Privacy Policy

1. General Provisions
1.1 This Personal Data Processing Policy (hereinafter referred to as the “Policy”) establishes the procedure and conditions for the processing of personal data by Chaika Modular Shipbuilding Center LLC (Taxpayer Identification Number: 5249186634; address: 15K Igumnovskoye Highway, Dzerzhinsk, Nizhny Novgorod Region, 606038, Russian Federation) in relation to users of the website msc-chaika.ru.
1.2 The terms used in this Policy shall have the meanings established by the legislation of the Russian Federation on personal data.
1.3 The Operator processes personal data in accordance with the principles of lawfulness, fairness, data minimisation, and restriction of processing to the achievement of specific, predetermined, and legitimate purposes.
1.4 The Operator ensures the confidentiality of personal data in accordance with Article 7 of the Federal Law on Personal Data and takes the necessary measures to fulfil the obligations established by Part 2 of Article 18.1 and Part 1 of Article 19 of the said law, including organisational and technical data protection measures.
1.5 Contact details for enquiries from personal data subjects: email: info@msc-chaika.ru; telephone: +7 (903) 790-84-84; postal address: 15K Igumnovskoye Highway, Dzerzhinsk, Nizhny Novgorod Region, 606038, Russian Federation. This Policy is effective from 2026-05-15 and is made publicly available on the website.

2. Key Terms Used in the Policy
2.1 Automated processing of personal data means the processing of personal data using computer technology.
2.2 Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to verify or update personal data.
2.3 Website means the collection of graphical and informational materials, computer software, and databases that make such materials available on the Internet at msc-chaika.ru.
2.4 Personal data information system means a collection of personal data contained in databases, together with the information technologies and technical means used for their processing.
2.5 Anonymisation of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data relates to a specific User or another personal data subject.
2.6 Processing of personal data means any action or operation, or any set of actions or operations, performed with or without automated means in relation to personal data, including collection, recording, systematisation, accumulation, storage, verification, updating, modification, retrieval, use, transfer, distribution, provision, access, anonymisation, blocking, deletion, and destruction of personal data.
2.7 Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organises and/or carries out the processing of personal data and determines the purposes of personal data processing, the categories of personal data to be processed, and the actions or operations performed with personal data.
2.8 Personal data means any information relating directly or indirectly to an identified or identifiable User of the website msc-chaika.ru.
2.9 Personal data authorised by the personal data subject for public distribution means personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorised for distribution in accordance with the procedure established by the Federal Law on Personal Data, hereinafter referred to as personal data authorised for distribution.
2.10 User means any visitor to the website msc-chaika.ru.
2.11 Provision of personal data means actions aimed at disclosing personal data to a specific person or a defined group of persons.
2.12 Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunications networks, or provision of access to personal data by any other means.
2.13 Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14 Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of such data in a personal data information system, and/or resulting in the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator
3.1 The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the consent of the personal data subject where the subject withdraws consent or submits a request to terminate processing, provided that grounds specified by the Federal Law on Personal Data are available;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Federal Law on Personal Data and the regulatory legal acts adopted pursuant to it, unless otherwise provided by the Federal Law on Personal Data or other federal laws.
3.2 The Operator is obliged to:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organise the processing of personal data in accordance with the applicable legislation of the Russian Federation;
— respond to enquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Federal Law on Personal Data;
— provide the authorised authority responsible for protecting the rights of personal data subjects with the requested information within 10 days from the date of receipt of such a request;
— publish this Personal Data Processing Policy or otherwise provide unrestricted access to it;
— take legal, organisational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
— terminate the transfer, distribution, provision, or access to personal data, terminate processing, and destroy personal data in the procedure and circumstances established by the Federal Law on Personal Data;
— fulfil other obligations established by the Federal Law on Personal Data.

4. Main Rights and Obligations of Personal Data Subjects
4.1 Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where lawful grounds exist for disclosing such personal data. The scope of information and the procedure for obtaining it are established by the Federal Law on Personal Data;
— require the Operator to verify, update, block, or destroy their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and take other measures provided by law to protect their rights;
— require prior consent before personal data is processed for the purpose of promoting goods, works, and services in the market;
— withdraw consent to personal data processing and submit a request to terminate the processing of personal data;
— appeal unlawful acts or omissions of the Operator in connection with personal data processing to the authorised authority responsible for protecting the rights of personal data subjects or through judicial proceedings;
— exercise other rights provided by the legislation of the Russian Federation.
4.2 Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any verification, update, or modification of their personal data.
4.3 Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that subject’s consent shall be liable in accordance with the legislation of the Russian Federation.

5. Purposes of Personal Data Collection and Processing
5.1 Preparation, conclusion, and performance of civil-law contracts.
5.2 User support and processing of enquiries.
5.3 Ensuring the operation and security of the website and/or application.
5.4 Statistical accounting and analysis.
5.5 Promotion of goods, works, and services in the market.
5.6 Organisation of events, webinars, and mailing campaigns.
5.7 Recruitment of candidates for vacant positions.

6. Legal Grounds for Personal Data Processing
6.1 For the purpose of “Preparation, conclusion, and performance of civil-law contracts”, the legal grounds are the Civil Code of the Russian Federation and the relevant contract.
6.2 For the purpose of “User support and processing of enquiries”, the legal grounds are the relevant contract or offer, Federal Law No. 126-FZ in relation to the recording of calls where notification is provided, and consent where required.
6.3 For the purpose of “Ensuring the operation and security of the website and/or application”, the legal grounds are the legitimate interests of the Operator in ensuring system functionality and security, Federal Law No. 149-FZ, internal regulations, and consent to cookies and analytics where required.
6.4 For the purpose of “Statistical accounting and analysis”, the legal grounds are Federal Law No. 282-FZ and the anonymisation of data.
6.5 For the purpose of “Promotion of goods, works, and services in the market”, the legal grounds are the personal data subject’s consent to marketing communications, Federal Law No. 38-FZ “On Advertising”, and Federal Law No. 126-FZ “On Communications”.
6.6 For the purpose of “Organisation of events, webinars, and mailing campaigns”, the legal grounds are the relevant contract or participation offer, consent to mailing and/or advertising communications, Federal Law No. 38-FZ “On Advertising”, and Federal Law No. 126-FZ “On Communications”.
6.7 For the purpose of “Recruitment of candidates for vacant positions”, the legal grounds are the Labour Code of the Russian Federation, the candidate’s consent, and the relevant contract or offer governing processing and consent.
6.8 The Operator’s constitutional documents, internal regulations, agreements concluded with personal data subjects, and/or consents granted by them may also constitute legal grounds in cases provided for by law.
Note: Federal Law No. 152-FZ “On Personal Data” establishes general requirements for personal data processing and does not in itself constitute a legal ground for processing.

7. Scope and Categories of Personal Data Processed; Categories of Personal Data Subjects
7.1 For the purpose of “Preparation, conclusion, and performance of civil-law contracts”, the following categories of data may be processed: full name or company name, passport or registration details, address, contact details, payment details, and transaction and settlement history.
7.2 For the purpose of “User support and processing of enquiries”, the following categories of data may be processed: full name, contact details, contents of enquiries, calls and chats, call recordings, ticket metadata, and payment or order data where required.
7.3 For the purpose of “Ensuring the operation and security of the website and/or application”, the following categories of data may be processed: IP addresses, date and time, URLs, headers and technical identifiers, cookies and SDK data, device information, error logs, and access logs.
7.4 For the purpose of “Statistical accounting and analysis”, anonymised and aggregated data may be processed, as well as the minimum necessary personal data where required, followed by anonymisation.
7.5 For the purpose of “Promotion of goods, works, and services in the market”, the following categories of data may be processed: full name, contact details, including telephone number, email address and messenger details, order and interaction history, cookies, and behavioural data where consent has been obtained.
7.6 For the purpose of “Organisation of events, webinars, and mailing campaigns”, the following categories of data may be processed: full name, contact details, position and organisation where provided, registration forms, attendance information, preferences, and survey results.
7.7 For the purpose of “Recruitment of candidates for vacant positions”, the following categories of data may be processed: full name, contact details, CV, education, experience, qualifications, interview and test results, portfolio, and references.
7.8 Depending on the purpose of processing, personal data subjects may include website visitors and service users, customers, individual counterparties, representatives of corporate counterparties, employees, candidates for vacant positions, and other persons.

8. Procedure and Conditions for Personal Data Processing
8.1 Personal data is processed on the basis of the User’s consent to the processing of their personal data, unless otherwise provided by the legislation of the Russian Federation.
8.2 Consent is expressed through actions clearly intended to provide personal data, including completing fields in a form on the Website, submitting an application or message, and confirming acceptance of this Policy by selecting the relevant checkbox next to the form where such a checkbox is provided.
8.3 The User may withdraw consent to personal data processing at any time by sending a request to info@msc-chaika.ru. Following withdrawal, the Operator shall terminate processing, except where processing without consent is permitted by law or on other lawful grounds.
8.4 For the purpose of “Preparation, conclusion, and performance of civil-law contracts”, the following operations may be performed with personal data: collection, recording, systematisation, accumulation, storage, verification, updating, modification, retrieval, use, transfer, provision, access, anonymisation, blocking, deletion, and destruction.
8.5 For the purpose of “User support and processing of enquiries”, the following operations may be performed with personal data: collection, recording, systematisation, accumulation, storage, verification, updating, modification, retrieval, use, transfer, provision, access, anonymisation, blocking, deletion, and destruction.
8.6 For the purpose of “Ensuring the operation and security of the website and/or application”, the following operations may be performed with personal data: collection, recording, systematisation, accumulation, storage, verification, updating, modification, retrieval, use, transfer, provision, access, anonymisation, blocking, deletion, and destruction.
8.7 For the purpose of “Statistical accounting and analysis”, the following operations may be performed with personal data: collection, recording, systematisation, accumulation, storage, verification, updating, modification, retrieval, use, transfer, provision, access, anonymisation, blocking, deletion, and destruction.
8.8 For the purpose of “Promotion of goods, works, and services in the market”, the following operations may be performed with personal data: collection, recording, systematisation, accumulation, storage, verification, updating, modification, retrieval, use, transfer, provision, access, anonymisation, blocking, deletion, and destruction.
8.9 For the purpose of “Organisation of events, webinars, and mailing campaigns”, the following operations may be performed with personal data: collection, recording, systematisation, accumulation, storage, verification, updating, modification, retrieval, use, transfer, provision, access, anonymisation, blocking, deletion, and destruction.
8.10 For the purpose of “Recruitment of candidates for vacant positions”, the following operations may be performed with personal data: collection, recording, systematisation, accumulation, storage, verification, updating, modification, retrieval, use, transfer, provision, access, anonymisation, blocking, deletion, and destruction.
8.11 Processing may be performed using automated means and/or without the use of automated means.
8.12 Personal data may be transferred to the following third parties: Yandex Metrica and Yandex Webmaster, on the basis of data processing agreements and/or other agreements and subject to compliance with personal data protection requirements.
8.13 The information systems and/or individual services are hosted by Makecloud.
8.14 When storing personal data, the Operator uses databases located within the territory of the Russian Federation in accordance with Part 5 of Article 18 of the Federal Law on Personal Data.
8.15 Data retention periods: logs are retained for 12 months and correspondence for 3 years.
8.16 The Website may use cookies to ensure the correct operation of its services and improve the user experience.
8.17 Website traffic analytics may be conducted, including through counters, pixels, and SDKs, with only the minimum necessary data being processed. The use of marketing identifiers requires consent where required by law.
8.18 The Operator may transfer personal data to authorised state authorities on the grounds established by the legislation of the Russian Federation.

9. Measures to Protect Personal Data
9.1 The Operator takes the necessary legal, organisational, and technical measures to protect Users’ personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions.
9.2 Such measures include, in particular: appointing persons responsible for organising personal data processing and ensuring personal data security; adopting internal regulations governing personal data processing and protection; limiting the number of employees with access to personal data and establishing procedures for such access; using antivirus software, firewalls, and other technical information-security measures; storing personal data under conditions ensuring its integrity and preventing unauthorised access; conducting internal monitoring and audits of compliance with the legislation of the Russian Federation on personal data and this Policy; and familiarising employees directly involved in personal data processing with the applicable legislation of the Russian Federation and the Operator’s internal regulations.

10. Updating, Correction, Deletion, and Destruction of Personal Data; Responses to Requests from Personal Data Subjects
10.1 Where the inaccuracy of personal data or the unlawfulness of its processing is confirmed, the Operator shall update the data and/or terminate its processing.
10.2 Personal data shall be destroyed once the purposes of processing have been achieved, upon withdrawal of consent where processing was based on consent, upon expiration of the applicable retention periods, or upon identification of unlawful processing, unless otherwise provided by law or contract.
10.3 A personal data subject may submit a request for information concerning the processing of their personal data and/or an application for verification, blocking, or deletion. The request may be sent by email to info@msc-chaika.ru or by post to: 15K Igumnovskoye Highway, Dzerzhinsk, Nizhny Novgorod Region, 606038, Russian Federation.
10.4 The Operator shall respond to a personal data subject’s request within no more than 30 calendar days from the date of receipt.
10.5 Processing shall be terminated upon achievement of the processing purposes, withdrawal of consent, identification of unlawful processing, or on other grounds provided by law.

11. Policy Updates
11.1 This Policy shall be reviewed and updated in the event of amendments to the legislation of the Russian Federation, applicable regulations, or by decision of the Operator.
11.2 The current version of this Policy is always available on the Operator’s website at msc-chaika.ru.
11.3 A revised version shall take effect from the moment it is published on the Website, unless otherwise stated in the revised version.