Regarding the processing of personal data of Users of the website https://rosfritt.ru

1. GENERAL PROVISIONS AND INFORMATION ABOUT THE OPERATOR

1.1. This Privacy Policy (hereinafter referred to as the Policy) defines the procedure, conditions, and principles for processing personal data applied by JSC “KSTZ”, Legal address: 58 Zavodskaya Street, Kamensk-Shakhtinsky, Rostov Region, 347801, Taxpayer Identification Number (INN/KPP) 6147001847/614701001 (hereinafter referred to as the Operator).

1.2. This Policy applies to all visitors and users of the website https://rosfritt.ru, its subdomains, and landing pages (hereinafter referred to as the Website).

1.3. This Policy has been developed in strict compliance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as 152-FZ).

1.4. Consent to the processing of personal data is given by the User through an active action—by checking the box “I accept the terms of the Privacy Policy and consent to the processing of my personal data” in the appropriate form on the Website (order, subscription, or feedback forms). Tacit consent (including simple use or continued browsing of the Website) is not permitted. If the User disagrees with the terms of this Policy, they must immediately cease using the Website and refrain from completing any forms.

2. BASIC CONCEPTS
   2.1. Operator — JSC “KSTZ”, Legal address: 347801, Rostov Region, Kamensk-Shakhtinsky, Zavodskaya Street, Bldg. 58, Taxpayer Identification Number (INN/KPP) 6147001847/614701001, which processes the personal data of Users.
   2.2. User — any individual using the Operator’s Website.
   2.3. Personal data — any information relating to a directly or indirectly identified or identifiable individual (personal data subject).
   2.4. Cookies — small files stored on the User’s device to improve the performance of the Website.
3. PURPOSES, COMPOSITION, AND TERMS OF DATA PROCESSING

In accordance with the requirements of Article 5 and Article According to Federal Law No. 6 152-FZ, the processing of personal data is strictly limited to specific, predetermined purposes. Mixing different processing purposes is not permitted.

3.1. Objective #1: Processing incoming requests, inquiries, and providing consultations
-Category of subjects: Website visitors, potential clients.
-Data processed: Last name, first name, patronymic (if any); contact phone number; email address.
-Legal basis: User consent to the processing of their personal data, provided when filling out feedback forms (Article 6 of Federal Law 152-FZ).
-Processing and storage period: Until the goal is achieved (providing a full consultation at the User’s request) or until the User revokes consent.

3.2. Objective #2: Concluding sales/service contracts and processing orders
-Category of subjects: Clients (buyers) placing an order on the Website.
-Data processed: Full name; contact phone number; email; delivery address or address of the service facility; Website order history.
-Legal basis: Processing is necessary for the performance of an agreement to which the User is a party or beneficiary (Article 6 of Federal Law 152-FZ).
-Processing and storage period: during the term of the agreement, and after its execution – for 5 years (in accordance with the requirements of the Tax Code of the Russian Federation and the Law on Accounting for the storage of primary documentation).

3.3. Purpose No. 3: Sending newsletters, news, and special offers
-Category of subjects: Users who have expressed separate consent to receive marketing materials.
-Data processed: Name, email address.
-Legal basis: Separate, voluntary consent of the User to receive advertising and informational mailings (Article 15 of Federal Law 152-FZ, Article 18 of the Federal Law “On Advertising”).

• Processing and storage period: until the User revokes their consent (unsubscribes from the newsletter).

3.4. Purpose No. 4: Ensuring the technical functioning of the Website and collecting web analytics

• Category of subjects: All Website visitors.
• Data processed: IP address; browser and device information; cookies; browsing history and behavior data on the Website.
• Legal basis: User consent, provided by actively selecting the cookie banner in the interface. Technically necessary cookies are processed without consent. Analytical and marketing cookies are processed only after explicit consent.
• Processing and storage period: until the web analytics goals are achieved or until the User deletes cookies through their browser settings.

4. LEGAL BASIS FOR PROCESSING
   Personal data processing is carried out on a legal basis in accordance with Federal Law No. 152-FZ:

• The User’s consent to the processing of their personal data (Article 6 of Federal Law No. 152-FZ).
• Data processing is necessary for the performance of an agreement to which the User is a party (e.g., a purchase and sale agreement, an offer) (Article 6.2 of Federal Law No. 152-FZ).

4. PRINCIPLES AND CONDITIONS OF PROCESSING. DATA TRANSFER

5.1. Confidentiality: The Operator ensures the complete confidentiality of the data received. Data is not subject to disclosure or transfer to third parties without the prior consent of the User, except in cases expressly established by Russian legislation (requests from courts, law enforcement agencies, etc.).

5.2. Data Transfer for Order Fulfillment: To achieve Objective No. 2 (contract fulfillment), the Operator has the right to outsource data processing or transfer the minimum necessary amount of information to third parties (delivery services, transport companies, payment aggregators) solely to fulfill their obligations to the User. Such parties undertake to comply with the confidentiality requirements of Federal Law No. 152.

5.3. Database Localization: The collection, recording, systematization, accumulation, and storage of personal data of Russian citizens is carried out exclusively on servers physically located within the Russian Federation.

6. PERSONAL DATA PROTECTION MEASURES

The Operator takes necessary and sufficient organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, and distribution:

• Use of the secure HTTPS data transfer protocol (SSL/TLS encryption) on the Website. – Limiting the number of Operator employees with access to the Website’s databases and CRM system.
• Use of certified antivirus and software.

1. USER RIGHTS

In accordance with Federal Law No. 152, each User has the right to:

• Receive information about the processing of their personal data and access it.
• Request clarification, blocking, or destruction of their data if it is incomplete, outdated, inaccurate, or obtained illegally.
• Revoke consent to the processing of personal data.
• Appeal the Operator’s actions or inaction to the authorized body for the protection of the rights of personal data subjects.

1. DATA DESTRUCTION PROCEDURE AND TIME LIMITS
   8.1. Upon the occurrence of the conditions for termination of processing (achievement of the objective, withdrawal of consent, detection of unlawful processing), the Operator undertakes to cease processing and destroy personal data within 30 business days.

8.2. Personal data is destroyed from electronic databases using guaranteed erasure methods that preclude the possibility of subsequent recovery.

8.3. The Operator shall document the data destruction procedure in strict accordance with the requirements of Roskomnadzor Order No. 179 by drawing up a corresponding Personal Data Destruction Report.

9. CONSENT REVOCATION PROCEDURE
   9.1. The User may revoke their consent to the processing of personal data by sending a written request by email to: rosfritt@rosfritt.ru or by mail to the Operator’s registered address.

9.2. All suggestions, questions, or requests should be sent to the same email address.

9.3. The current version of the Policy is always available at: rosfritt.ru/privacy-policy.

10. POLICY CHANGES
    10.1. The Operator reserves the right to amend this Policy. The new version shall take effect from the moment it is posted on the Website, unless otherwise provided in the new version.

10.2. The User undertakes to independently monitor changes to the Policy.

11. OPERATOR DETAILS

JSC “KSTZ” Legal address: 347801, Rostov Region, Kamensk-Shakhtinsky, Zavodskaya Street, 58, Taxpayer Identification Number (INN)/KPP (Registration Code) 6147001847/614701001
Email for communication and feedback: rosfritt@rosfritt.ru
Phone: +7 (863) 657-27-01