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regarding the processing of personal data
1.1. This Policy is implemented [__] ( hereinafter referred to as the “Operator”) in relation to the processing and protection of personal data of individuals (subjects of personal data) on the basis of Article 24 of the Constitution of the Russian Federation and Federal Law No. 152—FZ “On Personal Data”.
1.2. The Policy applies to all personal data that may be obtained by the Operator in the course of its activities, including the personal data of the Operator’s clients. The processing of personal data in the Operator is carried out in accordance with the following regulatory legal acts:
Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Federal Law “On Personal Data”);
Decree of the Government of the Russian Federation No. 687 dated September 15, 2008 “On Approval of the Regulation on the Specifics of Personal Data Processing carried out without the use of Automation tools”;
other regulatory legal acts of the Russian Federation and regulatory documents of the executive bodies of state power.
1.3. The purpose of the Policy is to provide the persons providing their personal data with the necessary information to assess what personal data is being processed by the Operator and for what purposes, what methods of ensuring their security are being implemented, as well as the establishment of basic principles and approaches to processing and ensuring the security of personal data in the Operator.
1.4. The Policy ensures the protection of the rights and freedoms of subjects when processing their personal data with or without the use of automation tools, and also establishes the responsibility of persons with access to personal data for failure to comply with the requirements governing the processing and protection of personal data.
1.5. Users using the Operator’s services and services, the services and services posted on the Operator’s website [policy_site] (hereinafter referred to as the Website), by informing the Operator of their personal data, including through the mediation of third parties, acknowledge their consent to the processing of personal data in accordance with this Policy. In case of disagreement with this Policy in general, as well as in case of disagreement with any point of this Policy, the User must refrain from using the Services.
1.6. The Operator receives and begins processing the Subject’s personal data from the moment of receiving his consent. Consent to the processing of personal data may be given by the Personal Data Subject in a form that allows to confirm the fact of obtaining consent, unless otherwise established by federal law.:
in writing and/or
by performing specific actions by the Personal Data Subject (checking the appropriate personal data entry form) when using the services on the Operator’s website, using feedback forms and accepting offers containing provisions on the processing of personal data in accordance with applicable law. In the absence of the consent of the Personal Data Subject to the processing of his personal data, such processing is not carried out.
1.7. Consent to the processing of personal data may be revoked by the personal data subject. If the personal data subject withdraws consent to the processing of personal data, the operator has the right to continue processing personal data without the consent of the personal data subject, provided there are grounds specified by applicable law.
1.8. This Policy may be changed by the Operator. The Operator has the right to make changes to this Policy at any time at its sole discretion, subject to prior notification to the User. When making changes in the current version, the date of the last update is indicated. The new version of the Policy takes effect from the moment it is posted on the web server, unless otherwise provided by the new version of the Policy.
1.9. This Policy applies only to User information obtained during the use of the Operator’s Services. The Operator does not control and is not responsible for the processing of User information by third-party websites to which the User can click on links available on the Operator’s official web server.
1.10. CONCEPTS USED IN THIS POLICY:
personal data – any information relating directly or indirectly to a specific or identifiable natural person (personal data subject)
personal data operator (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) performed with personal data.;
personal data processing is any action (operation) or set of actions (operations) with personal data performed with or without automation tools. The processing of personal data includes, among other things: collection; recording; systematization; accumulation; storage; clarification (updating, modification); extraction; use; transfer (distribution, provision, access); depersonalization; blocking; deletion; destruction.
automated personal data processing is 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.;
destruction of personal data – actions as a result of which it becomes 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;
personal data information system is a set of personal data contained in databases and information technologies and technical means that process them.;
The subject of personal data is an individual who is directly or indirectly identified or determined on the basis of Personal Data related to him.
2.1. For the purposes of this Policy, personal data means any information related directly or indirectly to a specific individual (personal data subject).
2.2. Depending on the subject of personal data, the Operator may process personal data of the following categories of subjects in order to carry out its activities and fulfill its obligations:
Customer data is information required by the Operator to fulfill its obligations under contractual relations with the Customer and to comply with the requirements of the legislation of the Russian Federation. This also includes data provided by potential clients, client representatives authorized to represent clients, managers and chief accountants of legal entities that are clients of the Operator, and persons who have concluded civil law contracts with the Operator for the provision of Operator services.; employees of the Operator’s partners and other legal entities that have contractual relations with the Operator, with whom the Operator’s employees interact as part of their activities.;
personal data of the Client provided during registration on the Website, as well as when using the services and forms of communication posted on the website;
personal data of other individuals who have consented to the processing of their personal data by the Operator, or individuals whose personal data processing is necessary for the Operator to achieve the goals provided for by an international treaty of the Russian Federation or a law, to exercise and fulfill the powers and duties assigned by the legislation of the Russian Federation;
personal data of individuals that are made publicly available by them, and their processing does not violate their rights and complies with the requirements established by the Legislation on Personal Data.
2.3. The Operator hereby informs the Personal Data Subjects that, within the framework provided on the Website by the Operator, subject to the consent of the Personal Data Subject to the processing of personal data, expressed by checking the appropriate box under the personal data collection form or clicking on the appropriate button, the following personal data may be processed: first name, last name, phone number; e-mail address (E-mail).
3.1. The Operator processes personal data to carry out its activities, including to provide services to Customers. The operator has the right to:
perform the functions assigned to the Operator by the legislation of the Russian Federation in accordance with the Federal Law “On Personal Data” and other laws and regulations of the Russian Federation, as well as the Charter and regulations of the Operator;
The Operator collects and stores the Client’s personal data necessary for the provision of services, the fulfillment of agreements and contracts, and the fulfillment of obligations to the Client.
3.2. The Operator processes personal data only if at least one of the following conditions is met::
the processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;
The processing of personal data is necessary to achieve the goals stipulated by law, to carry out and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.;
The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor.;
The processing of personal data is necessary to exercise the rights and legitimate interests of the Company or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.;
the processing of personal data is carried out, the access of an unlimited number of persons to which is provided by the subject of personal data or at his request.;
the processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.
3.3. Operators and other persons who have obtained access to personal data are required not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
3.4. The Operator may process personal data of personal data subjects for the following purposes::
to identify the personal data subject;
to contact the personal data subject, if necessary, including sending offers, notifications, information and requests, both related and unrelated to the provision of services, as well as processing applications, requests and requests from the Client;
improving the quality of services provided by the Operator.
3.5. Processing of special categories The Operator does not provide any personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.
4.1. The terms of personal data processing are determined based on the purposes of processing in the Operator’s information systems, in accordance with the term of the contract or agreement with the personal data subject.
4.2. The condition for termination of personal data processing may be the achievement of personal data processing goals in accordance with the terms of the agreement concluded between the Operator and the personal data subject, the expiration of the consent period or the withdrawal of the consent of the personal data subject to the processing of his personal data, as well as the identification of unlawful processing of personal data.
5.1. In order to achieve the objectives of Article 3 of this Policy, only those employees of the Operator who are required to do so in accordance with their official (labor) duties are allowed to process personal data. Access to other employees may be granted only in cases prescribed by law. The operator requires its employees to respect confidentiality and ensure the security of personal data during their processing.
5.2. The Operator has the right to transfer personal data to third parties in the following cases::
The personal data subject has explicitly expressed his consent to such actions;
The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law.
At the same time, all obligations to comply with the terms of this Policy in relation to the data received by the acquirer are transferred to the acquirer.
5.3. At the reasoned request of the authorized body and in accordance with the current legislation, the personal data of the subject may be transferred without his consent.:
in connection with the administration of justice to judicial authorities;
to the police, the Federal Security Service, the Prosecutor’s Office, and the Investigative Committee;
to other bodies and the Operator authorized by the current legislation and applicable legal norms in cases established in regulatory legal acts that are mandatory for the operator.
6.1. In the process of providing services, when carrying out on-farm activities, the Operator uses automated and non-automated processing of personal data.
6.2. The Operator has the right to entrust the Processing of Personal Data to another person with the consent of the Personal Data Subject, unless otherwise provided by the legislation of the Russian Federation, on the basis of a contract concluded with this person, the prerequisite of which is compliance by this person with the principles and rules of Personal Data Processing provided for by the Federal Law “On Personal Data”.
6.3. Personal Data is not disclosed to third parties and is not distributed in any other way without the consent of the Personal Data Subject, unless otherwise provided by the legislation of the Russian Federation.
6.4. Representatives of state authorities (including controlling, supervisory, law enforcement and other bodies) receive access to Personal Data processed by the Operator, to the extent and in accordance with the procedure established by the legislation of the Russian Federation.
6.5. Within the framework of personal data processing, the following rights are defined for the Personal Data Subject and the Operator.
6.5.1. The personal data subject has the right to:
to receive information regarding the processing of his personal data in the manner, form and time limits established by the Legislation on Personal Data;
to request clarification of their personal data, their Blocking or Destruction if the personal data is incomplete, outdated, unreliable, illegally obtained, is not necessary for the stated purpose of processing or is used for purposes not previously stated when the Personal Data Subject consents to the processing of personal data.;
take legal measures to protect their rights;
revoke your consent to the processing of personal data.
6.5.2. The Operator has the right to:
to process the personal data of the Personal Data Subject in accordance with the stated purpose;
require the Personal Data Subject to provide reliable personal data necessary for the performance of the contract, the provision of services, the identification of the Personal Data Subject, as well as in other cases provided for by the Legislation on Personal Data; restrict the access of the Personal Data Subject to his personal data if the Processing of personal data is carried out in accordance with the legislation on countering the legalization (laundering) of proceeds from crime and the financing of terrorism, the access of the Personal Data Subject to his personal data violates the rights and legitimate interests of third parties, as well as in other cases provided for byx by the legislation of the Russian Federation;
process publicly available personal data of individuals;
to process personal data subject to publication or mandatory disclosure in accordance with the legislation of the Russian Federation;
to entrust the processing of personal data to another person with the consent of the Personal Data Subject.
6.6. In case of confirmation of the inaccuracy of personal data or the illegality of their processing, personal data must be updated by the operator, and processing must be terminated.
6.7. Upon achieving the purposes of personal data processing, as well as in the case of revocation by the personal data subject of consent to their processing, personal data is subject to destruction if:
nothing else is provided for in the contract to which the personal data subject is a party, beneficiary or guarantor.;
The operator does not have the right to process personal data without the consent of the subject on the grounds provided for by the Federal Law “On Personal Data” or other federal laws.;
otherwise, no other agreement is provided for between the Operator and the subject of personal data.
6.8. The Operator is obliged to inform the personal data subject or his representative about the processing of such subject’s personal data upon the latter’s request.
6.9. The Operator also has other rights and bears other duties established by the Federal Law “On Personal Data”.