemination shall be given by the User directly to the Operator.

5.8.2 The Operator shall, within three working days from the receipt of the above consent of the User, publish information about the conditions of processing, the existence of prohibitions and conditions for the processing of personal data allowed for distribution to an unlimited number of persons.

5.8.3 Transfer (distribution, provision, access) of personal data, authorized 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 must include the last name, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to which it is sent.

5.8.4 Consent to the processing of personal data permitted for dissemination shall cease upon receipt by the Operator of the request specified in clause 5.8.3 of this Policy with respect to the processing of personal data.
6. PRINCIPLES OF PERSONAL DATA PROCESSING
6.1 Processing of personal data shall be lawful and fair.

6.2 Processing of personal data shall be limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.

6.3 Databases containing personal data that are processed for purposes that are incompatible with each other shall not be merged.

6.4 Only personal data that meets the purposes for which it is being processed shall be processed.

6.5 The content and scope of processed personal data shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes. 6.6.

6.6 When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance in relation to the purpose of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that incomplete or inaccurate data is removed or clarified.

6.7 Personal data shall be stored in a form that allows identification of the personal data subject for no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, an agreement, a party to which, a beneficiary or a guarantor under which the personal data subject is a party. Processed personal data shall be destroyed or depersonalized upon attainment of processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided by the federal law.
7. PURPOSES OF PERSONAL DATA PROCESSING
7.1 Purpose of processing of the User's personal data:
- informing the User by sending e-mails;
- conclusion, execution and termination of civil law contracts;
- providing the User with access to the services, information and/or materials contained on the website https://tdc-drillfluid.ru.

7.2 Also the Operator has the right to send the User notifications about new products and services, special offers and different events. The User can always refuse receiving informative messages by sending an email to the Operator at info@drillingcom.com with the note "Refuse notifications about new products and services and special offers".

7.3 The User's impersonal data collected with the help of the Internet statistics services serves for collecting information about the Users' actions on the website, improving the quality of the website and its content.
8. LEGAL BASIS FOR PROCESSING OF PERSONAL DATA
8.1. The legal basis for the processing of personal data by the Operator shall be
- statutory (constituent) documents of the Operator;
- Contracts concluded between the Operator and the subject of personal data;
- Federal laws, other regulations in the sphere of personal data protection;
- The consent of the Users for the processing of their personal data, for the processing of personal data allowed for distribution.

8.2. The Operator shall process the User's personal data only if they are filled in and/or sent by the User himself via special forms located on the website https://tdc-drillfluid.ru or sent to the Operator by e-mail. By filling in the relevant forms and/or sending his personal data to the Operator the User expresses his consent to this Policy.

8.3. The Operator processes the impersonal data of the User if it is allowed in the settings of the User's browser (the saving of cookies and the use of JavaScript technology are enabled).

8.4 The subject of personal data independently decides to provide his personal data and gives his consent freely, willingly and in his own interest.
9. TERMS AND CONDITIONS OF PERSONAL DATA PROCESSING
9.1 Processing of personal data shall be subject to the consent of the personal data subject for processing of his/her personal data.

9.2 Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

9.3 Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4 Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which the personal data subject is a party, as well as for conclusion of an agreement on the initiative of the personal data subject or an agreement, under which the personal data subject will be a beneficiary or guarantor.

9.5 Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or to achieve socially important objectives, provided that the rights and freedoms of the personal data subject are not violated thereby.

9.6 Personal data shall be processed to which access is granted to an unlimited number of persons by or at the request of the personal data subject (hereinafter, "publicly available personal data").

9.7 Processing of personal data subject to publication or mandatory disclosure in accordance with the federal law.
10. PROCEDURE OF COLLECTION, STORAGE, TRANSFER AND OTHER PROCESSING OF PERSONAL DATA
Security of personal data processed by the Operator shall be ensured by implementing legal, organizational and technical measures required to meet in full the requirements of applicable laws in the field of personal data protection.

10.1 The Operator ensures safety of personal data and takes all possible measures that exclude access to personal data by unauthorised persons.

10.2 The personal data of the User shall never, under no circumstances be transferred to third parties, except in cases related to the execution of the applicable laws or if the personal data subject has given their consent to the Operator for the transfer of data to a third party for the performance of obligations under a civil law contract.

10.3 In case of identification of any inaccuracies in the personal data, the User may update the personal data on their own by sending a notice to the Operator's e-mail address info@drillingcom.com with the note "Updating of personal data".

10.4 The period of processing of personal data is determined by achieving the purposes for which the personal data was collected, unless a different period is provided by the contract or by applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending a notice via e-mail to the Operator's e-mail address info@drillingcom.com marked "Withdrawal of consent to the processing of personal data".

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 the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to get acquainted with the specified documents in due time. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.

10.6 The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or processing conditions (other than gaining access) of personal data permitted for distribution shall not apply in cases of processing of personal data in state, public and other public interests as defined by Russian legislation.

10.7. The Operator shall ensure the confidentiality of personal data when processing personal data.

10.8. The operator shall store personal data in a form that allows the identification of the personal data subject, for no longer than the purposes of personal data processing require it, unless the period of storage of personal data is established by federal law, a contract, a party to which, a beneficiary or a guarantor under which the subject of personal data is a beneficiary.

10.9 A condition for termination of personal data processing may be achievement of the personal data processing objectives, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as detection of unlawful personal data processing.
11. LIST OF ACTIONS PERFORMED BY THE OPERATOR WITH THE RECEIVED PERSONAL DATA
11.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (distribution, provision, access), anonymize, block, delete and destroy personal data.

11.2 The Operator carries out automated processing of personal data with or without receipt and/or transfer of received information via information and telecommunication networks.
12. CROSS-BORDER TRANSFER OF PERSONAL DATA
12.1 Before transborder transfer of personal data, the operator shall make sure that the foreign state, to the territory of which the transfer of personal data is supposed to be carried out, provides reliable protection of personal data subjects' rights.

12.2 The cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out if the personal data subject consents in writing to the cross-border transfer of his/her personal data and/or performance of an agreement to which the personal data subject is a party.
13. CONFIDENTIALITY OF PERSONAL DATA
The operator and other persons who obtained access to personal data shall not disclose or distribute personal data to third parties without consent of the subject of personal data, unless otherwise provided by federal law.
14. CONCLUDING PROVISIONS
14.1. The User may obtain any clarification of questions of interest regarding the processing of their personal data by contacting the Operator by email at info@drillingcom.com.

14.2 This document will reflect any changes in the personal data processing policy of the Operator. The Policy is 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://tdc-drillfluid.ru/privacy.