Documents

Processor’s Policy Regarding Processing of Personal Data of OOO "Alexander Tischler"

1. Basic definitions.
1.1. Personal Data Processor (hereinafter referred to as the Processor) — a legal entity or an individual organizing and (or) carrying out processing of personal data, and also defining purposes and the content of personal data processing. For the purposes of this Policy, the Processor is OOO "Alexander Tischler".
1.2. Personal data — any information relating to directly or indirectly identified or defined individual (personal data subject).
1.3. Personal data processing — any action (operation) or a combination of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
1.4. Confidentiality of personal data — mandatory compliance for the Processor and other persons having received access to personal data with the requirement to prevent its distribution without the consent of the personal data subject or availability of other legal grounds.
1.5. Protection of personal data — a complex of measures (organizational, administrative, technical, legal) aimed at preventing unauthorized or accidental access to it, destruction, change, blocking, copying, distribution of subject’s personal data, as well as against other wrongful acts.
1.6. Authorized Body — the federal executive body responsible for control and supervision in the field of mass media, including electronic one, and mass communications, information technologies and communications, functions of control and supervision over the compliance of personal data processing with the requirements of Russian Federation legislation in the field of personal data — Federal Service for Supervision of Communications, Information Technology, and Mass Media.
1.7. User of the atischler.ru website (hereinafter referred to as the User) — a person having access to the website https://atischler.ru/, via the Internet and using the website.
1.8. Cookie — a small data fragment sent by a web-server and stored on the User’s computer, which web-client or web-browser sends to a web-server in HTTP-request each time when trying to open a page of the corresponding website.
1.9. Website Traffic Counter — a service designed to independently measure (statistically) the website traffic.
1.10. User’s Anonymized Data - information collected by Analytics services (Yandex.Metrics, Google.Analytics and similar services), automatically provided by the User’s browser (cookie) and not allowing identification of the User’s personality.

2. Principles of Personal Data Processing.
2.1. Personal data processing shall be arranged by the Processor based on the following principles:
2.1.1. legality and justice;
2.1.2. processing only personal data meeting the purposes of its processing;
2.1.3. compliance of the content and scope of personal data processed with the stated processing purposes. Processed personal data shall not be excessive in relation to stated processing purposes;
2.1.4. inadmissibility of merging databases containing personal data, processing of which is carried out for incompatible purposes;
2.1.5. ensuring the accuracy of personal data, its sufficiency and, where necessary, relevance in relation to personal data processing purposes. The Processor shall take necessary measures or ensure that they are taken to remove or clarify incomplete or inaccurate data;
2.1.6. storing personal data in a form enabling identification of the personal data subject, for no longer than the purposes of personal data processing require;
2.1.7. if the term for storing personal data is not established by the personal data legislation, a contract, a party, beneficiary or guarantor under which the personal data subject is, upon achievement of the processing objectives or in case of loss of necessity to achieve these objectives, unless otherwise provided by the federal law, the personal data processed shall be destroyed.

3. Personal Data Subjects.
3.1. For the purposes of this Policy, the subjects of personal data are defined as follows:
• Processor job applicants — individuals — applicants for vacancies for the period of the Processor’s decision to hire or refuse to hire;
• Processor’s employees — individuals being in the employ of the Processor;
• Processor’s customers — legal entities and individuals (including individual entrepreneurs), planning to or having entered into contractual relationships with the Processor;
• Users of the atischler.ru website (hereinafter referred to as the Users, the User) — persons having access to the website https://atischler.ru/ via Internet or using the website.

4. Purposes and Terms of Personal Data Processing.
4.1. The Processor processes personal data for the following purposes:
4.1.1. proper fulfillment of the Processor’s obligations arising from federal laws, other regulations and agreements with contractors;
4.1.2. execution, conclusion, as well as consideration of the possibility to conclude an employment agreement with the subject of personal data, succession pipeline (ensuring compliance with the requirements of current legislation of the Russian Federation, assistance to employees in employment, training and promotion, ensuring personal safety of employees, monitoring the quantity and quality of work performed and ensuring the safety of the Processor’s property);
4.1.3. reporting to the state supervisory authorities in accordance with the requirements of the current legislation of the Russian Federation;
4.1.4. conclusion, execution and consideration of the possibility to conclude civil law contracts with natural persons, legal entities, individual entrepreneurs and other persons, in the cases provided for by the legislation in force and the Charter of the Processor;
4.1.5. establishing feedback with the User, including sending notices, requests and information regarding the performance of contracts, as well as processing requests from the User;
4.1.6. providing information of a notification or marketing nature, including information on the performance of contracts, services offered and promotions (for which there is an application or prior consent of the subject to receive them);
4.1.7. promoting goods, works, services on the market;
4.1.8. providing information to the Processor’s affiliates;
4.1.9. taking measures to settle debts of personal data subjects;
4.1.10. taking measures to settle applications, claims, messages of clients on quality of service, product provision, sales channel activities;
4.1.11. other purposes in accordance with applicable Russian legislation.
4.2. Personal data may be processed in the following cases:
4.2.1. upon receipt of the personal data subject’s consent to process his/her personal data;
4.2.2. to achieve the purposes provided by law for the exercise and performance of the functions, powers and duties imposed on the Processor by the legislation of the Russian Federation;
4.2.3. to administer justice, enforce a judicial act, an act of another authority or an official subject to enforcement in accordance with Russian law on enforcement proceedings (hereinafter referred to as the execution of the court ruling);
4.2.4. to execute an agreement to which the personal data subject is a party or a beneficiary, including when the Processor exercises its right to assign rights (claims) under such an agreement, as well as to conclude an agreement at the initiative of the personal data subject or an agreement under which the personal data subject is a beneficiary;
4.2.5. to protect the life, health or other vital interests of the personal data subject, if obtaining the consent of the personal data subject is not possible;
4.2.6. to process personal data in accordance with the labour law and the state pension legislation of the Russian Federation;
4.2.7. to process personal data for the exercise of the rights and lawful interests of the Processor or third parties or for the achievement of socially important objectives, provided that the rights and freedoms of the personal data subject are not thereby violated;
4.2.8. to process personal data access to which is granted to an unlimited number of persons by the personal data subject or at his or her request (hereinafter - personal data made publicly available by the personal data subject);
4.2.9. to process personal data subject to publication or compulsory disclosure under federal law;
4.2.10. processing of personal data for the purpose of promoting goods, works or services on the market by direct contact with the potential consumer by means of communication is only permitted with the prior consent of the personal data subject;
4.2.11. in other cases provided for by the current legislation of the Russian Federation.
4.3. Terms and procedure for processing personal data of https://atischler.ru/: Users:
4.3.1. Using the https://atischler.ru/ website by the User means the User’s consent to this Policy;
4.3.2. by registering on https://atischler.ru/ website, as well as completing any sections of the forms posted on https://atischler.ru/ website (including feedback forms), providing their personal data through other services of https://atischler.ru/ website, the User confirms the decision to provide his/her personal data and voluntarily gives full and unconditional consent for its processing to the Processor. Consent shall be given to process the following personal data of the User:
• personal data provided by the User himself by filling in a callback order form, feedback form, presentation order form, newsletter and information subscription form of the Processor on the website https://atischler.ru/ in the relevant sections (services) of the website and including the following information:
— last name, name, patronymic of the User;
— contact phone number of the User;
— e-mail address;
— title and name of the organization on behalf of which the User applies;
— other data independently provided by the User.
• data automatically transmitted to the https://atischler.ru/ website services in the course of their use by the software installed on the User’s device, including IP-address, cookie information, information about the User’s browser (or other program used to access the Site), technical characteristics of the hardware and software used by the User, date and time of access to the Site, addresses of requested pages, and other similar information;
• other information about the User, the collection and/or provision of which is necessary for the use of the https://atischler.ru/ website;
4.3.3. consent is valid from the time the Processor receives the User’s personal data until the processing of the User’s personal data is terminated;
4.3.4. the Processor may use the User’s personal data for:
• establishing feedback from the User;
• providing the User with news announcements, Site news and other information of an advertising nature by sending messages to the e-mail address, messages in applications, communication in Telegram, WhatsApp, Viber, Skype, etc.;
• carrying out other promotional activities, including targeting advertising, research;
• analyzing website visitor behavior to improve the design, usability of the website, assessing the quality of content;
• transfer of personal data (after prior depersonalization procedure) by the Processor to third parties for targeting advertising, research, work or services on behalf of the Processor;
4.3.4. processing of personal data through cookies and website traffic counters:
• cookies transferred by the Processor to the User’s equipment and by the User’s equipment to the Processor may be used by the Processor to target advertisements shown to the User, for statistical and research purposes, and to improve the Website;
• the User is aware that the hardware and software he/she uses to visit websites on the Internet may have the ability to refuse cookies (for any website or for specific websites) and to delete previously received cookies;
• the structure of the cookie file, its content and technical parameters are determined by the Processor and are subject to change without prior notice to the User;
• counters placed by the Processor on the Site may be used to analyze User cookies, to collect and process statistical information on visits to sections of the Site, and to ensure the performance of the Site in general or individual sections of the Site in particular. Technical parameters of counters operation shall be determined by the Processor and are subject to change without prior notice to the User.
4.4. Processor’s assignment. The Processor shall be entitled to entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, based on an agreement concluded with that person, including a state or municipal contract, or by the adoption of an act by a state or municipal authority.
4.5. The Processor shall not receive and process personal data concerning the race, political views, religious or philosophical beliefs, health condition, and intimate life of the subjects.
4.6. The Processor shall not transfer personal data across borders due to the specific nature of its activities.
4.7. The processing of personal data for the purpose of promoting goods, works and services on the market through direct contact with the potential consumer by means of communication is permitted only with the prior consent of the personal data subject.

5. Rights and Obligations of the Personal Data Subject.
5.1. The personal data subject (or his/her representative) shall be entitled to withdraw his/her Consent to the processing of personal data in whole or in part at any time by submitting a free-form written withdrawal application. The application shall be sent to the address: 620049, Sverdlovsk region, Yekaterinburg, 11 Studencheskaya Str., office 505;
5.1.1. the withdrawal of consent to the processing of personal data must contain:
• name of the Processor;
• surname, first name and patronymic of the personal data subject, his/her passport data, residence address;
• surname, first name, patronymic of the representative of the personal data subject, his/her passport data, residence address, the document under which the representation of the personal data subject is performed;
• the purposes for which consent to the processing of personal data was originally given to the Processor, as well as information confirming the personal data subject’s participation in a relationship with the Processor (contract number, contract date, conventional verbal label and/or other information), or information otherwise confirming the processing of personal data by the Processor;
• specific personal data with regard to which the subject withdraws his/her consent;
• the term for the Processor to terminate processing personal data;
• handwritten signature of the personal data subject (or his or her representative);
5.1.2. upon receipt of the above withdrawal of consent to the processing of personal data, the Processor shall have the right to continue processing of personal data on the grounds set out in cl. 4.2.2.—4.2.11. of this Policy;
5.1.3. upon receipt of the above withdrawal of consent to the processing of personal data, the Processor shall notify the personal data subject in writing of the termination/continuation of their personal data processing within seven (7) business days at the latest;
5.1.4. upon receipt of a withdrawal of consent to the processing of personal data transferred for the purpose of promoting goods, works, services on the market, the Processor shall immediately stop processing this personal data and notify the personal data subject in writing within 7 (seven) business days of the termination of processing their personal data.
5.2. The personal data subject (or his/her representative) shall be entitled to access their personal data;
5.2.1. the personal data subject shall be entitled to receive information concerning the processing of his or her personal data, including:
• confirmation of personal data processing by the Processor;
• legal basis and purpose for processing personal data;
• purposes and methods of personal data processing used by the Processor;
• name and location of the Processor, information on persons (other than employees of the Processor) having access to personal data or to whom personal data may be disclosed under a contract with the Processor or under federal law;
• processed personal data relating to the personal data subject in question, the source of such data, unless another procedure for the presentation of such data is provided for by federal law;
• terms for processing personal data, including the terms for its retention;
• the procedure for exercising the personal data subject’s rights under the Federal Law;
• name or surname, first name, patronymic and address of the person processing the personal data on behalf of the Processor, if the processing has been or will be entrusted to such a person;
• other information as required by personal data legislation;
5.2.2. The personal data subject or his/her representative shall have the right to request the Processor to provide the information specified in cl. 5.2.1. of this Policy;
5.2.3. The request shall contain:
• name of the Processor;
• surname, first name and patronymic of the personal data subject, his/her passport data, residence address;
• surname, first name, patronymic of the representative of the personal data subject, his/her passport data, residence address, the document under which the representation of the personal data subject is performed;
• information confirming the personal data subject’s participation in a relationship with the Processor (contract number, date of contract, conventional verbal label and/or other information), or information otherwise confirming the processing of personal data by the Processor;
• form of information submission;
• handwritten signature of the personal data subject (or his or her representative);
5.2.4. The request may be sent in the form of an electronic document and signed by electronic signature in accordance with Russian legislation;
5.2.5. When the Processor receives a request from the personal data subject to provide the information specified in cl. 5.2.1. of this Policy, the Processor shall provide this information within 30 (thirty) calendar days from receipt of the request in the form specified in the request of the personal data subject;
5.2.6. In case of the Processor’s refusal to provide the information requested by the subject, the Processor must send the personal data subject (his/her representative) a reasoned response within 30 (thirty) calendar days from the request receipt, with an obligatory indication of the relevant provisions of the Personal Data Law, based on which the refusal was made;
5.2.7. The personal data subject shall have the right to reapply to the Processor to obtain the information specified in cl. 5.2.1. hereof, with a mandatory indication of the reasons for the reapplication in the request, within the following terms:
• not earlier than thirty (30) calendar days after the initial request, unless a shorter period is prescribed by federal law or an agreement to which the personal data subject is a party or a beneficiary or guarantor;
• before the expiry of the thirty-day period, if such information and/or processed personal data has not been made available to him/her in full following consideration of the initial application;
5.2.8. The Processor shall be entitled to refuse to fulfill a repeated request of the personal data subject not complying with the conditions stipulated in cl. 5.2.7. of this Policy. Such a refusal must be reasoned.
5.3. A personal data subject’s right of access to his/her personal data may be restricted, inter alia, if:
• personal data is processed for the purposes of national defense, state security and law enforcement;
• personal data is processed in accordance with anti-money laundering and counter-terrorist financing legislation;
• the personal data subject’s access to his or her personal data violates the rights and legitimate interests of third parties;
• other cases provided for by legislation on the processing and protection of personal data.
5.4. In order to ensure the protection of personal data, the personal data subjects shall be entitled to:
• have free access to their personal data, including the right to obtain a copy of any record containing the employee’s personal data, except in cases provided for by federal law;
• apply to the Processor with a statement that the personal data is incomplete, inaccurate or irrelevant and provide the relevant supporting documents;
• apply to the Processor for a declaration that his or her personal data is unlawfully obtained or is not necessary for the stated purpose of processing;
• require the Processor or its authorized person to notify all persons (including the data subject himself/herself) who have previously been informed of incorrect, incomplete or irrelevant personal data about all changes made to or deletions from the data subject’s personal data;
• demand that the Processor immediately cease processing of his/her personal data received for the purpose of promoting goods, works or services on the market;
• if the Processor or a person authorized by the Processor refuses to clarify, delete or correct the personal data of the personal data subject, to declare in writing his or her disagreement and provide justification;
• supplement the personal data with an evaluative statement expressing his or her own point of view;
• appeal to the competent authority/court against any unlawful acts or omissions by the Processor or its authorized person in processing and protecting personal data;
• defend his/her rights and legitimate interests, including compensation for damages and/or compensation for moral injury, through the courts.
5.5. In order to maintain complete and accurate information about him/her, the personal data subject shall:
• transmit accurate and reliable personal data to the Processor;
• notify the Processor of any changes to his/her personal data within a period not exceeding three (3) business days from the change in such data in the relevant documents;
• perform any other duties imposed on him/her by personal data law.

6. Responsibilities of the Processor. Measures aimed at ensuring the fulfillment of the Processor’s responsibilities.
6.1. The Processor and other persons having obtained access to personal data shall not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by Russian law.
6.2. Responsibilities of the Processor when collecting personal data. In order to ensure human and civil rights and freedoms, when processing personal data the Processor shall:
6.2.1. provide the personal data subject or his/her representative with the information specified in cl. 5.2.1. of this Policy free of charge;
6.2.2. if the provision of personal data is compulsory under federal law, the Processor must explain to the personal data subject the legal consequences of refusing to provide his/her personal data;
6.2.3. if personal data is received not from the personal data subject, before processing such personal data the Processor must provide the personal data subject with the following information:
• name or first name and address of the Processor or its representative;
• the purpose of personal data processing and its legal basis;
• intended users of personal data;
• the rights of the data subject;
• the source of the personal data;
6.2.4. the Processor shall have the right not to provide the information referred to in cl. 6.2.3. hereof in cases where:
• the personal data subject has been notified of the processing of his or her personal data by the relevant Processor;
• personal data is obtained by the Processor on the basis of a federal law or in connection with the performance of a contract to which the personal data subject is a party or a beneficiary;
• personal data is made publicly available by the personal data subject or is obtained from a publicly accessible source;
• the Processor processes personal data for statistical or other research purposes, for journalistic, scientific, literary or other creative activities, provided that the rights and legitimate interests of the personal data subject are not violated;
• providing the personal data subject with personal data violates the rights and legitimate interests of third parties.
6.3. Measures to ensure the fulfillment of the Processor’s responsibilities;
6.3.1. the Processor shall take such measures as are necessary and sufficient to ensure the fulfillment of the obligations imposed on it by Russian legislation on personal data, namely:
• appointment of a person responsible for organizing the processing of personal data;
• designating a person responsible for ensuring the security of data on information systems;
• publication of this Policy, as well as other documents defining the Processor’s policy regarding processing and protection of personal data;
• applying legal, organizational and technical measures to ensure the security of personal data in accordance with this Policy;
• exercising internal control over the compliance of personal data processing with Russian personal data legislation and this Policy;
• assessing the harm that may be caused to personal data subjects in the event of a breach of this Policy, the ratio of the said harm to the measures taken by the Processor to ensure the fulfillment of the Processor’s responsibilities;
• familiarizing the employees of the Processor directly involved in the processing of personal data with this Policy and Russian personal data legislation, including the training of the said employees;
6.3.2. the Processor shall, at the request of the authorized body, confirm that measures have been taken to ensure that the Processor’s responsibilities as set out in Russian law and this Policy are fulfilled;
6.3.3. the Processor shall publish on its official website: https://atischler.ru/ or otherwise provide unrestricted access to the document defining the Processor’s policy regarding processing of personal data, information on the implemented requirements for the protection of personal data.

7. Ensuring the Security of Personal Data during Processing.
7.1. When processing personal data, the Processor shall take necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other wrongful acts in relation to personal data.
7.2. The Processor shall ensure the security of personal data during its processing by using the following means:
• identification of threats to the security of personal data when processed in the Processor’s information systems;
• application of organizational and technical measures to ensure the security of personal data during their processing in the Processor’s information systems;
• use of information security features;
• evaluating the effectiveness of the measures taken to ensure the security of personal data prior to the Processor commissioning;
• restricting the use of computer media in the processing of personal data;
• detecting unauthorized access to personal data and taking action;
• restoring personal data that has been modified or destroyed as a result of unauthorized access;
• establishing rules for access to personal data processed in the Processor’s information systems, as well as ensuring registration and recording of all actions performed with personal data in the Processor’s information systems;
• monitoring the measures taken to ensure the security of personal data and the level of security of personal data information systems.
7.3. Measures taken by the Processor to ensure the security of personal data processed using tangible media and information systems:
• establishing a restricted access regime for the personal data of the subjects by the Processor;
• establishing a data protection regime for personal data carriers;
• establishing a security regime for premises;
• establishing a security regime for information systems.

Operating Procedures for the OOO "Alexander Tischler" products

1. General recommendations.
Keep the products from any contact with sharp and cutting objects and impacts.

2. Products made of laminated chipboard.
Take care of laminated chipboard products using soft, damp cloths. You can use polishes for plastics. Use polishes that are safe to come into contact with food. Do not use hard cleaners with a plastic or metal surface for cleaning. Protect products from direct sunlight, hot and cold objects, and liquids.

3. Products made of MDF, finished with veneer.
When caring for veneered products use a soft cloth or suede; moisten and wring out well before use. After cleaning, wipe with a dry cloth. A good alternative is dry cleaning with a vacuum cleaner with a soft brush attachment. Protect products from direct sunlight, hot and cold objects, and liquids.

4. Products made of MDF, finished with enamel.
When cleaning use a soft cloth moistened with soapy water or special detergents without abrasive particles. Protect products from direct sunlight, hot and cold objects, and liquids.

5. Products made of MDF, finished with metallized enamel.
In case of contact with water, wipe the product dry. Do not use devices with hard surfaces or detergents containing abrasive particles. Protect products from direct sunlight, hot and cold objects, and liquids.

6. Products made of solid wood.
To remove dust, use a dry cloth. To clean, use products designed for wooden furniture. Avoid sudden changes in temperature and humidity in the rooms where the product is placed. Permissible temperature: not lower than +10 and not more than +40°C. Permissible humidity: from 40% to 60%. Protect products from direct sunlight, hot and cold objects, and liquids.

7. Products made of acrylic stone.
When cleaning, do not use aggressive chemicals or hard sponges. Protect products from direct sunlight and contact with hot and cold objects.

8. Products made from quartz agglomerate.
To clean, use a soft cloth dampened with detergent. Hardened dirt can be carefully removed with a plastic spatula. Do not use metal sponges or chlorine-containing products for cleaning. If you are not certain about the safety of a detergent, test it in a small amount in an inconspicuous place before use. Protect products from contact with hot and cold objects.

9. Products made of natural stone.
Marble products are much more porous than quartzite or granite and they are especially susceptible to contamination from liquids and food residues. Keep products clean and dry. When cleaning, do not use aggressive chemicals or hard sponges.

10. Leather goods.
To care for suede items, use a soft-bristled brush or a vacuum cleaner with a delicate attachment. To care for items made of smooth natural leather, use a vacuum cleaner with a soft attachment and a damp cloth. To remove stains, use special products; do not use hard sponges. After cleaning with water, wipe the product dry. Protect products from direct sunlight.

11. Products made of artificial leather.
Care for artificial leather items using a foam sponge or soft cloth and a mild soap solution. To remove stains, use special products; after cleaning with water, wipe the product dry.

12. Fabric products.
When cleaning, use a brush with soft bristles. Avoid exposure to moisture. Protect products from contact with hot and cold objects.

13. Products made of glass.
Clean glass items using a soft cloth dampened with glass cleaner. Protect products from contact with hot and cold objects.

14. Products made of acrylic glass.
When cleaning, use a soft cloth dampened with a non-aggressive cleaning agent.

15. Products made of stainless steel.
When cleaning, do not use aggressive chemicals or harsh devices.

16. Products made of aluminum.
When cleaning, use a soft cloth and non-aggressive chemicals. To add shine, you can use soft, dry fabrics. Protect products from contact with hot and cold objects.

17. Products made of ceramic granite.
When cleaning, use a soft cloth and cleaning products without abrasive particles.

18. Fittings.
Do not load shelves and drawers over the permissible values: for drawers, it’s no more than 25 kg, and for shelves – no more than 50 kg. Distribute the load evenly. Do not hang foreign objects on the facades, do not hang on them. Protect the fittings from contact with liquids.

Business Profile of OOO "Alexander Tischler"

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