Personal Data Processing Policy

Unless otherwise provided in the text of this Policy, the terms capitalized herein are used with the meanings defined in Article 1 of this Policy:

Company — Limited Liability Company “FLOW” (INN 5038179677 OGRN 1235000076365) using this Policy;

PD — personal data;

Policy — this document which defines the policy for processing PD;

Website — the Company’s website on the information and telecommunication network “Internet” at the address: https://flow.engineer/;

Destruction of PD — actions taken by the Company as a result of which it becomes impossible to restore the content of PD in the PD information system and/or as a result of which physical media containing PD are destroyed;

Federal Law — the Federal Law of the Russian Federation “On Personal Data” dated July 27, 2006, No. 152-FZ as amended.

 

This document defines the Company’s Policy regarding PD processing. This Policy has been prepared in accordance with clause 2, article 18.1 of the Federal Law.

The Company is registered in the Register of Operators Processing Personal Data in accordance with Order No. 54 dated February 22, 2017.

This Policy is developed and is in force in accordance with the current legislation of the Russian Federation regarding PD, regulatory documents of executive government authorities on issues of PD security, including when processed in PD information systems, and the Company’s local regulations.

This Policy applies to all processes of collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of PD, carried out using automation tools and without using such tools.

The processed PD may include: last name, first name, patronymic; year of birth; month of birth; date of birth; place of birth; registration address; photographic image; gender; identity document details (series and number, date of issue, name of issuing authority, and division code); citizenship; contact information (phone number and email).

The Policy is mandatory for familiarization and execution by employees involved in processing PD.

The Policy is subject to publication on the Website to provide unrestricted access to it.

If the Policy is amended, the current version shall be promptly published on the Website.

Principles of PD Processing

When processing PD, the Company adheres to the following principles:

• legality and fair basis;

• limitation of PD processing to achieve specific, predetermined, and lawful purposes;

• prohibition of combining databases containing PD processed for incompatible purposes;

• compliance of the content and volume of PD processed with the declared purposes of processing;

• prohibition of processing PD that is incompatible or excessive in relation to the declared purposes of processing;

• ensuring accuracy, sufficiency, and, if necessary, relevance of PD in relation to the stated purposes of processing;

• destruction or anonymization of PD once the purposes of processing are achieved or if it is no longer necessary to achieve such purposes, unless the retention period for PD is established by federal law or contract to which the PD subject is a party, beneficiary, or guarantor.

 

PD processing in the Company is permitted only if one of the following conditions is met:

• PD processing is carried out with the consent of the PD subject to the processing of his/her PD;

• PD processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, to exercise and fulfill the powers and duties imposed on the operator by the laws of the Russian Federation;

• PD processing is necessary for the administration of justice, execution of a judicial act, act of another body or official, to be executed under the legislation of the Russian Federation on enforcement proceedings;

• PD processing is necessary for the provision of state or municipal services as per the Federal Law No. 210-FZ “On the Organization of Provision of State and Municipal Services” dated July 27, 2010, to ensure the provision of such a service, to register the PD subject on the unified portal of state and municipal services;

• PD processing is necessary for the execution of a contract to which the PD subject is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the PD subject or a contract under which the PD subject will be a beneficiary or guarantor;

• PD processing is necessary to protect the life, health, or other vital interests of the PD subject if obtaining consent is not possible;

• PD processing is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant purposes, provided this does not violate the rights and freedoms of the PD subject;

• PD processing is carried out for statistical or other research purposes, subject to mandatory anonymization of PD. This excludes processing for promoting goods, works, or services on the market via direct contact with a potential consumer using means of communication, and for political campaigning;

• processing of PD that the PD subject has made publicly available or at the subject’s request (hereinafter referred to as publicly available PD);

• processing of PD subject to publication or mandatory disclosure as provided by Russian law.

PD processing requires the consent of the PD subject in the following cases (except when otherwise specified in the Federal Law):

• inclusion of the subject’s PD in publicly accessible PD sources;

• processing of special categories of PD related to race, ethnicity, political views, religious or philosophical beliefs, health, or intimate life;

• processing of biometric PD (information that characterizes physiological and biological features of a person, based on which his or her identity can be determined and is used by the operator to determine the identity of the PD subject);

• cross-border transmission of PD to foreign states that do not provide adequate protection for PD subjects’ rights;

• making decisions based solely on automated PD processing that cause legal consequences or otherwise affect the rights and legitimate interests of the PD subject.

Consent in the form of an electronic document signed according to federal law (including, but not limited to, a simple electronic signature) is equivalent to a written consent with a handwritten signature and may include consent given on the Website.

The Company may entrust PD processing to another party with the consent of the PD subject (unless otherwise provided by federal law), under a contract concluded with this party. The party processing PD on behalf of the Company must comply with the principles and rules provided by the Federal Law.

If the Company instructs another party to process PD, the Company remains responsible to the PD subject for such party’s actions. Such party is responsible to the Company.

The Company and other persons having access to PD must not disclose or distribute PD to third parties without the consent of the PD subject, unless otherwise provided by law.

Rights of PD Subjects

A PD subject may request the Company to clarify, block or delete his/her PD if the PD is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared processing purpose, as well as to take legal measures to protect his/her rights.

The PD subject has the right to request information regarding the processing of his/her PD, including:

• confirmation of the fact of PD processing by the Company;

• legal grounds and purposes of PD processing;

• purposes and methods used by the Company in PD processing;

• company name and location, information about persons (excluding the Company’s employees) who have access to PD or who may be disclosed PD under a contract or by law;

• processed PD relating to the relevant PD subject, source of their acquisition, unless another procedure is prescribed by law;

• terms of PD processing, including terms of their storage;

• procedure for the PD subject to exercise the rights provided by law;

• information on past or intended cross-border data transfers;

• surname, first name, patronymic and address of a person processing PD on behalf of the Company, if such processing is entrusted or will be entrusted to such a person;

• other information provided by law or other applicable legislation of the Russian Federation.

To obtain information according to paragraph 5.2, a PD subject may send a written request to the Company’s address listed in the Unified State Register of Legal Entities (also available online at https://egrul.nalog.ru/index.html) in accordance with articles 14, 20, 21 of the Federal Law. The request may also be sent as an electronic document signed by electronic signature to the following email address: sales@flowrus.ru

 

When processing PD, the Company implements necessary legal, organizational, and technical measures to protect PD from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions.

Ensuring PD security in particular involves:

• determining PD security threats when processed in PD information systems;

• organizational and technical measures to ensure PD security in PD information systems, as required for compliance with Russian Government-established levels of PD protection;

• using security tools subject to official conformity assessment procedures;

• evaluating the effectiveness of PD security measures before commissioning the PD information system;

• accounting for PD machine storage media;

• detection of unauthorized PD access situations and measures taken;

• restoration of PD modified or destroyed as a result of unauthorized access;

• establishing access rules for PD processed in the information system, and ensuring registration and recording of all PD actions in the system;

• monitoring PD security measures and the protection level of PD information systems.

Conditions for Termination of PD Processing

The Company terminates the processing of personal data in the following cases:

• upon occurrence of conditions for termination or expiry of established terms;

• upon achievement of processing purposes or loss of the need to achieve such purposes;

• upon the PD subject’s request if the Company’s PD are found to be incomplete, outdated, inaccurate, unlawfully obtained, or not required for the declared purpose;

• when unlawful PD processing is revealed and it is not possible to ensure lawful PD processing;

• upon withdrawal of consent by the PD subject or upon expiration of such consent (if processing is based solely on the PD subject’s consent);

• upon dissolution of the Company.

Upon occurrence of the above cases, PD is destroyed.

 

Limited Liability Company “FLOW”

INN: 5038179677

KPP: 503801001

OGRN: 1235000076365

Legal address: 141204, Moscow Region, Pushkino, Turgeneva str., 1, premise 2, room 3e

Postal address: 129226, Moscow, Dokukina str., 10 bld.26

Contact phone: +7(495) 799-85-58

Company website: https://flow.engineer/

All information in this catalog is published for informational purposes only, does not impose any obligations on our company, and does not constitute a civil law offer. The information in the catalog does not give rise to contractual relations regarding the products presented. For additional information on the terms of purchase, please contact our official dealers. The information and described products in this catalog may be changed or updated by “FLOW” at any time without prior notice. Unless officially stated otherwise, the content of the “FLOW” catalog does not contain any guarantees regarding properties or quality information of the products, for which “FLOW” may be liable.

This also applies to the relevance, accuracy, completeness, and quality of the information. “FLOW” assumes no liability concerning the contents of this catalog, except as expressly provided by law. “FLOW” accepts no responsibility for any direct or indirect damages and other negative consequences resulting from the use of this catalog. The obligations and responsibility of “FLOW” concerning the specified goods may be established exclusively by duly executed contracts and legislation.

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