Privacy Policy

  1. General provisions
    1. The policy regarding the personal data processing  (hereinafter referred to as the Policy) is aimed at protecting the rights and freedoms of individuals, whose personal data are processed by Tula-Steel Trading House LLC (hereinafter the Operator).
    2. The policy is developed in accordance with paragraph 2 of Part 1 of Art. 18.1 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (hereinafter - the Federal Law “On Personal Data”).
    3. The Policy contains information to be disclosed in accordance with Part 1 of Art. 14 of the Federal Law "On Personal Data", and is a public document.
  2. Operator Information
    1. The Operator conducts its activities at the address: 2nd Verkhniy Mikhailovskiy proezd, 9
      115419, Moscow
  3. Information on the personal data processing 
    1. The Operator processes personal data in a lawful and fair manner to perform the functions, powers and duties entrusted by the law, exercise the rights and legitimate interests of the Operator, Operator’s employees and third parties.
    2. The Operator receives personal data directly from the subjects of personal data (hereinafter - PD).
    3. The Operator processes personal data in automated and non-automated ways, using computer technology and without the use of such tools.
    4. Actions for personal data processing include their collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.
  4. Personal data processing
    1. The Operator processes the personal data of customers within the framework of legal relations with the Operator, settled by Part Two of the Civil Code of the Russian Federation dated January 26, 1996 No. 14-FZ (hereinafter referred to as customers).
    2. The Operator processes the personal data of customers in order to comply with the laws of the Russian Federation, as well as to:
      • receive requests and applications from the subject of PD;
      • inform about new products, special promotions and offers;
      • conclude and execute the contract terms.
    3. The Operator processes the personal data of customers with their consent, provided by customers and / or their legal representatives by implicative actions on this Internet site, including, but not limited to, placing an order, registering a personal account, subscribing to a newsletter, in accordance with this Policy.
    4. The Operator processes the personal data of customers for no longer than the purpose of personal data processing requires, unless otherwise required by the legislation of the Russian Federation.
    5. The Operator can process the following customers' personal  data:
      • full Name;
      • address;
      • contact phone number;
      • e-mail address
    6. There is no processing of special personal data:
      • related to race, nationality;
      • political views, religious or philosophical opinions;
      • health and intimate life.
  5. Information on the security of personal data
    1. When processing personal data, the Operator takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unauthorized or accidental access to them, their destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions in relation to personal data.
    2. Measures to ensure the security of personal data during their processing, applied by the Operator, are planned and implemented in order to ensure compliance with the requirements set forth in Article 19 of the Federal Law FZ-152 “On Personal Data”.
    3. In accordance with Article 18.1 of FZ-152, the Operator independently determines the composition and list of measures necessary and sufficient to ensure compliance with the requirements of the law. The Operator in particular took the following measures:
      • appointment of responsible person for organization of PD processing;
      • development and introduction of local acts on PD processing, as well as local acts establishing procedures to prevent and detect violations of established procedures for PD processing and eliminate consequences of such violations;
      • application of legal, organizational and technical measures to ensure the PD safety in accordance with Article 19 of the Federal Law FZ-152;
      • internal control of the PD processing compliance with FZ-152 and regulatory legal acts adopted in accordance with this law, requirements for PD protection, Operator's policy regarding PD processing, the local acts of the Operator;
      • an assessment of the harmful consequences that may be caused to PD subjects in case of violation of the FZ-152, the ratio of the said harm and measures taken by Operator to ensure the fulfillment of obligations stipulated by FZ-152;
      • Operator’s employees who directly process PD are familiar with the provisions of Russian law on PD, including PD protection requirements, documents defining Operator’s policy regarding PD processing, local acts on PD processing;
      • In addition to the requirements of FZ-152 “On Personal Data”, the Operator takes a set of measures aimed at protecting information on the customers, employees and counterparties.
  6. Rights of personal data subjects
    1. The personal data subject has the right:
      • to obtain personal data relating to the subject, and information relating to their processing;
      • to clarify, block or destroy his personal data in case they are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
      • to withdraw his consent to the personal data processing;
      • to protect his rights and legitimate interests, including compensation for damages and  moral harm in court;
      • to appeal against the Operator's actions or inaction to the personal data protection authority or in court.
    2. To exercise their rights and legitimate interests, personal data subjects are entitled to contact the Operator, send a request in person or with the help of a representative. The request must contain the information specified in Part 3 of Art. 14 of the Federal Law "On Personal Data".