Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law dated July 27, 2006 No. 152-ÔÇ “On Personal Data” and determines the procedure for processing personal data and measures to ensure the security of personal data of Alumet LLC (hereinafter – the Operator).
The Operator sets the observance of human civil and political rights and freedoms in the personal data processing, including personal and family privacy, as the most important goal and condition for operation.
- This Operator policy regarding personal data processing (hereinafter referred to as the ‘Policy’) applies to all information that the Operator can receive about visitors to http://alumet.ru.
Main Concepts of Policy
- Automated personal data processing – processing of personal data using computer technology;
- Blocking of personal data – temporary suspension of personal data processing (unless the processing is
necessary to clarify personal data);
- Website – a set of graphic and information materials, as well as computer programs and databases,
ensuring their availability in the Internet at http://alumet.ru;
- Personal data information system – the sum of personal data contained in databases, as well as
information technologies and technical means ensuring personal data processing;
- Personal data anonymization – actions, which make it impossible to determine ownership of personal data
to a specific user or other personal data subject without the use of additional information;
- Personal data processing – any action (operation) or a set of actions (operations) performed using or
not using automation tools with personal data, including collection, recording, systematization,
accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution,
provision, access), anonymization, blocking, deletion, and destruction of personal data;
- Operator – a state or municipal body, legal or natural person, independently or jointly with other
persons organizing and (or) processing personal data, as well as determining the purposes of processing
personal data, the composition of personal data to be processed, and actions (operations) performed with
- Personal data – any information relating directly or indirectly to a specific or determined User of
- User – any visitor to http://alumet.ru;
- Provision of personal data – actions aimed at disclosing personal data to a specific person or a
certain circle of persons;
- Distribution of personal data – any actions aimed at disclosing personal data to an undefined circle of
persons (transfer of personal data) or familiarizing oneself with personal data of an unlimited circle
of persons, including disclosing personal data in the media, in information and telecommunication
networks or providing access to personal data in any other way;
- Cross-border transfer of personal data – personal data transfer to the territory of a foreign state, to
a foreign state authority, a foreign individual or a foreign legal entity;
- Destruction of personal data – any actions resulting in a permanent destruction of personal data with
the inability to further restore the content of personal data in the personal data information system
and (or) resulting in the destruction of material carriers of personal data.
The Operator may process the following User’s personal data:
- Full Name;
- E-mail address;
- Phone numbers;
- The site also collects and processes anonymous data about visitors (including cookies) using Internet
statistics services (Yandex Metric, Google Analytics and others).
- The above data are further incorporated in the text of the Policy by the general concept of Personal
4. Purposes of Personal Data Processing
- The purpose of User’s personal data processing is to inform the User by sending e-mails.
- 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 informational messages by
sending an e-mail to the Operator at email@example.com marked ‘Refusal to receive informational messages
about new products, services and special offers.’
- Anonymized data of Users collected through the Internet statistics services are used to collect
information about the actions of Users on the site, to improve the quality of the site and its content.
5. Legal Basis for Personal Data Processing
- The Operator processes the User’s personal data only if they are filled out and/or sent by the User
independently through special forms located at http://alumet.ru. By filling out the appropriate forms
and/or sending his or her personal data to the Operator, the User expresses consent to this Policy.
- The Operator processes anonymized data about the User if it is allowed in the settings of the User’s
6. Collection, Storage, Transfer and Other Types of Personal Data Processing
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 current legislation in the field of personal data protection.
- The Operator ensures safety of personal data and takes all possible measures to exclude access of
unauthorized persons to personal data.
- Under no circumstances will the User’s personal data be transferred to third parties, with the
exception of cases related to the implementation of applicable law.
- In case of inaccuracies in personal data, the User can update them independently by sending an e-mail
marked ‘Updating personal information’ to the Operator at the Operator’s email address firstname.lastname@example.org.
- The processing time for personal data is unlimited. The User can at any time withdraw his consent to
the personal data processing by sending an e-mail marked ‘Revocation of consent to personal data
processing’ to the Operator at the Operator’s e-mail address email@example.com.
7. Cross-border Transfer of Personal Data
- Before starting cross-border transfer of personal data, the Operator must make sure that the foreign
state where personal data is supposed to be transferred provides reliable protection of the rights of
personal data subjects.
- Cross-border transfer of personal data on the territory of foreign states that do not meet the above
requirements can be carried out only if there is a written consent of the personal data subject to the
cross-border transfer of his personal data and/or the execution of the contract to which the personal
data subject is a party.
8. Final Provisions
- The User can get any clarification on matters of interest regarding his personal data processing by
contacting the Operator via e-mail at firstname.lastname@example.org.
- This document will reflect any changes in the policy of personal data processing by the Operator. The
policy is valid indefinitely until it is replaced with a new version.
- The current version of the Policy is freely available on the Internet at