Reference translation. This document is a courtesy translation of the Russian original. Legal force belongs to the Russian text at lazercomet.ru/privacy; in case of any discrepancy, the Russian version prevails. The relations described here are governed by the law of the Russian Federation.
1. General provisions
1.1. This Policy on the processing of personal data (the “Policy”) is drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (“Law No. 152-FZ”) and defines how Limited Liability Company “KOMETA” processes personal data and the measures it takes to keep them secure.
1.2. The personal data operator is Kometa LLC, PSRN 1255000011529, TIN 5047309273, KPP 504701001, registered address: 19 Kolkhoznaya Street, Dolgoprudny, Moscow Region, 141703, Russia (the “Operator”).
1.3. The Operator regards respect for human and civil rights and freedoms in the processing of personal data — including the right to privacy and to personal and family confidentiality — as a paramount objective of its activity.
1.4. This Policy applies to all information the Operator may obtain about visitors to lazercomet.ru (the “Website”), as well as in the course of performing contracts and other activities.
1.5. The Policy is published for open access on the internet in accordance with part 2 of Article 18.1 of Law No. 152-FZ.
2. Key definitions
2.1. Personal data — any information relating directly or indirectly to an identified or identifiable natural person (the data subject).
2.2. Processing of personal data — any action or set of actions performed on personal data with or without automated means, including collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer, depersonalisation, blocking, deletion and destruction.
2.3. User — a visitor to the Website who has submitted personal data through a form on the Website or otherwise.
2.4. Cookie — a small piece of data sent by the Website and stored on the User’s device. How cookies are used is set out in section 8 of this Policy.
3. Categories of data subjects and data processed
3.1. The Operator processes personal data of the following categories of subjects: visitors to the Website who have submitted an enquiry; representatives and employees of counterparties; users of the 3D studio account.
3.2. The Operator processes the following personal data, provided voluntarily by the User:
- surname and given name (or any other form of address supplied by the User);
- contact telephone number;
- email address;
- company name and job title — where supplied by the User;
- the contents of the message and any attached files (artwork, sketches, drawings, images) where these contain personal data.
3.3. The Operator also processes depersonalised data transmitted automatically by the User’s browser: IP address, browser and operating system details, date and time of the request, the address of the referring page, and web analytics data.
3.4. The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sex life) or biometric personal data.
3.5. The Operator does not process personal data of minors. By submitting data through the Website, the User confirms their legal capacity and that they are at least 18 years old.
4. Purposes and legal grounds
4.1. The Operator processes personal data solely for the following purposes:
- handling enquiries submitted through forms on the Website and preparing commercial proposals and cost estimates;
- concluding, performing and terminating manufacturing contracts and settling payments under them;
- informing the User about the progress of their order;
- registering and providing access to the 3D studio account, and restoring access;
- sending advertising and information messages — only where a separate consent has been given by the User;
- improving the Website and analysing visitor behaviour in depersonalised form;
- fulfilling obligations imposed on the Operator by the law of the Russian Federation.
4.2. The legal grounds for processing are:
- the consent of the data subject to the processing of their personal data (clause 1, part 1, Article 6 of Law No. 152-FZ);
- performance of a contract to which the data subject is a party or a beneficiary (clause 5, part 1, Article 6 of Law No. 152-FZ);
- performance of functions and duties imposed on the Operator by law (clause 2, part 1, Article 6 of Law No. 152-FZ);
- the Operator’s Articles of Association and the contracts it concludes.
4.3. Advertising and information about the Operator’s work and services is sent only with the User’s prior consent, in accordance with part 1 of Article 18 of Federal Law No. 38-FZ of 13 March 2006 “On Advertising”. That consent is given through a separate tick-box in the form and may be withdrawn at any time.
5. How processing is carried out
5.1. Personal data are processed with the subject’s consent and in the cases set out in Article 6 of Law No. 152-FZ. Consent is given by the User ticking the relevant box in a form on the Website and is specific, informed, conscious and unambiguous.
5.2. Processing is carried out both by automated means and without such means (mixed processing).
5.3. The Operator processes personal data within the Russian Federation using databases located in the Russian Federation, in accordance with part 5 of Article 18 of Law No. 152-FZ.
5.4. The Operator carries out no cross-border transfer of personal data.
5.5. The Operator takes no decisions producing legal effects for the data subject solely on the basis of automated processing of their personal data.
5.6. Personal data may be passed to third parties only to the extent necessary to achieve the purposes of processing: to telecom operators and the hosting provider that keep the Website running; to delivery services for shipping finished goods; to credit institutions for settlements; and to state authorities on the grounds and in the manner established by Russian law. Any such transfer is subject to the recipient observing confidentiality and the requirements of Law No. 152-FZ.
5.7. The Operator does not sell personal data and does not pass them to third parties for advertising purposes.
6. Retention periods
6.1. Personal data are processed until the purposes of processing are achieved or until the data subject withdraws consent.
6.2. Data obtained from Website forms that did not lead to a contract are kept for no longer than three years from the User’s last enquiry.
6.3. Data processed in connection with concluding and performing a contract are kept for the term of the contract and for five years after its termination — as required by accounting and archive legislation.
6.4. Once the purposes of processing are achieved, or the need to achieve them is lost, personal data are destroyed or depersonalised within thirty days, unless otherwise provided by law or by contract.
6.5. Destruction is evidenced by a destruction record drawn up in the manner set out in Roskomnadzor Order No. 179 of 28 October 2022.
7. Security measures
7.1. The Operator takes the legal, organisational and technical measures necessary to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision or dissemination, and from other unlawful acts, including:
- appointing a person responsible for organising the processing of personal data;
- issuing internal rules on the processing and protection of personal data and briefing staff on them;
- identifying security threats and applying protective measures under Russian Government Decree No. 1119 of 1 November 2012;
- limiting and logging the circle of persons with access to personal data;
- encrypting the transmission channel (HTTPS) when data are sent from Website forms;
- backing up data and controlling the integrity of media holding personal data.
7.2. The person responsible for organising the processing of personal data is the General Director of Kometa LLC.
8. Cookies and analytics
8.1. The Website uses cookies — small text files stored in the User’s browser. Cookies are used for the following purposes:
- strictly necessary — keeping the Website working, maintaining the signed-in session, protecting forms against automated requests and storing the User’s cookie choice. These are used on the basis of clause 5, part 1, Article 6 of Law No. 152-FZ and require no separate consent;
- analytics — collecting depersonalised visit statistics through Yandex Metrica (Yandex LLC). These are used only with the User’s consent.
8.1.1. The Contacts page embeds a map from Yandex Maps (Yandex LLC). Loading it may allow that service to set its own cookies and to obtain the User’s IP address. The map is not loaded automatically before consent to analytics cookies is given: a placeholder with the address and a manual load button is shown instead. By pressing “Show map”, the User consents to loading the third-party service.
8.2. On a first visit, the User is offered a choice of cookie mode: allow strictly necessary files only, or allow all files. The choice is stored for six months and can be changed at any time through the “Cookie settings” link at the bottom of any page.
8.3. The User may restrict or block cookies through their browser settings. If strictly necessary cookies are disabled, some Website functions may become unavailable.
8.4. The terms on which Yandex Metrica processes data are set by the documents of Yandex LLC published on that service’s website.
9. Rights of the data subject
9.1. The data subject has the right to:
- obtain the information about the processing of their personal data listed in part 7 of Article 14 of Law No. 152-FZ;
- require that their personal data be rectified, blocked or destroyed if the data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing;
- withdraw consent to the processing of personal data;
- opt out of advertising and information mailings;
- appeal against the Operator’s acts or omissions to the authority for the protection of data subjects’ rights (Roskomnadzor) or in court.
9.2. A request from a data subject must contain the information required by part 3 of Article 14 of Law No. 152-FZ: the number of the main identity document of the subject or their representative, its date of issue and issuing authority, information evidencing the subject’s relationship with the Operator, and the signature of the subject or their representative.
9.3. The Operator reviews the request and replies within ten business days of receiving it. That period may be extended by no more than five business days, with a reasoned notice sent to the subject.
9.4. A withdrawal of consent is sent to info@lazercomet.ru or by post to the Operator’s address. From the moment the withdrawal is received, the Operator stops processing and destroys the personal data within thirty days, except where processing is permitted without the subject’s consent.
10. Final provisions
10.1. The Operator may amend this Policy. A new version takes effect when it is published on the Website, unless the new version provides otherwise.
10.2. The current version of the Policy is permanently available at lazercomet.ru/privacy.
10.3. All relations arising in connection with the processing of personal data are governed by the law of the Russian Federation.
10.4. For any questions about the processing of personal data, the User may contact the Operator at info@lazercomet.ru, by phone at +7 (977) 454-99-97, or by post to: 19 Kolkhoznaya Street, Dolgoprudny, Moscow Region, 141703, Russia.