This is a translation provided for convenience. In case of any discrepancy, the Russian version shall prevail.
1. General provisions
1.1. This Policy on the processing of personal data (the “Policy”) has been developed in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken by RBE LLC (the “Operator”) to ensure its security.
1.2. The Policy sets out the procedure for processing personal data and the measures to ensure the security of personal data on the Operator’s Website in order to comply with the legislation on the processing and protection of personal data. The purpose of this Policy is to protect the rights and freedoms of individuals when the Operator processes their personal data.
1.3. This Policy applies to all information that the Operator may obtain about Users through the Website. The Policy does not apply to third-party websites that a User may visit via links on the Website.
1.4. Operator details: RBE Limited Liability Company (OGRN 5147746269039, INN 7717798160), address: 1st Avtozavodsky proezd 4, bldg. 1, premises II, Moscow, 115280, Russia. E-mail for personal data enquiries: IT_Security@rbest.ru.
2. Definitions used in the Policy
2.1. Personal data means any information relating directly or indirectly to an identified or identifiable User of this Website.
2.2. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, with or without automation, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
2.3. Operator means a legal entity that, alone or jointly with others, organises and (or) carries out the processing of personal data and determines the purposes of processing, the scope of personal data to be processed and the actions (operations) performed with personal data.
2.4. Data subject means an individual to whom the personal data relates.
2.5. Website means the set of graphic and informational materials, computer programs and databases that make them available on the Internet at https://rbegroup.ru/ (and/or its subdomains).
2.6. User means any visitor of the Website.
3. Principles of personal data processing
3.1. The Operator processes personal data lawfully and fairly.
3.2. Processing of personal data is limited to specific, predetermined and legitimate purposes. Processing incompatible with the purposes of collection is not permitted.
3.3. Databases containing personal data processed for incompatible purposes are not combined.
3.4. Only personal data that meets the purposes of processing is processed.
3.5. The content and volume of the personal data processed correspond to the stated purposes. Excessive processing is not permitted.
3.6. The Operator ensures the accuracy, sufficiency and, where necessary, relevance of personal data to the purposes of processing, and takes measures to delete or correct incomplete or inaccurate data.
3.7. Personal data is stored in a form that permits identification of the data subject no longer than the purposes of processing require, unless the storage period is established by federal law or a contract. Personal data is destroyed or depersonalised once the purposes of processing have been achieved or are no longer needed, unless otherwise provided by federal law.
4. Purposes, scope, legal grounds and procedure of personal data processing
4.1. The legal grounds for the processing of personal data by the Operator are:
- Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and other regulations of the Russian Federation on personal data protection;
- the Labour Code of the Russian Federation;
- the data subject’s consent to the processing of their personal data;
- processing necessary for the exercise of the Operator’s rights and legitimate interests.
4.2. The Operator processes personal data for the following purposes:
4.2.1. Searching for and selecting candidates for vacancies.
- Data: surname, first name, patronymic, city of residence, phone number, e-mail address, CV file and other personal data provided by the data subject in the CV.
- Data subjects: job applicants.
- Ground: the data subject’s consent.
4.2.2. Contacting the User, consulting on the Operator’s services and replying to enquiries.
- Data: name, phone number, e-mail address.
- Data subjects: Website Users submitting enquiries.
- Ground: the data subject’s consent.
4.2.3. Contacting suppliers, reviewing incoming enquiries and cooperation proposals, consulting on cooperation with the Operator.
- Data: name, phone number, e-mail address, company name.
- Data subjects: Website Users submitting enquiries via the supplier form.
- Ground: the data subject’s consent.
4.2.4. Statistical analysis of Website traffic and improvement of the Website.
- Data: IP address, cookie identifier, browser and operating system information, access time, addresses of pages visited and actions on the Website.
- Data subjects: Website Users.
- Ground: the User’s consent to the use of cookies.
4.2.5. Sending the User information and advertising materials, news and individual offers.
- Data: surname, first name, patronymic (if any), e-mail address, technical data collected automatically when interacting with the mailing.
- Data subjects: Website Users who have consented to receive mailings.
- Ground: the data subject’s consent to receive advertising mailings.
5. Rights and obligations of the Operator
5.1. The Operator has the right to:
5.1.1. Receive reliable information and/or documents containing personal data from the data subject.
5.1.2. Continue processing personal data without the data subject’s consent after the consent is withdrawn, where the Personal Data Law provides legal grounds for doing so.
5.1.3. Determine independently the scope and list of measures necessary and sufficient to fulfil the obligations under the Personal Data Law.
5.2. The Operator is obliged to:
5.2.1. Provide the data subject, upon request, with information concerning the processing of their personal data.
5.2.2. Organise the processing of personal data in accordance with the legislation of the Russian Federation.
5.2.3. Respond to requests from data subjects and their legal representatives in accordance with the Personal Data Law.
5.2.4. Publish or otherwise provide unrestricted access to this Policy.
5.2.5. Take legal, organisational and technical measures to protect personal data against unauthorised or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions.
5.2.6. Stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the cases and manner provided by the Personal Data Law.
5.2.7. Fulfil other obligations provided by the Personal Data Law.
6. Rights of the data subject
6.1. The data subject has the right to:
6.1.1. Receive information concerning the processing of their personal data;
6.1.2. Demand clarification, blocking or destruction of their personal data if it is incomplete, outdated, inaccurate or unlawfully processed;
6.1.3. Withdraw their consent to the processing of personal data;
6.1.4. Appeal against unlawful actions or inaction of the Operator to the authorised body for the protection of data subjects’ rights or in court;
6.1.5. Exercise other rights provided by the legislation of the Russian Federation.
6.2. A data subject’s request is sent to the Operator by e-mail to IT_Security@rbest.ru or by post to the address specified in clause 1.4. The Operator responds within 10 (ten) working days of receipt; this period may be extended by no more than 5 (five) working days with a reasoned notice to the data subject.
7. Conditions of personal data processing
7.1. Personal data is processed with the data subject’s consent.
7.2. Processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or by law, or to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official subject to enforcement under the legislation of the Russian Federation.
7.4. Processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, or for entering into a contract at the data subject’s initiative or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data subject to publication or mandatory disclosure under federal law is processed.
8. Procedure for collection, storage, transfer and other processing of personal data
8.1. The Operator ensures the safety of personal data and takes the necessary legal, organisational and technical measures to protect it against unauthorised or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions.
8.2. The Operator may transfer personal data to third parties to whom it has entrusted the processing of personal data under a contract (Part 3 of Article 6 of the Personal Data Law), including the Website hosting provider. The transfer is made solely for the purposes specified in this Policy. The Operator obliges such processors to keep personal data confidential and ensure its security in accordance with the Personal Data Law.
8.3. If inaccuracies are found in personal data, the User may update it by sending a notice to the Operator at IT_Security@rbest.ru marked “Personal data update”.
8.4. The processing period is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by a contract or the legislation of the Russian Federation. Once the purpose is achieved or consent is withdrawn, personal data is destroyed within 30 days, unless otherwise provided by the Personal Data Law.
8.5. The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator at IT_Security@rbest.ru marked “Withdrawal of consent to the processing of personal data”.
8.6. The Operator ensures the confidentiality of personal data when processing it.
8.7. The Operator stores personal data in a form that permits identification of the data subject no longer than the purposes of processing require, unless the storage period is established by federal law or a contract.
8.8. Processing is terminated upon achievement of its purposes, expiry of the consent, withdrawal of consent by the data subject, or detection of unlawful processing.
8.9. The Operator is not responsible for the actions of third parties to whom personal data has been lawfully transferred in accordance with this Policy.
8.10. To ensure the proper operation of the Website, analyse its traffic and improve its functionality, the Operator uses cookies and the Yandex Metrica web analytics service (Yandex LLC, Russian Federation), including the Webvisor technology. Cookies are stored on the User’s device and technical data is collected automatically: IP address, cookie identifier, browser and operating system information, access time, addresses of pages visited and the User’s actions on the Website. This data is processed for statistical analysis of traffic, stored in the Russian Federation and is not used by the Operator to identify the User. The User may disable cookies in their browser settings at any time; however, some Website functions may then work incorrectly.
8.11. When collecting personal data, including via the Internet, the Operator records, systematises, accumulates, stores, clarifies (updates, modifies) and retrieves personal data of citizens of the Russian Federation using databases located in the Russian Federation.
9. Actions performed by the Operator with personal data
9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalises, blocks, deletes and destroys personal data.
9.2. The Operator processes personal data automatically, with or without receiving and/or transmitting the information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. The Operator does not carry out cross-border transfer of personal data.
10.2. Should a decision be made to transfer personal data across borders, the Operator will notify the authorised body for the protection of data subjects’ rights before the transfer begins, in accordance with Article 12 of the Personal Data Law.
11. Final provisions
11.1. The User may obtain any clarification on the processing of their personal data by contacting the Operator by e-mail at IT_Security@rbest.ru.
11.2. The current version of the Policy is freely available at https://rbegroup.ru/privacy-policy/.
11.3. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
Version of 2 October 2026.