This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by JSC “BFZ” (hereinafter — the Operator).
1.1. The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data — including the protection of the right to privacy, personal and family confidentiality — to be its primary objective and a condition of its operations.
1.2. This Policy of the Operator with respect to the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://rusferroalloys.ru/en/.

2.1. Automated processing of personal data — processing of personal data using computing equipment.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is required to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, making them accessible on the internet at https://rusferroalloys.ru/en/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means used to process them.
2.5. Anonymisation of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated means in relation to personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymisation, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organises and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the categories of personal data to be processed, and the actions (operations) to be performed on personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://rusferroalloys.ru/en/.
2.9. Personal data authorised by the data subject for dissemination — personal data to which unrestricted access has been granted by the data subject by giving consent to the processing of personal data authorised for dissemination in the manner prescribed by the Personal Data Law (hereinafter — personal data authorised for dissemination).
2.10. User — any visitor to the website https://rusferroalloys.ru/en/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a defined group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or provision of access to personal data by any other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign state authority, or to a foreign individual or legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed with no possibility of further recovery of its content within the personal data information system, and/or physical carriers of personal data are destroyed.

3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, or submits a request to cease processing, continue processing personal data without the subject’s consent where grounds specified in the Personal Data Law exist;
— independently determine the composition and scope of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law and related regulatory legal acts, unless otherwise stipulated by the Personal Data Law 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 procedure established by the applicable legislation of the Russian Federation;
— respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— submit the necessary information to the authorised body for the protection of personal data subjects’ rights upon that body’s request within 10 days of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— implement legal, organisational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions in respect of personal data;
— cease the transfer (dissemination, provision, access), cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfil other obligations provided for by the Personal Data Law.

4.1. Personal data subjects have the right to:
— obtain information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the data subject by the Operator in an accessible form and shall not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purpose of processing, and to take legally prescribed measures to protect their rights;
— stipulate prior consent as a condition for the processing of personal data for the purposes of marketing goods, works, and services;
— withdraw consent to the processing of personal data and submit a request to cease such processing;
— lodge a judicial complaint against, or appeal to the authorised body for the protection of personal data subjects’ rights in respect of, unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided for 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 updates (changes) to their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, shall be held liable in accordance with the legislation of the Russian Federation.

5.1. Personal data is processed on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of its collection is not permitted.
5.3. The merging of databases containing personal data processed for purposes that are incompatible with one another is not permitted.
5.4. Only personal data that is consistent with the purposes of its processing shall be subject to processing.
5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. During the processing of personal data, its accuracy, sufficiency, and, where necessary, relevance in relation to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or by an agreement to which the data subject is a party, beneficiary, or guarantor. Personal data being processed shall be destroyed or anonymised upon achievement of the processing purposes, or upon the purposes no longer being necessary to achieve, unless otherwise provided for by federal law.

7.1. Personal data is processed with the consent of the personal data subject.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to fulfil the functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a court order, or enforcement of an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve publicly significant objectives, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. Processing is carried out in respect of personal data to which unrestricted access has been granted by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out in respect of personal data subject to publication or mandatory disclosure in accordance with federal law.

The security of personal data processed by the Operator is ensured through the implementation of legal, organisational, and technical measures necessary to fully comply with the requirements of applicable personal data protection legislation.
8.1. The Operator ensures the integrity of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
8.2. The User's personal data shall under no circumstances be transferred to third parties, except where required by applicable legislation or where the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law agreement.
8.3. Should inaccuracies be identified in personal data, the User may update it independently by sending the Operator a notification to investor@rusferroalloys.ru marked "Personal Data Update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is stipulated by agreement or applicable legislation. The User may withdraw consent to the processing of personal data at any time by sending the Operator a notification by email to investor@rusferroalloys.ru marked "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those parties (Operators) in accordance with their respective User Agreements and Privacy Policies. The Operator bears no liability for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer (other than the provision of access) or processing of personal data authorised for dissemination, or conditions placed on such processing, shall not apply where personal data is processed in the public, social, or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data in the course of its processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or by an agreement to which the data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data include: achievement of the processing purposes, expiry of the personal data subject's consent, withdrawal of consent by the data subject, a request to cease processing, or identification of unlawful processing of personal data.

9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymisation, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without the transmission of information received via information and telecommunication networks.

10.1. Prior to commencing cross-border transfer of personal data, the Operator is required to notify the authorised body for the protection of personal data subjects' rights of its intention to carry out such transfer (such notification is submitted separately from the notification of intention to process personal data).
10.2. Prior to submitting the above notification, the Operator is required to obtain the relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

The Operator and any other persons who have obtained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided for by federal law.

12.1. The User may obtain clarification on any questions relating to the processing of their personal data by contacting the Operator at investor@rusferroalloys.ru.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at http://rusferroalloys.ru/en/privacy-policy.