Home

Policy on the processing of personal data

LLC “RDS” · revised on 02.09.2026 · website: https://rockdrilling.ru/en

Personal data operator: Limited Liability Company “Rock Drilling Solutions” (LLC “RDS”)

OGRN 1226600078352

INN 6678125921 / KPP 667801001

Legal entity address: 623704, Sverdlovsk Oblast, Berezovsky Municipal District, Berezovsky City, Komsomolskaya Street, 19

Contact phone: +7 (902) 258 2075

Email address: ps@rockdrilling.ru

This Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all internet resources owned by the limited liability company “Rock Drilling Solutions” (hereinafter referred to as the “Company”, the “Operator”), including but not limited to the website and domain name https://rockdrilling.ru/en, as well as its regional subdomains and other web resources and services of the Company that enable the collection, storage, and processing of users’ personal data.

1. Terms, definitions and abbreviations used in

the "Personal Data" Policy are any information related directly or indirectly to a specific or identifiable natural person (personal data subject).

""Personal data operator" (hereinafter referred to as the "Operator") is a state body, municipal body, legal entity or individual who independently or jointly with other persons organize and (or) process personal data, as well as determine the purposes of personal data processing, the composition of personal data to be processed, actions (operations), transactions made with personal data.

“Personal data permitted by the subject of personal data for distribution” — personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in accordance with the procedure provided for by Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data”.

“Subject of personal data” — an individual to whom personal data belongs and who can be identified by it.

“Processing of personal data” means any action (operation) or a set of actions (operations) with personal data, carried out using automation tools or without their use. Processing of personal data includes, among other things: collection; recording; systematization; accumulation; storage; clarification (update, modification); extraction; use; transfer (dissemination, provision, access); anonymization; blocking; deletion; destruction.

“Automated processing of personal data” means the processing of personal data using computer technology.

"Dissemination of personal data" — actions aimed at disclosing personal data to an unspecified group of people.

"Providing personal data" is an action aimed at disclosing personal data to a specific person or a specific group of people.

"Blocking of personal data" is the temporary termination of the processing of personal data (except in cases where the processing is necessary to clarify personal data).

"Destruction of personal data" means actions that make it impossible to restore the content of personal data in the personal data information system and/or as a result of which the material carriers of personal data are destroyed.

“Depersonalization of personal data” — actions that make it impossible to determine whether personal data belongs to a specific personal data subject without using additional information.

“Information system of personal data” — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

“Cross‑border transfer of personal data” — the transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.

2. General provisions

This Personal Data Processing Policy has been developed in accordance with the requirements of Article 18.1 of Federal Law No. 152‑FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”), as well as other regulatory legal acts of the Russian Federation in the field of protection and processing of personal data, and defines the goals, principles, conditions and procedure for processing personal data, as well as the measures for their protection implemented by the Company.

The purpose of the Policy is to ensure the protection of the rights and legitimate interests of Personal Data Subjects when their personal data is processed, including the protection of the right to privacy, personal and family secrets, and to ensure that the Company complies with the requirements of the legislation of the Russian Federation in the field of protection and processing of personal data.The Company ensures the protection of the processed personal data from unauthorized access and disclosure, unlawful use or loss in accordance with the requirements of Federal Law No. 152‑FZ dated 27.07.2006 “On Personal Data”.

The policy applies to all personal data processed by the limited liability company “Rock Drilling Solutions” (OGRN 1226600078352, INN 6678125921 / KPP 667801001, legal address: 623704, Sverdlovsk Oblast, Berezovsky Municipal District, Berezovsky City, Komsomolskaya Street, 19).

In accordance with the requirements of Part 2 of Article 18.1 of the Law on Personal Data, this Policy is published in the public domain on the Operator’s website in the information and telecommunications network of the Internet. The scope of this Policy applies to all information resources posted by the Operator on the Internet.

The organization of the storage, accounting, and use of personal data is carried out in accordance with Federal Law No. 152‑FZ dated July 27, 2006, “On Personal Data”.

Monitoring compliance with the requirements of this Policy is carried out by an authorized person responsible for organizing the processing of personal data by the Operator.

Liability for violating the requirements of the legislation of the Russian Federation and the regulatory acts of LLC “RDS” in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.

Responsible for organizing the processing of personal data:

Full name: Pliskin Pavel Viktorovich

Position: manager — individual entrepreneur;

Email address: ps@rockdrilling.ru;

Postal address: 623704, Sverdlovsk Oblast, Berezovsky Municipal District, Berezovsky Town, Komsomolskaya Street, 19.

3. Legal grounds for processing personal data

3.1. The legal grounds for processing personal data are the set of regulatory legal acts, in accordance with which and pursuant to which the Operator processes personal data, including:

  • the Constitution of the Russian Federation;
  • the Civil Code of the Russian Federation;
  • the Labour Code of the Russian Federation;
  • the Tax Code of the Russian Federation;
  • Federal Law No. 14‑FZ dated 08.02.1998 “On Limited Liability Companies”.

Federal Law No. 402-FZ dated December 6, 2011, “On Accounting”;

Federal Law No. 167-FZ dated December 15, 2001, “On Compulsory Pension Insurance in the Russian Federation”;

other regulatory legal acts regulating relations related to the Operator’s activities.

3.2. The legal basis for the processing of personal data also includes:

  • the charter of LLC “RDS”;
  • contracts concluded between the Operator and the subjects of personal data;
  • consent of the subjects of personal data to the processing of their personal data.

4. Purposes of collecting personal data

4.1. The processing of personal data is limited to achieving specific, predetermined and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

4.2. Only personal data that meets the purposes of its processing is subject to processing.

4.3. The Operator processes personal data for the following purposes:

  • ensuring compliance with the Constitution of the Russian Federation, federal laws and other regulatory legal acts of the Russian Federation, including labour, tax and pension legislation of the Russian Federation;
  • assisting employees in finding employment, obtaining education and career advancement, ensuring the personal safety of employees, monitoring the quantity and quality of work performed, ensuring the safety of property;
  • selecting personnel (job applicants) for vacant positions at the Operator, including attracting and selecting candidates for employment with the Operator.

The organization of registering employees for individual (personalized) accounting in the compulsory pension insurance system;

filling out and submitting the required reporting forms to the executive authorities and other authorized organizations;

maintaining personnel and accounting records;

ensuring the completion of introductory, industrial, or pre‑graduation practical training based on an agreement with the educational institution;

processing applications, inquiries, and requests received via the website forms, as well as by phone and email, including preparing and sending commercial offers.

Preparation, conclusion, and execution of civil law contracts, including contracts for the supply of spare parts, repair, and maintenance of machinery and equipment;

promotion of goods, works, and services on the market;

ensuring the access control regime to the Operator’s territory.

Ensuring information security and the stable operation of the Operator’s information systems, including the prevention, detection, and investigation of incidents and leaks of confidential information, personal data, trade secrets, intellectual property, and other information protected by law, as well as protecting property interests, monitoring employees’ compliance with their job duties and adherence to the rules of the internal labour regulations within the corporate information systems, recording and analysing labour discipline, conducting internal investigations into recorded incidents and violations;

conducting meetings, including audio recording and automatic speech transcription for the purposes of logging and documenting the decisions made.

The creation and publication of corporate materials, including the posting of photographs and video recordings of employees on the Operator’s official website, on social media, on the internal portal, in advertising and informational brochures, presentations and other materials aimed at promoting services, building a positive image and informing clients and partners;

the Operator’s participation in constitutional, civil, administrative, criminal proceedings, and proceedings in arbitration courts;

enforcement of a court order;

providing access to the Operator’s website.

4.4. The processing of employees’ personal data may be carried out solely for the purpose of ensuring compliance with laws and other regulatory legal acts.

5. The scope and categories of personal data being processed, and the categories of Personal Data Subjects.

5.1. The content and scope of the personal data being processed must correspond to the stated processing purposes provided for in Section 4 of this Policy. The personal data being processed must not be excessive in relation to the stated purposes of their processing.

5.2. The Operator may process the personal data of the following categories of Personal Data Subjects:

5.2.1. Candidates for employment with the Operator:

  • surname, first name, patronymic;
  • gender;
  • citizenship;
  • date and place of birth;
  • contact details: details of the identity document, phone number, email address;
  • information about education, work experience, qualifications;
  • other personal data provided by candidates in their resumes and cover letters.

5.2.2. Employees and former employees of the Operator:

  • surname, first name, patronymic;
  • gender;
  • citizenship;
  • date and place of birth;
  • image (photo);
  • details of the identity document;
  • registered address;
  • actual address of residence;
  • contact details;
  • individual taxpayer number (ITN);
  • social insurance number of the individual account (SNILS);
  • information about education, qualifications, professional training and professional development;
  • marital status, presence of children, family relationships.

information about employment, including the presence of incentives, awards, and (or) disciplinary penalties;

data on marriage registration;

information on military registration;

information on disability;

information on alimony withholding;

information about income from the previous place of employment;

other personal data provided by employees in accordance with the requirements of labor legislation..

5.2.3. Family members of the Operator’s employees:

  • last name, first name, patronymic;
  • degree of kinship;
  • year of birth;
  • other personal data provided by employees in accordance with the requirements of labor legislation.

5.2.4. Clients and counterparties of the Operator (individuals):

  • last name, first name, patronymic;
  • date and place of birth;
  • details of the identity document;
  • address of registration at the place of residence;
  • contact details;
  • position;
  • individual taxpayer number (TIN);
  • bank account number;
  • Other personal data provided by clients and counterparties (individuals) that is necessary for the conclusion and execution of civil law contracts.

5.2.5. Representatives (employees) of the Operator’s clients and counterparties (legal entities):

  • last name, first name, patronymic;
  • details of the document удостоверяющего identity;
  • contact details;
  • position;
  • other personal data provided by representatives (employees) of clients and counterparties that is necessary for the conclusion and execution of contracts.

5.3. The Operator processes biometric personal data (information that characterizes a person’s physiological and biological characteristics, on the basis of which their identity can be established) in accordance with the legislation of the Russian Federation.

5.4. The Operator does not process special categories of personal data related to race, national origin, political views, religious or philosophical beliefs, health status, or intimate life, except in cases provided for by the legislation of the Russian Federation.

6. Procedure and conditions for processing personal data

6.1. The Operator processes personal data in accordance with the requirements of the legislation of the Russian Federation.

6.2. The processing of personal data is carried out with the consent of the Subjects of Personal Data to the processing of their personal data, as well as without such consent in cases provided for by the legislation of the Russian Federation.

6.3. The Operator carries out both automated and non‑automated processing of personal data.

6.4. Employees of the Operator whose job duties include the processing of personal data are allowed to process personal data.

6.5. Personal data is processed by:

  • obtaining personal data in oral and written form directly from the Subjects of Personal Data, including through forms on the Operator’s website;
  • obtaining personal data from publicly available sources;
  • entering personal data into the Operator’s logs, registers and information systems;
  • using other methods of processing personal data.

1.6. Disclosure to third parties and distribution of personal data are not permitted without the consent of the Personal Data Subject, unless otherwise provided for by federal law.

6.7. The transfer of personal data to investigative and inquiry bodies, to the Federal Tax Service, the Social Fund of Russia (SFR), and other authorized executive authorities and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.

6.8. The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, dissemination, and other unauthorized actions, including:

  • identifies threats to the security of personal data during its processing;
  • adopts local regulatory acts and other documents regulating relations in the field of processing and protection of personal data;
  • designates persons responsible for ensuring the security of personal data in the Operator’s structural units and information systems;
  • creates the necessary conditions for working with personal data.

organizes the accounting of documents containing personal data;

organizes work with information systems in which personal data is processed;

stores personal data under conditions that ensure its safety and prevent unlawful access to it;

organizes training for the Operator’s employees who process personal data.

6.9. The Operator stores personal data in a form that allows identifying the Subject of Personal Data for no longer than required by the purposes of processing, unless the period for storing personal data is established by federal law or a contract. The detailed procedure for storing and destroying personal data is set out in Section 9 of this Policy.

6.10. When collecting personal data, including through the information and telecommunications network Internet, the Operator ensures the recording, systematization, accumulation, storage, clarification (update, modification), and extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except in cases specified in the Law on Personal Data.

6.11. The Operator does not carry out cross‑border transfer of personal data. All personal data is processed and stored within the territory of the Russian Federation.

6.12. Use of web analytics services:

For the purpose of analyzing traffic, improving the quality of user service, and the functioning of the website: https://rockdrilling.ru/en, the Operator uses a third‑party web analytics service, Yandex Metrica.

The specified service may collect and process anonymized technical data about users’ actions on the Operator’s website (cookies, IP address, device and equipment parameters, software used, external sources of traffic to the website, including backlinks, access time, session identifier, actions on pages, communication channels, and the User’s behavior on the website, etc.) in accordance with the privacy policy of the service owner.

You can review the privacy policy of Yandex LLC at: https://yandex.ru/legal/confidential.

The processing of such data is carried out exclusively in an anonymized form and is used for analytical and statistical purposes. The user can at any time limit or disable the use of cookies through the browser settings, as well as through the cookie management banner on the website. For more details, see the Cookie Consent.

6.13. Transfer of personal data to third parties

The Operator transfers personal data to the following third parties:

Third party:

The purpose of data transfer:

Limited Liability Company “YANDEX”, INN 7736207543, address: 119021, Moscow, Lev Tolstoy Street, building 16

Collection and analysis of statistical data to improve the operator’s website performance (Yandex Metrica service)

Limited Liability Company “VK”, INN 7743001840, address: 125167, Moscow, Leningradsky Prospekt, building 39 79

Collection and analysis of statistical data, promotion of goods, works and services on the market

Limited Liability Company “Internet‑Pro” (NetAngels service), INN 6671142678, OGRN 1036604026040, address: 620026, Sverdlovsk Region, Yekaterinburg, Tveritina Street, house 34

Providing hosting services to the Operator — hosting and storing the Operator’s website and related databases on the technical site of the hosting provider located in the Russian Federation.

Persons who process the personal data of the Personal Data Subject on behalf of the Operator are obliged to comply with the principles and rules for processing personal data provided for by the legislation of the Russian Federation, to maintain the confidentiality of personal data and to ensure its security.

6.14. Personal data is processed in personal data information systems, the list of which is approved by an order of the Operator’s sole executive body. The list of information systems for personal data is kept by the person responsible for organizing the processing of personal data and is subject to updating.

All information systems for personal data used operate on the territory of the Russian Federation. Measures to ensure the security of personal data are implemented in accordance with Government Decree No. 1119 dated November 1, 2012, “On Approval of Requirements for the Protection of Personal Data When It Is Processed in Information Systems for Personal Data” and Order of the FSTEC of Russia No. 21 dated February 18, 2013, “On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data When It Is Processed in Information Systems for Personal Data.” The level of protection is established based on categorization.

7. Basic rights and obligations of the Operator

7.1. The Operator has the right to:

  • independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided for by federal laws;

delegate the processing of personal data to another person with the consent of the Personal Data Subject, unless otherwise provided for by federal law, on the basis of an agreement concluded with that person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules for processing personal data provided for in the Law on Personal Data, to maintain the confidentiality of personal data, and to take the necessary measures to ensure compliance with the obligations provided for in the said law; to obtain reliable information and/or documents containing personal data from the Data Subject for the purposes of processing specified in this Policy.

In the event that the Subject of Personal Data withdraws their consent to the processing of personal data, or submits a request to stop the processing of personal data, the Operator may continue to process personal data without the Subject’s consent only if there are grounds specified in the Personal Data Law.

7.2. The Operator is obliged to:

  • organize the processing of personal data solely for the purposes specified in this Policy, in accordance with the current legislation of the Russian Federation;
  • provide the Subject of Personal Data, upon their request, with information regarding the processing of their personal data.

to respond to appeals and requests from the Subject of Personal Data and their legal representative in accordance with the requirements of the Personal Data Law;

to provide the authorized body responsible for protecting the rights of Subject of Personal Data (Roskomnadzor) with the necessary information at the body’s request within the timeframes established by law;

to take legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data.

cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in accordance with the procedure and in cases provided for by the Law on Personal Data;

fulfill other obligations provided for by the Law on Personal Data..

Liability for violating the requirements of the legislation of the Russian Federation and the Operator’s regulatory acts in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.

8. Rights and Obligations of the Personal Data Subject

8.1. The Personal Data Subject has the right to:

receive information regarding the processing of their personal data, except in cases provided for by federal laws. The Operator shall provide the Personal Data Subject with the information in an accessible form, and the information shall not contain personal data relating to other Personal Data Subjects, except in cases where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law.

to require the Operator to clarify their personal data, block it, or delete it if the personal data is incomplete, outdated, inaccurate, obtained illegally, or not necessary for the stated purpose of processing, as well as to take the measures provided for by law to protect their rights;

to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;

To withdraw consent to the collection, processing, dissemination in publicly available sources, transfer to third parties, and cross‑border transfer of personal data, except in cases provided for in paragraph 2 of Article 8 of the Personal Data Law. The withdrawal of consent is sent by the Personal data Subject to the Operator's address: 623704, Sverdlovsk region, Berezovsky island, Berezovsky, Komsomolskaya str., 19, or to the email address: ps@rockdrilling.ru ;

to appeal to the authorized body for the protection of the rights of Personal data Subjects (Roskomnadzor) or in court against the actions or omissions of the Operator, if he considers that that the latter processes his personal data in violation of the requirements of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" or otherwise violates his rights and freedoms;

to request full or partial anonymization (hiding) of their personal data published on the Operator’s website: https://rockdrilling.ru/en;

to exercise other rights provided for by the legislation of the Russian Federation.

8.2. The subject of personal data is obliged to:

  • ensure the accuracy of the personal data provided to the Operator, which is necessary for the purposes of processing specified in this Policy;
  • inform the Operator about any updates (refinements, changes) to their personal data.

9. Updating and correcting personal data. Responses to requests from data subjects. Deletion and destruction of personal data

9.1. Procedure for updating and correcting personal data:

9.1.1. If inaccurate personal data is identified when the Subject of Personal Data or their representative contacts the Operator, or at their request or at the request of Roskomnadzor, the Operator shall block the personal data relating to this Subject of Personal Data from the moment of such contact or receipt of the specified request for the duration of the verification, provided that blocking the personal data does not infringe upon the rights and legitimate interests of the Subject of Personal Data or third parties.

9.1.2. If the inaccuracy of the personal data is confirmed, the Operator, based on the information provided by the Subject of Personal Data or their representative, or by Roskomnadzor, or on the basis of other necessary documents, clarifies the personal data within seven working days from the date such information is submitted, and lifts the blocking of the personal data.

9.2. Confirmation of the fact that the Operator processes personal data, the legal grounds and purposes for processing personal data, as well as other information specified in Part 7 of Article 14 of the Personal Data Law, shall be provided by the Operator to the Data Subject or their representative upon request or upon receiving a request from the Data Subject or their representative.

The provided information does not include personal data relating to other Data Subjects, except in cases where there are lawful grounds for disclosing such personal data.

The request must contain the following information:

  • the series and number of the main identity document of the Personal Data Subject or his representative, information on the date of issue of the specified document and the issuing authority;
  • information confirming the Personal Data Subject's participation in the relationship with the Operator (contract number, date of conclusion of the contract, conditional designation and (or) other information) or information otherwise confirming the fact of personal data processing by the Operator;
  • signature of the Personal Data Subject or his representative.

The request may be submitted in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.

If the personal data subject’s appeal (request) does not contain all the necessary information in accordance with the requirements of the Law on Personal Data, or the subject does not have the right to access the requested information, a reasoned refusal is sent to them.

The right of the Subject of Personal Data to access their personal data may be restricted in accordance with Part 8 of Article 14 of the Law on Personal Data, including if the Subject of Personal Data’s access to their personal data violates the rights and legitimate interests of third parties.

9.3. Procedure for ceasing the unlawful processing of personal data:

9.3.1. If unlawful processing of personal data is detected in response to an inquiry (request) from the Personal Data Subject or their representative, or from Roskomnadzor, the Operator shall block the unlawfully processed personal data relating to that Personal Data Subject from the moment of such inquiry or receipt of the request for the period of the verification.

9.3.2. If the fact of unlawful processing of personal data is confirmed, the Operator shall, within a period not exceeding three business days from the date of such detection, cease the unlawful processing of personal data or ensure the cessation of such unlawful processing. If it is impossible to ensure the lawfulness of the processing of personal data, the Operator shall destroy such personal data or ensure their destruction within a period not exceeding ten business days from the date of detection of unlawful processing of personal data.

9.4. Procedure for the destruction of personal data by the Operator:

9.4.1. The Operator shall destroy personal data in the following cases and within the established timeframes:

  • upon achievement of the purpose of processing personal data or loss of the need to achieve it — within thirty days;
  • At the request of the Subject of Personal Data or their representative, upon providing confirmation that the personal data was obtained illegally or is not necessary for the stated purpose of processing — within seven working days;
  • upon the Subject of Personal Data revoking their consent to the processing of their personal data, if their retention for the purpose of processing is no longer required — within thirty days;
  • upon the expiration of the storage period for documents containing personal data — within thirty days.

9.4.2. When the purpose of processing personal data is achieved, as well as in the event that the Subject of Personal Data revokes consent to the processing of personal data, the data must be destroyed, unless otherwise provided for in a contract or other agreement with the Subject of Personal Data, or the Operator is not entitled to process the data without the Subject of Personal Data’s consent on grounds provided for by the Law on Personal Data or other federal laws.

9.4.3. The destruction of personal data is carried out by a commission established by order of the Operator’s head.

9.4.4. The methods for destroying personal data are established in the Operator’s local regulatory acts.

9.4.5. Personal data is removed from the website on the basis of a written request from the Subject of Personal Data or their representative, or from Roskomnadzor, including in the form of an electronic document signed with an electronic signature in accordance with the legislation of the Russian Federation.

10. Final Provisions

10.1. This Personal Data Processing Policy was approved by Order No. 22 of the Manager of LLC “RDS” dated 02.09.2026 and is valid indefinitely until a new version of the Policy comes into force.

10.2. If the legislation of the Russian Federation in the field of personal data protection changes, the Operator adopts a new version of the Policy taking into account the changes. Until that moment, the Policy is valid insofar as it does not contradict the current legislation of the Russian Federation.

10.3. The following contact details may be used to contact the Operator:

  • Phone: +7 (902) 258 2075;
  • Email address: ps@rockdrilling.ru;
  • Postal address: 623704, Sverdlovsk Oblast, Berezovsky Municipal District, Berezovsky City, Komsomolskaya Street, 19.

Other documents: