CONFIDENTIALITY POLICY

Moscow

This personal data confidentiality policy (further — Confidentiality Policy) applies to any User information obtainable by the website located at http://orgonaft.ru/ during the use of the company's website, software and products.

1.         TERMS AND DEFINITIONS

1.1       Terms used in this Confidentiality Policy have the following meaning:

1.1.1.   Company's Website Administration (further — Website Administration) means authorized employees of the website management team acting on behalf of JSC EPT Orgneftekhimzadody who organize and/or undertake personal data processing, and define the personal data processing objectives, scope of personal data subject to processing, actions (operations) with use of personal data.

1.1.2.   Personal Data means any information relating, directly or indirectly, to a certain or identifiable private person (personal data owner).

1.1.3.   Personal Data Processing means any action (operation) or a series of actions (operations) performed using the computers or without using them with personal data, including collection, recording, classification, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, locking, removal, destruction of personal data.

1.1.4.   Personal Data Confidentiality is a mandatory requirement for the Operator or another party having obtained access to personal data to prevent their distribution without consent of the personal data owner or availability of another legal ground for it.

1.1.5.   User of http://orgonaft.ru/ website (further — User) means a person having access to the website via Internet and using the company's website.

1.1.6.   Cookies mean a small fragment of data sent by web-server and stored at the User's computer which is resent every time by a web‑client or a web-browser to the web-server in HTTP request in the attempt to open a page of respective website.

1.1.7.   IP address means a unique web address of a device in the computer network based on IP protocol.

2.         GENERAL PROVISIONS

2.1.      Use of the company's website by the User is understood as his/her consent with this Confidentiality Policy and the terms and conditions of the User's personal data processing.

2.2.      If the User disagrees with the terms and conditions of the Confidentiality Policy, he/she shall cease using the company's website.

2.3.      This Confidentiality Policy applies only to the company's website http://orgonaft.ru/. The Company shall not control and not assume liability for the websites of third parties, which the User can visit using the links available at the company's website.

2.4.      The Website Administration shall not check accuracy of personal data provided by the User of the company's website.

3.         CONFIDENTIALITY POLICY SCOPE

3.1.      This Confidentiality Policy outlines responsibilities of the company's Website Administration for non-disclosure and maintaining confidentiality of personal data, which the User provides upon request of the Website Administration in process of signing-in to the company's website.

3.2.      Personal data permitted for processing under this Confidentiality Policy shall be provided by the User by filling in the sign-in forms at the company's website http://orgonaft.ru/ and include the following information:

3.2.1.   User's surname, name, patronymic.

3.2.2.   User's contact phone.

3.2.3.   E-mail.

3.2.4.   User's place of residence.

3.3.      The company protects the data automatically transferred in process of viewing of commercials and visiting the pages where statistical script (pixel) is installed:

3.3.1.   IP address;

3.3.2.   information from cookies;

3.3.3.   information on web-browser (or another program implementing access to commercials);

3.3.4.   time of access;

3.3.5.   address of the page with commercial;

3.3.6.   referrer (address of the previous page).

3.4.      Any other personal information not stipulated above (browsing history, used browsers and operating systems, etc.) is subject to proper storage and non-distribution, except for the cases specified in Clauses 5.2 and 5.3 of this Confidentiality Policy.

4.         PURPOSE OF COLLECTION OF USER PERSONAL DATA

4.1.      User's personal data can be used by the Website Administration for the following purposes:

4.1.1.   Identifying of the User signed up at the website.

4.1.2.   Maintaining feedback with the User, including sending of notices, requests regarding use of the company's website, provision of services, processing of the User's requests.

4.1.3.   Locating the User for the sake of security, fraud prevention.

4.1.4.   Confirming the accuracy and completeness of personal data provided by the User.

4.1.5.   Providing to the User of efficient client and technical support when any problems with use of the company's website occur.

4.1.6.   Providing to the User (upon the User's consent) of service updates, special offers, pricing information, newsletters and other information on behalf of the company.

4.1.7.   Implementing promotional activities upon the User's consent.

5.         PERSONAL DATA PROCESSING METHODS AND TIMELINES

5.1.      User's personal data shall be processed without limitation as to time by any legally permitted method, including processing in personal information management systems, using computers or without them.

5.2.      User's personal data may be transferred to the competent public authorities of the Russian Federation only for reasons and in manner established by the Russian Federation law.

5.3.      In the event of loss or disclosure of personal data, the Website Administration shall inform the User on the loss or disclosure of personal data.

5.4.      The Website Administration shall take any reasonable organizational and technical measures to protect the User's personal data against unlawful or unauthorized access, destruction, alteration, locking, reproduction, distribution, or other unlawful actions of the third parties.

5.5.      The Website Administration, jointly with the User, shall take any reasonable measures to prevent the losses or other adverse consequences caused by loss or disclosure of the User's personal data.

6.         COMMITMENTS OF THE PARTIES

6.1.      The User shall:

6.1.1.   Provide information on the personal data necessary for using the company's website.

6.1.2.   Update, add the provided information on the personal data in case of change of such information.

6.2.      The Website Administration shall:

6.2.1.   Use the obtained information solely for the purposes specified in Clause 4 of this Confidentiality Policy.

6.2.2.   Ensure keeping confidential information in secret, not disclose it without prior written permit of the User, not sell, exchange, publish or disclose the User's personal data by other potential means, except for the purpose of Clauses 5.2 and 5.3 of this Confidentiality Policy.

6.2.3.   Exercise reasonable care for privacy protection of the User's personal data in accordance with the procedure normally used for protection of such type of information in the customary business practices.

6.2.4.   Lock personal data belonging to respective User as of the time of application or request of the User or his/her legal representative or authorized body for protection of the rights of the personal data owners for a period of check-up when any inaccurate personal data or wrongful actions are revealed.

7.         LIABILITY OF THE PARTIES

7.1.      Failing to fulfill its responsibilities, the Website Administration shall be liable for the losses incurred by the User due to inappropriate use of personal data in accordance with the Russian Federation law, except for the purpose of Clauses 5.2 and 7.2 of this Confidentiality Policy.

7.2.      In the event of loss or disclosure of confidential information, the Website Administration shall not be liable if such confidential information:

7.2.1.   has become publicly available before its loss or disclosure;

7.2.2.   has been obtained from a third party before its receipt by the Website Administration;

7.2.3.   has been disclosed upon the User's consent.

8.         DISPUTE SETTLEMENT

8.1.      Before initiation of the legal proceedings in respect of any disputes arising out of relations between the website User and the Website Administration, a party concerned shall lodge a claim (written proposal on amicable dispute settlement).

8.2.      Within 30 calendar days after the claim receipt date, the claim receiver shall notify the claimer in writing on the claim review results.

8.3.      Should the parties fail to reach an agreement, the dispute shall be referred to the court for resolution in accordance with the effective law of the Russian Federation.

8.4.      This Confidentiality Policy and relations between the User and the Website Administration shall be governed by the effective law of the Russian Federation.

9.         MISCELLANEOUS

9.1.      The Website Administration may introduce amendments in this Confidentiality Policy without the User's consent.

9.2.      The new Confidentiality Policy shall enter into effect as of the date of its publishing at the website, unless otherwise stated in the new version of the Confidentiality Policy.

9.3.      Any proposals or questions regarding this Confidentiality Policy shall be addressed to ipt@orgonaft.ru.

9.4.      Effective Confidentiality Policy is published at http://orgonaft.ru/