Delta Computers Privacy and Website Users’ Personal Data Processing Policy

1. General provisions

This privacy and personal data processing policy has been drawn up in accordance with the requirements of Federal Law # 152-FZ of 27.07.2006 “On Personal Data” and defines the personal data processing procedure and measures to ensure the personal data safety taken by Delta Computers LLC (hereinafter referred to as the Operator). 

1.1. The Operator shall set the observance of human rights and freedoms in personal data processing, including the protection of the rights to privacy, personal and family secrets, as its essential goal and condition for the implementation of its activities.

1.2. This Operator's Personal Data Processing Policy (hereinafter referred to as the Policy) shall apply to all information the Operator can receive about visitors to the website

1.3. The personal data of Website Users shall be processed in compliance with the following principles:

  • Legitimacy;

  • Personal data processing limited by the achievement of specific, predetermined and legitimate goals;

  • Non-admission of any personal data processing incompatible with the purposes of personal data collection;

  • Non-admission of the integration of databases containing any personal data processed for any purposes incompatible with each other.

1.4. The use of the website by the User shall imply the acceptance of this Policy.

1.5. In case of disagreement with the terms and conditions of the Policy, the User shall abandon the use of the website

2. Basic concepts used in the Policy

2.1. Automated processing of personal data – computer-based processing of personal data;

2.2. Website – a set of graphic and information materials, as well as computer programs and databases ensuring their Internet availability at the web address;

2.3. Information system of personal data – a set of personal data contained in databases, as well as information technologies and technical means ensuring the processing thereof;

 2.4. Processing of personal data – any action (operation) or a set of actions (operations) performed with any personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, sharing, access), anonymization, blocking, deletion, destruction of personal data;

2.5. Operator - Delta Computers LLC (address: Office 22/10, room part 22, room IV, floor 3, 41A, 3-rd Parkovaya str., Moscow, Russian Federation 105425) – a legal entity that organizes and processes personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, as well as actions (operations) taken with personal data;

2.6. Personal data – any information related directly or indirectly to a specific or identifiable User of the website Such information may include full name, email, telephone number and any other information;

2.7. User – any user of the website;

2.8. Personal data sharing – actions aimed at disclosing personal data to a certain person or scope of persons;

2.9. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite scope of persons (transfer of personal data) or familiarizing with personal data of an unlimited scope of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other form;

2.10. Destruction of personal data – any actions resulting in the inevitable destruction of personal data without possible further restoration of the content thereof in the information system of personal data and (or) destruction of any material media bearing personal data;

2.11. Blocking of personal data – temporary suspension of the personal data processing (unless the processing is necessary to clarify personal data);

2.12. Anonymization of personal data – actions, as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or any other personal data subject.

2.13. Cookies – a small piece of data sent by a web server and stored on the user’s computer sent by the web client or web browser to the web server in an HTTP request each time it tries to open a page of the relevant site.

3. The Operator may process the following personal data of the User:

3. The Operator may process the following personal data of the User:

3.1. Full name;

3.2. Email;

3.3. Telephone numbers;

3.4. Information on your Internet activity, including information on the pages you visited and the time you spent on the page;

3.5. IP address and (if applicable) type of your device used to access the website and its unique identifier, any other information automatically transmitted by your browser;

3.6. Information on the interaction with Our Advertisements displayed outside the resource, their number, frequency and depth of web browsing;

3.7. The website also collects and processes anonymous data on users (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics, etc.).

3.8. The above data shall be hereinafter united by the common concept of Personal Data.

3.9. Any other personal information not stipulated above shall be subject to secure storage and non-distribution, except for cases related to the enforcement of the applicable law.

4. Purposes of personal data processing

4.1. The User’s personal data shall be processed for the following purposes:

- Setting User feedback, including sending notifications and requests regarding the use of the Website, the provision of services, processing the User requests and applications;

- Provision and improving the provision of services, developing individual offers for Website Users;

- Improvement in service;

- Statistical and other research;

- Advertising activities with the User’s consent.

4.2. Any anonymized User data collected via Internet statistics services shall be used to collect information on the Users’ activity on the website, improve the website quality and content, as well as collect marketing information.

5. Legal grounds for the processing of personal data

5.1. The Operator shall process the User’s personal data only if they are personally completed and/or sent by the User via special forms placed on the website By completing the relevant forms and/or sending the personal data to the Operator, the User expresses his/her consent to this Policy.

5.2. The Operator shall process anonymized User data if it is allowed in the User’s browser settings. Disabling cookies may deny access to the website.

6. The procedure for the collection, storage, transfer and other types of personal data processing

The safety of personal data processed by the Operator shall be ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the applicable personal data protection legislation.

6.1. The Operator shall ensure the safety of personal data and take all possible measures to prevent any unauthorized access thereto.

6.2. The User’s personal data shall never, under any circumstances, be transferred to any third parties, except for cases related to the enforcement of the applicable law. The User’s personal data may be transferred to competent public authorities of the Russian Federation only on the grounds and in the manner established by the RF legislation.

6.3. In case of any loss or disclosure of personal data, the Operator shall notify the User thereof.

6.4. Upon detection of any inaccuracies in personal data, the User can update them personally by emailing a notification to the Operator to marked “Personal data update”.

6.5. The term for personal data processing shall be unlimited. The User may at any time withdraw his/her consent to the processing of personal data by emailing a notification to the Operator to marked “Withdrawal of consent to personal data processing”.

7. Final provisions

7.1. The User can obtain clarifications on any issues of interest regarding the processing of his/her personal data by emailing to the Operator to or sending a relevant written request to the Operator’s address.

7.2. This Policy shall constitute the Company’s local regulatory document and be stored in paper form at the Company’s address by an officer in charge of personal data processing.

7.3. This Policy may be revised in any of the following cases:

  • In case of amending the personal data processing and protection legislation of the Russian Federation;

  • Upon receipt of any instructions to eliminate any inconsistencies affecting the scope of the Policy;

  • By decision of the Company’s management

  • In case of changing the purposes of personal data processing;

  • In case of changing the organization structure, the structure of information and/or telecommunication systems (or introducing new ones);

  • In case of using new personal data processing technologies (including transmission, storage);

  • In case it becomes necessary to change the process of personal data processing related to the Company’s activities.

7.4. In case of a failure to comply with the provisions of this Policy, the Company and its employees shall be liable in accordance with the applicable legislation of the Russian Federation.