Политика обработки персональных данныхPrivacy policy

This English translation is provided for information and convenience. In the event of any discrepancy between the Russian and English versions, the Russian version shall prevail.

1. General provisions

This Privacy Policy (the “Policy”) sets out the procedure for processing personal data and the measures taken to ensure their security. It covers personal data obtained by MN Medical Limited Liability Company (the “Operator”) through the use of the mnmedical.ru website (the “Website”) and in reviewing enquiries submitted through it.

The Policy has been developed in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable laws and regulations of the Russian Federation.

The Policy applies to visitors to the Website and to persons submitting enquiries through the Website form, including representatives of organisations. It is publicly available. A link to the Policy is provided on the enquiry form page.

Consent to the processing of data submitted through the form is given separately from this Policy. Reading this Policy does not in itself constitute consent.

2. Information about the Operator

Full name: MN Medical Limited Liability Company (ООО «МН Медикал»).
Taxpayer Identification Number (INN): 7717762527.
Tax Registration Reason Code (KPP): 771701001.
Primary State Registration Number (OGRN): 1137746837810.
Address: Office 1011, 101 Prospekt Mira, Building 1, Moscow, 129085, Russia.
Telephone: +7 495 617-61-86.
Email for enquiries, including personal data matters: info@mnmedical.ru.

3. Key terms

Personal data means any information relating directly or indirectly to an identified or identifiable natural person.

Personal data processing means any action or set of actions performed with personal data, with or without the use of automated means, including collection, recording, organisation, accumulation, storage, rectification, retrieval, use, transfer, blocking, deletion and destruction.

User means a natural person who visits the Website or submits an enquiry through the Website form, including a person acting on behalf of an organisation.

4. Data processed

4.1. When submitting an enquiry through the Website form, the User may provide:

• their name;
• the name of the organisation they represent;
• a telephone number and/or email address;
• the selected area and subject of the enquiry;
• the text of the message and any other information voluntarily included in it.

The name of the organisation is processed as part of the enquiry; the name of a legal entity does not in itself constitute the personal data of a natural person.

To confirm that consent has been obtained, records of its provision may be retained, including the date, time and version of the consent text.

4.2. To ensure the operation and security of the Website, technical data may be processed: IP address, browser and device information, the date and time of access, the address of the requested page and information about technical errors. The scope of such data is determined by the actual operation of the server software.

No web analytics services are used on the Website.

4.3. The Operator does not request special categories of personal data through the Website form, including health data, or biometric personal data. Please do not include in enquiries any patient information, medical records or other data not required to discuss equipment or servicing.

5. Purposes and legal bases of processing

5.1. Reviewing enquiries and communicating with the User.

Purpose: reviewing enquiries about equipment supply, implementation, training and servicing; preparing a response, proposal or presentation materials; and further communication regarding the enquiry.

Categories of data subjects: Users who have submitted an enquiry, including representatives of organisations.

Data: the information listed in clause 4.1, to the extent necessary to review the specific enquiry.

Legal basis: the User’s consent to personal data processing.

Processing continues until the enquiry has been reviewed and the related communication has been completed, or until consent is withdrawn, unless there are other lawful grounds for continued processing.

5.2. Preparation, conclusion and performance of contracts.

If an enquiry leads to the preparation or conclusion of a contract, the necessary data may be processed for the purposes of contractual dealings and compliance with legal requirements.

Categories of data subjects: natural persons who are parties to contractual relations and representatives of counterparty organisations.

Data: name, contact details, information about the organisation represented and correspondence concerning the subject matter of the contract, to the extent necessary.

The legal basis for processing may be consent, the performance of obligations imposed by law and other applicable grounds under Article 6 of Federal Law No. 152-FZ. The ground relating to the conclusion or performance of a contract with the data subject applies only where the data subject is a party to, a beneficiary under or a guarantor of that contract. Acting as a representative of an organisation does not in itself make the User a party to that organisation’s contract.

Processing and retention periods are determined by the purposes of the contractual dealings and by applicable legal requirements, including document retention requirements.

5.3. Ensuring the operation and security of the Website.

Purpose: providing access to the Website, detecting technical errors, and preventing unauthorised access and misuse.

Categories of data subjects: visitors to the Website.

Data: the technical information referred to in clause 4.2, to the extent necessary for these purposes.

Legal basis: the exercise of the rights and legitimate interests of the Operator, provided that the rights and freedoms of Users are not infringed, in accordance with clause 7 of Part 1 of Article 6 of Federal Law No. 152-FZ.

Retention periods for technical logs are set by the Operator in its internal documents and server software settings, based on the needs of security and troubleshooting. Logs are not retained for longer than necessary for these purposes.

6. Consent to personal data processing

Before submitting an enquiry, the User reads the separate document “Consent to Personal Data Processing”, available via a link next to the relevant form field, and gives consent by selecting that field themselves.

The consent field must not be pre-selected. A form for which consent is the legal basis for processing is submitted only after consent has been given.

The Operator ensures that the fact of consent and the content of the version accepted by the User can be confirmed.

The User may withdraw consent by writing to info@mnmedical.ru or to the Operator’s postal address. To help identify the enquiry, it is recommended to state the name and contact details used when submitting it.

7. Processing, storage and destruction of data

Processing is carried out both with and without the use of automated means. The Operator processes only the data necessary for the stated purposes.

Enquiries from the Website form are delivered directly to the corporate address info@mnmedical.ru, which is hosted on Yandex’s email service, without the use of intermediate enquiry storage services. Enquiries are reviewed manually by authorised employees of MN Medical LLC at the company’s office.

When collecting personal data of citizens of the Russian Federation, the Operator ensures compliance with the requirements of Part 5 of Article 18 of Federal Law No. 152-FZ on the use of databases located in the Russian Federation.

Applicants’ personal data are not disclosed to equipment manufacturers. The content of enquiries is not made publicly available and is not used for marketing mailings under this Policy.

Providers of services that support the operation of the Website and corporate email may process data to the extent necessary to provide those services, on the grounds provided for by law and by contract. Where processing is entrusted to another person, the Operator ensures compliance with the requirements of Article 6 of Federal Law No. 152-FZ. Data may be provided to public authorities in the cases and in the manner prescribed by law.

Data are stored for periods corresponding to the purposes set out in section 5. Once the purposes of processing have been achieved or consent has been withdrawn, the Operator ceases processing and ensures that the data are destroyed within the periods prescribed by law, unless there are other lawful grounds for continued processing and storage.

Destruction is carried out by deleting electronic records and messages and, where paper records exist, by a method that prevents recovery of the personal data they contain. Where data are processed on the Operator’s behalf, the Operator ensures that the relevant person ceases processing and destroys the data in the cases provided for by law. Destruction is documented in the manner prescribed by law.

8. User rights

The User has the right to:

• obtain information about the processing of their personal data;
• request the rectification, blocking or destruction of data that are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purposes;
• withdraw consent to personal data processing;
• request that processing be stopped in the cases provided for by law;
• appeal against the actions or inaction of the Operator to Roskomnadzor or in court.

To exercise these rights, a request may be sent to info@mnmedical.ru or to the Operator’s postal address. The Operator considers requests within the time limits and in the manner established by Federal Law No. 152-FZ and, where necessary, requests information to confirm the identity of the applicant or the authority of their representative.

Withdrawal of consent does not preclude continued processing where another lawful basis exists.

9. Personal data protection measures

The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions.

These measures include appointing a person responsible for organising personal data processing, establishing access and processing rules, restricting access to authorised employees, ensuring confidentiality, using the necessary security tools and internal monitoring of compliance with the established requirements.

10. Storage of user settings

To remember the selected language, the Website uses the browser’s local storage (localStorage). The setting is stored on the User’s device. The User can delete it by clearing the Website’s data in the browser settings.

No web analytics services or advertising tracking systems are used on the Website.

11. Final provisions

The Operator may amend this Policy. The current version is published on the Website with its date and takes effect upon publication, unless otherwise specified in it.

An amendment to the Policy does not in itself extend the scope of consent previously given by the User. Where necessary, the Operator obtains new consent or ensures that another legal basis for processing provided for by law applies.

Questions about this Policy may be sent to info@mnmedical.ru.