Personal Data Processing Policy
General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data," and defines the procedure for processing personal data and measures to ensure the security of personal data by Comtech Technologies LLC (hereinafter referred to as the "Operator").
1. The Operator considers the highest priority in its activities to be the observance of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal, and family secrets.
2. This Operator’s Policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://comtech.ru/en/.
Key Terms Used in the Policy
1. Automated Processing of Personal Data – processing of personal data using computer technology;
2. Blocking of Personal Data – temporary suspension of personal data processing (except where processing is necessary to clarify personal data);
3. Website – a collection of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the web address https://comtech.ru/en/;
4. Personal Data Information System – a set of personal data contained in databases and information technologies and technical means enabling their processing;
5. Depersonalization of Personal Data – actions that make it impossible to determine, without additional information, the ownership of personal data by a specific User or other subject of personal data;
6. Processing of Personal Data – any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data;
7. Operator – a state body, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or processes personal data, as well as determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed with personal data;
8. Personal Data – any information directly or indirectly related to an identified or identifiable User of the website https://comtech.ru/en/;
9. User – any visitor to the website https://comtech.ru/en/;
10. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or group of persons;
11. Dissemination of Personal Data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in mass media, posting in information and telecommunication networks, or providing access in any other way;
12. Cross-Border Transfer of Personal Data – the transfer of personal data to the territory of a foreign state, to a foreign authority, foreign individual, or foreign legal entity;
13. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the information system and/or resulting in the destruction of physical media containing personal data.
Personal Data Processed by the Operator
1. Full name;
2. Email address;
3. Phone numbers;
4. The website also collects and processes anonymized visitor data (including "cookies") using internet statistics services (Yandex Metrica, Google Analytics, and others).
5. The aforementioned data is collectively referred to as Personal Data in this Policy.
Purposes of Personal Data Processing
1. The purpose of processing the User’s personal data is to inform the User via email; to conclude, execute, and terminate civil contracts; to provide the User with access to services, information, and/or materials on the website; and to clarify details of inquiries.
2. The Operator may also send the User notifications about new products, services, special offers, and events. The User may opt out of such notifications by sending an email to info@comtech.ru with the subject line "Opt-out of notifications about new products, services, and special offers."
3. Anonymized User data collected via internet statistics services is used to gather information about User actions on the website, improve site quality, and enhance content.
Legal Basis for Personal Data Processing
1. The Operator processes the User’s personal data only if the User fills in and/or submits such data independently via special forms on https://comtech.ru/en/. By submitting their personal data, the User consents to this Policy.
2. The Operator processes anonymized User data if permitted by the User’s browser settings (enabling "cookies" and JavaScript).
Procedures for Collection, Storage, Transfer, and Other Processing of Personal Data
The security of processed personal data is ensured through legal, organizational, and technical measures necessary to fully comply with applicable data protection laws.
1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access.
2. The User’s personal data will never be disclosed to third parties, except as required by law.
3. If inaccuracies in personal data are identified, the User may update them by notifying the Operator via email at info@comtech.ru with the subject line "Update personal data."
4. The processing of personal data is unlimited. The User may withdraw consent at any time by sending an email to info@comtech.ru with the subject line "Withdrawal of consent to personal data processing."
Final Provisions
1. The User may request clarifications regarding personal data processing by contacting the Operator at info@comtech.ru.
2. This document will reflect any changes to the Operator’s Personal Data Processing Policy. The Policy remains in effect indefinitely until replaced by a new version.
3. The current version of the Policy is freely available at https://comtech.ru/en/.
