1. General provisions
This Policy determines the procedure for processing and protecting personal data of ESGC LLC (OGRN 1207700063130, INN 9709059593; address: 109004, Moscow, Nikoloyamskaya St., 40/22, building 4; email: info@s-martgroup.ru), hereinafter referred to as the “Operator”.
The policy applies to information received through s-martgroup.ru, email, telephone and instant messengers selected by the user. The operator is guided by the Constitution of the Russian Federation, Federal Law No. 152-FZ “On Personal Data” and other applicable acts.
2. Processing principles
The operator processes data lawfully, fairly and only for predetermined purposes; does not combine incompatible databases, limits the composition of data to the required volume, ensures accuracy and does not store data longer than required for the purpose or law.
3. Subjects, data and purposes
Name, phone number, email or messenger ID, organization and position - if reported, content of the request and correspondence. Purpose: response, call back, task assessment, proposal preparation and actions before concluding a contract.
Contact, identification, contractual and payment information to the extent necessary for the contract, legal verification, performance of obligations and protection of rights.
Name and selected contact. Purpose: news, invitations and offers - only on the basis of separate prior consent.
IP address, date and time of the request, browser, device, address of the requested page and technical logs - to the extent generated by the site infrastructure. Purpose: operation, security and diagnostics of the site.
4. Foundations and operations
The grounds are the consent of the subject, actions at his request before concluding the contract, execution of the contract, the Operator’s obligations under the law and legitimate interests, if they do not violate the rights of the subject. The operator can collect, record, systematize, accumulate, store, clarify, retrieve, use, transfer in appropriate cases, block, delete and destroy in an automated and non-automated way.
5. Transfer and assignment of processing
Employees and attracted suppliers receive access to the required extent: hosting and technical support, corporate mail, communications, CRM and professional consultants. Transfer to government agencies is carried out by law. When choosing WhatsApp or Telegram, the user independently initiates communication with the corresponding service; his data is also processed by the owner of the service according to his own rules.
Cross-border transfers, if they occur, are carried out only after compliance with the applicable requirements of Russian law. The operator does not sell personal data databases.
6. Deadlines and destruction
The communication is stored until the communication is completed and then for no longer than three years, unless a longer period is required by law, contract or protection of rights. Contractual documents are stored within the time limits established by law. Mailing contacts are processed until consent is withdrawn. Once the purpose is achieved or consent is withdrawn, the data is destroyed or anonymized unless there is another legal basis.
7. User rights
The User has the right to obtain information about the processing, demand clarification, blocking or destruction of data, withdraw consent and appeal the Operator’s actions to Roskomnadzor or the court. The request is sent to info@s-martgroup.ru with information that allows you to identify the applicant and the request. Opting out of advertising messages will be carried out without undue delay.
8. Data protection
The operator applies legal, organizational and technical measures commensurate with the risks: access control, media and system accounting, redundancy, channel and device protection, incident management, supplier control and employee training. No transmissions over the Internet can be guaranteed to be absolutely secure.
9. Cookies and analytics
The website uses strictly necessary technical data to deliver and protect pages. With the user's separate consent, Yandex Metrica (tag 47246979) may load and receive visit data, requested pages, referral source, device, browser and interactions with website elements, and may store analytical cookies and localStorage identifiers. The purpose is to measure traffic, diagnose issues and improve content and interface.
The analytics tag is not initialised until the user selects “Allow”. Refusal does not restrict access to the website. Session Replay is disabled in the website code. The service provider also processes the data under the Yandex Metrica terms.
10. Changes and contacts
The Operator updates the Policy when processes or laws change. The current edition is always available at this address. Questions about data: info@s-martgroup.ru; The Operator's postal address is specified in section 1.