Privacy policy
1. General provisions
1.1. This Personal Data Processing Policy (the "Policy") sets out how personal data of users of scrap.com.ru (the "Site") is processed and protected. It is drawn up in accordance with Russian Federal Law No. 152-FZ "On Personal Data" of 27 July 2006, as amended (the "Personal Data Law"), and other laws of the Russian Federation.
1.2. The personal data operator (the "Operator") is:
- Name: UVM-Vtortsvetmet LLC
- Taxpayer ID (INN): 6679177520
- Tax registration reason code (KPP): 667901001
- Registration No. (OGRN): 1246600036737
- Registered address: Office 12, 3 Novinskaya St., Yekaterinburg, Sverdlovsk Region, 620024
- Branch operating the Site: "Moscow West" branch, Bldg. 1, 1A Institutskaya St., Nakhabino, Krasnogorsk, Moscow Region, 143432
- E-mail for requests: info@scrap.com.ru
- Phone: +7 (925) 748-81-95
1.3. The Policy is publicly available. A link to it is placed on every page of the Site, including the mobile version.
1.4. The Policy applies to all personal data the Operator receives from Site users, whether processed automatically or manually.
2. Definitions
2.1. Personal data means any information relating to an identified or identifiable natural person (data subject).
2.2. Processing means any operation performed on personal data, with or without automation, including collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), depersonalisation, blocking, deletion and destruction.
2.3. Data subject means a natural person whose personal data is processed by the Operator.
2.4. Consent means a specific, informed, conscious and unambiguous permission of the data subject to process their personal data. On the Site, consent is given as a separate document, the Consent to Personal Data Processing, and is not included in other documents.
3. Legal grounds
3.1. The Operator processes personal data on the basis of:
- Federal Law No. 152-FZ "On Personal Data";
- Russian laws on handling ferrous and non-ferrous scrap metal and on accounting and taxation;
- the data subject's consent;
- contracts between the Operator and the data subject.
4. Purposes and data processed
4.1. The Operator processes personal data only for the following purposes:
| No. | Purpose | Data | Legal ground |
|---|---|---|---|
| 1 | Handling a request submitted through the Site form: calling back, quoting a price, arranging scrap delivery or collection | Name, phone number, type of metal and approximate weight, comment text (e.g. collection address) | Consent |
| 2 | Concluding and performing a scrap purchase contract, issuing an acceptance certificate, making payments | Full name, passport details, phone number, bank details or card number for payment; for company representatives, position and company details | Contract; scrap metal and accounting legislation |
| 3 | Keeping the Site working and secure, protecting the form from automated submissions | IP address, address of the page the request was sent from, technical cookies | Consent; the Operator's legitimate interest |
| 4 | Analysing Site traffic and improving the Site with Yandex Metrica | Cookies, IP address, browser and device details, referring and visited pages, actions on the Site (clicks, scrolling, cursor movements). The contents of the request form fields are not recorded | Consent expressed by continuing to use the Site after the cookie notice (clause 8.3) |
| 5 | Handling a job application: contacting the candidate, assessing the candidacy, inviting to an interview | Name, phone number, selected vacancy, comment, and CV details if the candidate sends a CV to the Operator's e-mail | Consent |
4.2. The Operator collects only the data needed for these purposes. The Site does not ask for an e-mail address, does not send marketing e-mails. A candidate may choose to send a CV to the Operator's e-mail; such data is processed for purpose 5.
4.3. Personal data is not processed for any other purposes.
4.4. The Operator does not process special categories of personal data (racial or ethnic origin, political views, religious beliefs, health, intimate life) or biometric data.
5. Data subjects
5.1. The Operator processes personal data of Site visitors, persons who submit a request through the Site, candidates applying for the Operator's vacancies, individual clients selling scrap metal to the Operator, and representatives of client and partner companies.
6. Processing procedure
6.1. Data provided in a request or job application is processed with the data subject's consent, given by ticking a separate checkbox before submitting the form, on the terms of the Consent to Personal Data Processing.
6.2. The Operator performs the following operations: collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), depersonalisation, blocking, deletion and destruction.
6.3. Processing is carried out with and without automation. Requests and job applications from the Site are stored in the Site's content management system and sent to the Operator's e-mail.
6.4. Data localisation. Personal data of Russian citizens is recorded, organised, accumulated, stored and updated in databases located in the Russian Federation. The Site and its database are hosted on servers in the Russian Federation. The Site does not load fonts, scripts or other resources from third-party servers abroad.
6.5. Retention. Data from a request that did not result in a contract is kept for no more than 1 year from receipt. Data of a candidate who was not hired is destroyed within 30 days of the decision. Documents on completed transactions, including acceptance certificates, are kept for the periods required by Russian law.
6.6. Once the purpose is achieved or consent is withdrawn, personal data is destroyed or depersonalised within 30 days unless the law sets a different period.
7. Transfer to third parties
7.1. The Operator may transfer personal data to third parties only with the data subject's consent, where required by Russian law (including requests from public authorities), or where necessary to perform a contract with the data subject: to the bank processing the payment and to the hosting provider whose servers in the Russian Federation host the Site; and, for traffic analytics, to Yandex LLC (Russian Federation), the operator of Yandex Metrica (clause 8.2).
7.2. The Operator does not transfer personal data outside the Russian Federation.
7.3. The Operator does not sell personal data or share it for purposes unrelated to serving the data subject.
8. Cookies
8.1. The Site uses two kinds of cookies: technical cookies required for it to work (the session identifier, protection of the request form against forged requests, service cookies of the content management system) and analytics cookies of Yandex Metrica.
8.2. The Site uses the Yandex Metrica web analytics service (Yandex LLC, Russian Federation): visit statistics, click maps and Session Replay (Webvisor), which records user actions on pages (clicks, scrolling, cursor movements). Session Replay does not record the contents of the request form fields (name, phone, weight, comment). The data is processed by Yandex LLC under its privacy policy and stored in the Russian Federation; the Operator receives aggregated statistics. The Site does not use advertising trackers.
8.3. On your first visit you see a notice about cookies and Yandex Metrica with a link to this Policy. By continuing to use the Site after this notice, you agree to the processing described in clauses 8.1-8.2.
8.4. You can opt out of analytics at any time by disabling cookies in your browser or installing the official Yandex Metrica opt-out add-on (yandex.com/support/metrica/general/opt-out.html). If you disable technical cookies, the request form may not work correctly.
8.5. On the Contacts page you can open a directions map from Yandex Maps (Yandex LLC, Russian Federation). The map is loaded only after you click "Show map". Yandex LLC then receives your IP address and technical browser data and may use its own cookies under its privacy policy. Until you click the button, no data is sent to Yandex Maps.
9. Rights of the data subject
9.1. You have the right to obtain information about the processing of your personal data; to demand that it be updated, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or no longer needed; to withdraw your consent at any time; and to appeal the Operator's actions to Roskomnadzor (the Russian data protection authority) or in court.
9.2. To exercise your rights, write to info@scrap.com.ru or send a letter to Bldg. 1, 1A Institutskaya St., Nakhabino, Krasnogorsk, Moscow Region, 143432.
9.3. The Operator replies within 10 working days of receiving the request. This period may be extended by no more than 5 working days, with the reasons explained to you.
9.4. After receiving a withdrawal of consent, the Operator stops processing and destroys the personal data, except where processing must continue by law.
10. Security measures
10.1. The Operator takes legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision and disclosure. In particular, it appoints a person responsible for personal data processing, limits access to requests to authorised staff in a password-protected site control panel, transmits data between your browser and the Site only over HTTPS, trains staff in data protection requirements and carries out internal compliance checks.
11. Final provisions
11.1. The Operator may amend this Policy. The current version is always available at scrap.com.ru/privacy/.
11.2. A new version takes effect when published on the Site unless stated otherwise.
11.3. For any questions about personal data processing, contact us: e-mail info@scrap.com.ru, phone +7 (925) 748-81-95, address: Bldg. 1, 1A Institutskaya St., Nakhabino, Krasnogorsk, Moscow Region, 143432.