Personal Data Processing Policy

This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter, the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken by Photonica.Tech LLC (hereinafter, the “Operator”) to ensure the security of personal data.

1.1. The Operator’s paramount objective and condition for carrying out its activities is the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family secrecy.

1.2. This Operator’s policy on the processing of personal data (hereinafter, the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://photonica.tech.

2.1. Automated processing of personal data means the processing of personal data by means of computer technology.

2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except where processing is necessary to rectify the personal data).

2.3. Website means the aggregate of graphic and informational materials, as well as computer programs and databases, that make them available on the Internet at the network address https://photonica.tech.

2.4. Personal data information system means the aggregate of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data means actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belong to a specific User or other personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, erasure and destruction of personal data.

2.7. Operator means a state body, municipal body, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the scope of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data means any information relating, directly or indirectly, to an identified or identifiable User of the website https://photonica.tech.

2.9. Personal data authorized by the personal data subject for dissemination means personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized by the personal data subject for dissemination, in accordance with the procedure established by the Personal Data Law (hereinafter, “personal data authorized for dissemination”).

2.10. User means any visitor to the website https://photonica.tech.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the mass media, posting in information and telecommunication networks, or providing access to personal data in any other manner.

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

2.14. Destruction of personal data means any actions as a result of which personal data are irreversibly destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and/or as a result of which the tangible media containing personal data are destroyed.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, shall be liable in accordance with the legislation of the Russian Federation.

5.1. Personal data are processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

5.3. Combining databases containing personal data processed for mutually incompatible purposes is not permitted.

5.4. Only personal data that are relevant to the purposes of their processing are subject to processing.

5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The processed personal data must not be excessive in relation to the stated purposes of their processing.

5.6. When personal data are processed, their accuracy, sufficiency and, where necessary, relevance in relation to the purposes of processing are ensured. The Operator takes, or ensures the taking of, the necessary measures to delete or rectify incomplete or inaccurate data.

5.7. Personal data are stored in a form that permits identification of the personal data subject for no longer than is required by the purposes of processing, unless the storage period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized once the purposes of processing have been achieved or where it is no longer necessary to achieve those purposes, unless otherwise provided by federal law.

Purpose of processing

collection of service requests

Personal data

surname, first name, patronymic, email address, telephone numbers, documentation

Legal grounds

Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Protection of Information”

Types of personal data processing

Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data; sending informational emails to the email address

7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.

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

7.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act, or an act of another body or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, or 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 guarantor.

7.5. 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 significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data are processed to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter, “publicly available personal data”).

7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the applicable legislation on personal data protection.

8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.

8.3. If inaccuracies are found in the personal data, the User may update them independently by sending a notice to the Operator’s email address contact@photonica.tech marked “Updating of personal data”.

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

The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator by email to the Operator’s email address contact@photonica.tech marked “Withdrawal of consent to the processing of personal data”.

8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User should review the said documents. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions established by the personal data subject on the transfer (other than the provision of access) and on the processing, or conditions of processing (other than obtaining access), of personal data authorized for dissemination do not apply in cases where personal data are processed in the state, public and other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that permits identification of the personal data subject for no longer than is required by the purposes of processing, unless the storage period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.

8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiry of the consent of the personal data subject, withdrawal of consent by the personal data subject or a request to cease the processing of personal data, or detection of unlawful processing of personal data.

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, erasure and destruction of personal data.

9.2. The Operator carries out automated processing of personal data, with or without receipt and/or transfer of the information obtained via information and telecommunication networks.

10.1. Before commencing cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is submitted separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the foreign public authorities, foreign individuals and foreign legal entities to which the cross-border transfer of personal data is planned.

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

12.1. The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator by email at contact@photonica.tech.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://photonica.tech/privacy-policy.