1. General Provisions

This Personal Data Processing Policy (hereinafter — the Policy) defines the procedures for processing and protecting personal data of individuals who use the services of ROSSMA LLC (hereinafter — the Operator).

Operator: ROSSMA LLC
Address: 614 064, Perm Krai, Perm, Chkalova St., 9D, office 320, 322, Russia
E-mail: info@rossma.ru
Phone: +7 342 233 93 99

The Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and other regulatory legal acts of the Russian Federation in the field of personal data.

The Policy applies to all personal data that the Operator receives from data subjects, including through the website rossma.ru.

2. Key Definitions

• Personal data — any information relating directly or indirectly to an identified or identifiable individual (data subject).
• Personal data processing — any action (operation) or set of actions performed with or without automation on personal data, including collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
• Operator — a legal entity that independently or jointly with other persons organizes and/or carries out the processing of personal data.
• Data subject — an individual whose personal data is processed by the Operator.
• Confidentiality of personal data — a mandatory requirement for the Operator to prevent the dissemination of personal data without the consent of the data subject or other legal grounds.

3. Categories of Personal Data Processed

The Operator may process the following categories of personal data:

• Full name;
• Email address;
• Phone number;
• Organization name and position;
• IP address;
• Cookie data;
• Website visit data (date, time, pages viewed, browser type, operating system);
• Other data voluntarily provided by the subject through website contact forms.

The Operator does not process special categories of personal data (racial origin, political views, health status, etc.).

4. Purposes of Data Processing

Personal data is processed for the following purposes:

• Conclusion and execution of contracts for product supply and services;
• Processing inquiries and requests through contact forms;
• Project cost estimation at the client's request;
• Technical support and consultation;
• Sending informational and promotional materials (with separate consent);
• Improving service quality and website performance;
• Website visit statistics;
• Compliance with the legislation of the Russian Federation.

5. Legal Basis for Processing

Personal data processing is carried out on the following legal grounds:

• Consent of the data subject (Art. 6, Part 1, Clause 1 of FZ-152);
• Performance of a contract to which the data subject is a party (Art. 6, Part 1, Clause 5 of FZ-152);
• Compliance with legal obligations (Art. 6, Part 1, Clause 2 of FZ-152);
• Exercise of the Operator's legitimate rights and interests (Art. 6, Part 1, Clause 7 of FZ-152).

In accordance with amendments effective September 1, 2025, the data subject's consent is obtained separately for each purpose of personal data processing.

6. Data Processing Procedures

Personal data processing includes the following actions:

• Collection — performed when the subject fills out forms on the website, sends requests via email, or enters into contracts;
• Storage — on servers located within the Russian Federation;
• Use — for the purposes specified in Section 4 of this Policy;
• Transfer — to third parties only on lawful grounds;
• Destruction — upon achieving the purposes of processing or at the data subject's request.

The Operator does not carry out automated decision-making, including profiling, based on personal data.

7. Personal Data Protection

The Operator takes necessary and sufficient organizational and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, dissemination, and other unlawful actions.

Technical measures:

• Use of the secure HTTPS (SSL/TLS) protocol for data transmission;
• Restricted access to personal data by authorized employees only;
• Regular software updates;
• Use of antivirus protection and firewall systems.

Organizational measures:

• Approval of internal documents defining the procedures for personal data processing;
• Familiarizing employees with personal data legislation requirements;
• Appointment of a person responsible for organizing personal data processing.

8. Rights of Data Subjects

The data subject has the right to:

• Receive information about the processing of their personal data;
• Request clarification, blocking, or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose;
• Withdraw consent to personal data processing at any time by sending a request to info@rossma.ru;
• Request cessation of data processing for marketing purposes;
• Appeal the Operator's actions or inaction to Roskomnadzor or through the courts.

The Operator is obliged to review the data subject's request within 10 business days of receipt. Upon withdrawal of consent, the Operator shall cease processing and destroy the personal data within 30 days.

9. Cookies and Tracking Technologies

The rossma.ru website uses cookies and similar technologies. Analytics cookies are only set after your explicit consent given through the cookie banner on your first visit.

Managing consent: on your first visit, a banner asks you to accept or reject analytics cookies. Your choice is stored for 365 days. To withdraw consent, clear your browser cookies — the banner will reappear on your next visit.

Disabling cookies in your browser: you may block cookies via browser settings. Note that disabling essential cookies may affect website functionality (login, language selection).

10. Cross-Border Data Transfers

Personal data of citizens of the Russian Federation is stored and processed on servers located within the Russian Federation, in accordance with Part 5, Article 18 of FZ-152.

Cross-border transfer of personal data to foreign states is carried out only when adequate protection of data subjects' rights is ensured in accordance with FZ-152 requirements.

11. Data Retention Periods

Personal data is retained for the periods necessary to achieve the purposes of processing:

• Contact form data — for 1 year from the date of last inquiry;
• Contract data — for 5 years after termination of contractual relations;
• Newsletter subscriber data — until the subscriber unsubscribes;
• Cookie data — in accordance with user browser settings, but no longer than 1 year.

Upon expiration of the retention period, personal data is destroyed within 30 days.

12. Policy Amendments

The Operator reserves the right to amend this Policy. The new version becomes effective upon publication on the website unless otherwise specified.

Continued use of the website after changes are made constitutes the data subject's acceptance of the new version of the Policy.

We recommend periodically reviewing this Policy for updates.

13. Contact Information

For questions related to personal data processing, you may contact:

• E-mail: info@rossma.ru
• Phone: +7 342 233 93 99
• Postal address: 614 064, Perm Krai, Perm, Chkalova St., 9D, office 320, 322, Russia

Authorized body for the protection of data subjects' rights:

Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)
Address: 109992, Moscow, Kitaygorodsky Proezd 7, Bldg 2, Russia
Website: rkn.gov.ru