Privacy Policy

Policy regarding the processing of personal data

1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of
the Federal Law of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter referred to as the
Law on Personal Data) and determines the procedure for processing personal data and measures
to ensure the security of personal data taken by NPF Real-Storm LLC (hereinafter referred to as
the Operator).
1.1. The operator sets as its most important goal and condition for carrying out its activities the
observance of the rights and freedoms of man and citizen when processing his personal data,
including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as
the Policy) applies to all information that the Operator can receive about visitors to the website
https://realstorm.ru
2. Basic concepts used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer
technology.
2.2. Blocking of personal data – temporary cessation of processing of personal data (except for
cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and information materials, as well as computer programs
and databases that ensure their availability on the Internet at the network address
https://realstorm.ru
2.4. Personal data information system is a set of personal data contained in databases and
information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine
without the use of additional information the ownership of personal data to a specific User or
other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed
using automation tools or without the use of such means with personal data, including collection,
recording, systematization, accumulation, storage, clarification (updating, changing), extraction,
use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction
of personal data.
2.7. Operator - a state body, municipal body, legal or natural person, independently or jointly
with other persons organizing and (or) carrying out the processing of personal data, as well as
determining the purposes of processing personal data, the composition of personal data to be
processed, actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identified User
of the website https://realstorm.ru
2.9. Personal data authorized by the subject of personal data for distribution - personal data,
access to an unlimited number of persons 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 the Law on Personal Data (hereinafter - personal data
authorized for distribution).
2.10. User – any visitor to the website https://realstorm.ru
2.11. Providing personal data – actions aimed at disclosing personal data to a certain person or a
certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an
indefinite number of persons (transfer of personal data) or familiarizing with personal data to an
unlimited number of persons, including the publication of personal data in the media, posting in
information and telecommunication networks or providing access to personal data in any other
way.
2.13. Cross-border transfer of personal data is the transfer of 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 personal data – any actions as a result of which personal data are destroyed
irrevocably with the impossibility of further restoration of the content of personal data in the
personal data information system and (or) the material media of personal data are destroyed.

3. Basic rights and obligations of the Operator
3.1. The operator has the right:
– receive from the subject of personal data reliable information and/or documents containing
personal data;
– if the subject of personal data withdraws consent to the processing of personal data, the
Operator has the right to continue processing personal data without the consent of the subject of
personal data if there are grounds specified in the Law on 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 Personal Data and
regulations adopted in accordance with it, unless otherwise provided by the Law on Personal
Data or other federal laws.
3.2. The operator is obliged:
– provide the subject of personal data, at his request, with information regarding the processing
of his personal data;
– organize the processing of personal data in the manner established by the current legislation of
the Russian Federation;
– respond to requests and inquiries from personal data subjects and their legal representatives in
accordance with the requirements of the Personal Data Law;
– report to the authorized body for the protection of the rights of personal data subjects, at the
request of this body, the necessary information within 30 days from the date of receipt of such a
request;
– publish or otherwise provide unrestricted access to this Policy regarding the processing of
personal data;
– take legal, organizational and technical measures to protect personal data from unauthorized or
accidental access, destruction, modification, blocking, copying, provision, distribution of
personal data, as well as from other unlawful actions in relation to personal data;
– stop transfer (distribution, provision, access) of personal data, stop processing and destroy
personal data in the manner and cases provided for by the Law on Personal Data;
– fulfill other duties provided for by the Personal Data Law.

4. Basic rights and obligations of personal data subjects
4.1. Subjects of personal data have the right:
– receive information regarding the processing of his personal data, except for cases provided for
by federal laws. The information is provided to the subject of personal data by the Operator in an
accessible form, and it should not contain personal data relating to other subjects of personal
data, except in cases where there are legal grounds for the disclosure of such personal data. The
list of information and the procedure for obtaining it is established by the Law on Personal Data;
– require the operator to clarify his personal data, block it or destroy it if the personal data is
incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of
processing, as well as take measures provided by law to protect their rights;
– put forward the condition of prior consent when processing personal data in order to promote
goods, works and services on the market;
– to withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in
court against unlawful actions or inaction of the Operator when processing his personal data;
– to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
– provide the Operator with reliable information about yourself;
– inform the Operator about clarification (updating, changing) of your personal data.
4.3. Persons who provided the Operator with false information about themselves or information
about another subject of personal data without the latter’s consent are liable in accordance with
the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User
5.1. Full Name.
5.2. Email address.
5.3. Phone numbers.
5.4. Photos, documents (PDF, word, excel)
5.5. The site also collects and processes anonymized data about visitors (including cookies)
using Internet statistics services (Yandex Metrica and Google Analytics and others).
5.6. The above data below in the text of the Policy are united by the general concept of Personal
Data.
5.7. The Processing of special categories of personal data relating to race, nationality, political
views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
5.8. Processing of personal data permitted for distribution from among the special categories of
personal data specified in Part 1 of Art. 10 of the Law on Personal Data is permitted if the
prohibitions and conditions provided for in Art. 10.1 of the Personal Data Law.
5.9. The User’s consent to the processing of personal data permitted for distribution is issued
separately from other consents to the processing of his personal data. In this case, the conditions
provided for, in particular, Art. 10.1 of the Personal Data Law. Requirements for the content of
such consent are established by the authorized body for the protection of the rights of personal
data subjects.
5.9.1 The User provides consent to the processing of personal data permitted for distribution
directly to the Operator.
5.9.2 The Operator is obliged, no later than three working days from the date of receipt of the
specified consent of the User, to publish information about the conditions of processing, the
existence of prohibitions and conditions for the processing of personal data permitted for
distribution by an unlimited number of persons.
5.9.3 The transfer (distribution, provision, access) of personal data authorized by the subject of
personal data for distribution must be stopped at any time at the request of the subject of personal
data. This requirement must include the last name, first name, patronymic (if any), contact
information (telephone number, email address or postal address) of the subject of personal data,
as well as a list of personal data whose processing is subject to termination. The personal data
specified in this requirement can only be processed by the Operator to whom it is sent.
5.9.4 Consent to the processing of personal data permitted for distribution terminates from the
moment the Operator receives the request specified in clause 5.9.3 of this Policy regarding the
processing of personal data.

6. Principles for processing personal data
6.1. The processing of personal data is carried out on a legal and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, pre-defined and
legitimate purposes. Processing of personal data that is incompatible with the purposes of
collecting personal data is not permitted.
6.3. It is not allowed to combine databases containing personal data, the processing of which is
carried out for purposes that are incompatible with each other.
6.4. Only personal data that meets the purposes of their processing are subject to processing.
6.5. The content and volume of personal data processed correspond to the stated purposes of
processing. Redundancy of the processed personal data in relation to the stated purposes of their
processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where
necessary, relevance in relation to the purposes of processing personal data are 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 storage of personal data is carried out in a form that makes it possible to identify the
subject of personal data, no longer than required by the purposes of processing personal data,
unless the period for storing personal data is established by federal law, an agreement to which
the subject of personal data is a party, beneficiary or guarantor. The processed personal data is
destroyed or anonymized upon achievement of the processing goals or in the event of the loss of
the need to achieve these goals, unless otherwise provided by federal law.

7. Purposes of processing personal data
7.1. Purpose of processing the User’s personal data:
– informing the User by sending emails;
– conclusion, execution and termination of civil contracts;
– providing the User with access to services, information and/or materials contained on the
website https://realstorm.ru
7.2. The Operator also has the right to send notifications to the User about new products and
services, special offers and various events. The User can always refuse to receive information
messages by sending the Operator an email to sales@realstorm.ru with the note “Refusal of
notifications about new products and services and special offers.”
7.3. Anonymized data of Users, collected using Internet statistics services, serves to collect
information about the actions of Users on the site, improve the quality of the site and its content.

8. Legal grounds for processing personal data
8.1. The legal grounds for the processing of personal data by the Operator are:
– list the regulations governing relations related to your activities, for example, if your activities
are related to information technology, in particular with the creation of websites, then here you
can indicate the Federal Law “On Information, Information Technologies and Information
Protection” dated July 27 .2006 N 149-FZ;
– statutory documents of the Operator;
– agreements concluded between the operator and the subject of personal data;
– federal laws, other regulations in the field of personal data protection;
– consent of Users to the processing of their personal data, to the processing of personal data
permitted for distribution.
8.2. The Operator processes the User’s personal data only if it is filled out and/or sent by the
User independently through special forms located on the website https://realstorm.ru or sent to
the Operator via email. By filling out the appropriate forms and/or sending his personal data to
the Operator, the User expresses his consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is allowed in the User's
browser settings (saving cookies and using JavaScript technology are enabled).
8.4. The subject of personal data independently decides to provide his personal data and gives
consent freely, of his own free will and in his own interest.

9. Conditions for processing personal data
9.1. The processing of personal data is carried out with the consent of the subject of personal
data to the processing of his personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an
international treaty of the Russian Federation or law, to implement the functions, powers and
responsibilities assigned by the legislation of the Russian Federation to the operator.
9.3. The processing of 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 personal data is necessary for the execution of an agreement to which the
subject of personal data is a party or beneficiary or guarantor, as well as for concluding an
agreement on the initiative of the subject of personal data or an agreement under which the
subject of personal data will be a beneficiary or guarantor.
9.5. The processing of 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 processing of personal data is carried out, access to an unlimited number of persons is
provided by the subject of personal data or at his request (hereinafter referred to as publicly
available personal data).
9.7. We process personal data that is subject to publication or mandatory disclosure in
accordance with federal law.

10. Procedure for collection, storage, transfer and other types of processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal,
organizational and technical measures necessary to fully comply with the requirements of current
legislation in the field of personal data protection.
10.1. The operator ensures the safety of personal data and takes all possible measures to prevent
access to personal data by unauthorized persons.
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 in the event that the
subject of personal data gives consent to the Operator to transfer data to a third party to fulfill
obligations under a civil law contract.
10.3. If inaccuracies in personal data are identified, the User can update them independently by
sending a notification to the Operator to the Operator's e-mail address sales@realstorm.ru with
the note “Updating personal data.”
10.4. The period for processing personal data is determined by the achievement of the purposes
for which the personal data were collected, unless a different period is provided for by the
contract or current legislation.
The User may at any time withdraw his consent to the processing of personal data by sending a
notification to the Operator via email to the Operator's email address sales@realstorm.ru with the
note “Withdrawal of consent to the processing of personal data.”
10.5. All information that is collected by third-party services, including payment systems,
communications and other service providers, is stored and processed by these persons
(Operators) in accordance with their User Agreement and Privacy Policy. The subject of
personal data and/or the User is obliged to independently familiarize himself with the specified
documents in a timely manner. The operator is not responsible for the actions of third parties,
including the service providers specified in this paragraph.
10.6. Prohibitions established by the subject of personal data on the transfer (except for
providing access), as well as on processing or conditions for processing (except for gaining
access) of personal data permitted for distribution, do not apply in cases of processing personal
data in state, public and other public interests determined by law RF.
10.7. When processing personal data, the operator ensures the confidentiality of personal data.
10.8. The operator stores personal data in a form that makes it possible to identify the subject of
personal data for no longer than required by the purposes of processing personal data, unless the
period for storing personal data is established by federal law, an agreement to which the subject
of personal data is a party, beneficiary or guarantor.
10.9. The condition for terminating the processing of personal data may be the achievement of
the purposes of processing personal data, 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 identification of
unlawful processing of personal data.
11. List of actions performed by the Operator with received personal data
11.1. The operator collects, records, systematizes, accumulates, stores, refines (updates,
changes), extracts, uses, transfers (distribute, provide, access), depersonalizes, blocks, deletes
and destroys personal data.
11.2. The operator carries out automated processing of personal data with or without receiving
and/or transmitting the received information via information and telecommunication networks.
12. Cross-border transfer of personal data
12.1. Before the start of cross-border transfer of personal data, the operator is obliged to ensure
that the foreign state into whose territory it is intended to transfer personal data provides reliable
protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the
above requirements can only be carried out if there is written consent of the subject of personal
data to the cross-border transfer of his personal data and/or execution of an agreement to which
the subject of personal data is a party.

13. Confidentiality of personal data
The operator and other persons who have access to personal data are obliged not to disclose to
third parties or distribute personal data without the consent of the subject of personal data, unless
otherwise provided by federal law.
14. Final provisions
14.1. The User can receive any clarification on issues of interest regarding the processing of his
personal data by contacting the Operator via email sales@realstorm.ru
14.2. This document will reflect any changes to the Operator’s personal data processing policy.
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://realstorm.ru/privacy

Contacts