Personal Data Processing Policy

1. General provisions

This policy sets out the procedure and conditions for processing personal data at Limited Liability Company “Pro-Print” (the Operator) and the measures taken to protect it. It is issued pursuant to Part 2 of Article 18.1 of Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the Personal Data Law) and applies to all personal data the Operator receives through pro-print.pro.

The policy is publicly available: a link to it is placed next to the request form and in the footer of every page.

2. Operator details

Limited Liability Company “Pro-Print”, INN 7805794800, KPP 780501001, OGRN 1227800087239. Registered address: office 209, 10A Oboronnaya St., Saint Petersburg, 198095, Russia. Phone: +7 994 412-97-44, email: pr0print@yandex.ru.

The person responsible for organizing personal data processing is the General Director, Nadezhda V. Voroshko.

3. Definitions

• —Personal data — any information relating directly or indirectly to an identified or identifiable individual (data subject).
• —Processing of personal data — any operation or set of operations performed on personal data, whether or not by automated means.
• —User — any person visiting pro-print.pro.
• —Cookie — a small piece of data a website stores in the user’s browser; for the purposes of this policy, browser local storage (localStorage) is treated as a cookie.

4. Legal grounds for processing

• —the data subject’s consent (Clause 1, Part 1, Article 6 of the Personal Data Law), given separately from other documents when submitting a request;
• —the need to conclude and perform a contract to which the data subject is a party (Clause 5, Part 1, Article 6 of the Personal Data Law);
• —the Civil Code of the Russian Federation, Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Protection of Information” and Federal Law No. 402-FZ of 6 December 2011 “On Accounting”.

5. Purposes, data subjects and data categories

The Operator processes only the data required for the stated purpose and does not collect excessive information.

• —Handling requests and contacting the person who submitted them: a call or email, cost calculation and a commercial offer. Data subjects: website users, including representatives of organizations. Data: name, company name, phone number, email address, order details from the optional form fields (volume and parameters, packaging machine model, artwork link, comment), and the IP address, date and time of submission and browser details — to evidence that consent was obtained.
• —Concluding and performing a contract where an agreement is reached. Data subjects: client representatives. Data: the data listed above and the data needed to execute the contract.
• —Ensuring the website works and is secure. Data subjects: website users. Data: IP address, date and time of the request, page address, browser and device details, and the choice made in the cookie notice.

The Operator does not process special categories of personal data or biometric data and makes no decisions producing legal effects for users based solely on automated processing. The website is intended for businesses and is not directed at persons under 18.

6. Processing procedure and conditions

• —Operations: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion and destruction.
• —Processing method: mixed, with and without automation, with transfer over the Internet.
• —Recording, systematization, accumulation, storage, clarification and retrieval of personal data of Russian citizens are carried out using databases located in the Russian Federation (Part 5, Article 18 of the Personal Data Law).
• —Personal data is not transferred across borders and is not made public.
• —The Operator entrusts processing (Part 3, Article 6 of the Personal Data Law) to TIMEWEB.CLOUD LLC (INN 7810945525; office 605, 7 Universitetskaya St., Innopolis, Republic of Tatarstan, 420500, Russia) for website hosting on servers in Russia, and to YANDEX LLC (INN 7736207543; 16 Lva Tolstogo St., Moscow, 119021, Russia) for the email service through which website requests reach the Operator. These parties are required to keep the data confidential and secure.
• —Data is disclosed to other parties only where required by Russian law, for example at the request of a court or competent public authorities.
• —The Operator and anyone given access to the data shall not disclose or distribute it without the data subject’s consent unless otherwise provided by federal law (Article 7 of the Personal Data Law).

7. Retention and destruction

• —Request data is processed until the purposes are achieved, but no longer than three years from the last contact if no contract has been concluded.
• —If a contract is concluded — for its term and the document retention periods required by Russian law.
• —Once the purposes are achieved, the period expires or consent is withdrawn, the Operator stops processing and destroys the data within 30 days unless otherwise provided by contract or federal law (Parts 4 and 5, Article 21 of the Personal Data Law). If destruction within this period is not possible, the Operator blocks the data and destroys it within six months (Part 6, Article 21).
• —Destruction is documented in accordance with Roskomnadzor Order No. 179 of 28 October 2022.

8. User rights

Users have the right to:

• —obtain information about the processing of their personal data (Article 14 of the Personal Data Law);
• —demand that their data be clarified, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose;
• —withdraw consent to processing at any time;
• —appeal the Operator’s actions or omissions to Roskomnadzor (the Russian data protection authority) or in court.

Requests and withdrawals of consent can be sent to pr0print@yandex.ru or by post to the Operator’s registered address. A request must contain information identifying the sender and confirming their dealings with the Operator, such as the date of the request and the phone number given in it (Part 3, Article 14). The Operator may ask for additional information to verify identity.

The Operator responds within 10 business days of receipt. This period may be extended by no more than 5 business days with a reasoned notice.

9. Data protection

The Operator takes the legal, organizational and technical measures required by Articles 18.1 and 19 of the Personal Data Law:

• —appoints a person responsible for organizing data processing and adopts internal policies on data processing and protection;
• —grants access to data only to employees who need it for their duties and informs them of the legal requirements;
• —transmits data from the website over an encrypted connection (HTTPS) and restricts access to email and servers with passwords;
• —assesses potential harm to data subjects in accordance with Roskomnadzor Order No. 178 of 27 October 2022 and carries out internal control;
• —notifies Roskomnadzor of any unlawful or accidental transfer of personal data within 24 hours, and of the results of the internal investigation within 72 hours (Part 3.1, Article 21 of the Personal Data Law).

10. Cookies

The website stores only strictly necessary data in the browser. Analytics and advertising cookies are not used; if introduced, they will only run with the user’s permission. The list and how to change your choice are in the cookies section of the legal information page.

Cookies and browser storage

11. Final provisions

The Operator may amend this policy. A new version takes effect once published on the website unless stated otherwise. The current version is always available on this page.

Questions about personal data processing: pr0print@yandex.ru or +7 994 412-97-44.