Personal Data Processing Agreement
1. General Provisions
This Personal Data Processing Policy is developed in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by PROZHEKTOR Ltd (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for conducting its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy, personal and family secrecy.
1.2. This Operator's Policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://prozhektor.ru.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing equipment.
2.2. Blocking of personal data — temporary cessation of processing personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software for computers and databases, ensuring their availability on the internet at the network address https://prozhektor.ru.
2.4. Personal data information system — a combination of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine the ownership of personal data to a specific User or another subject of personal data without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with the use of automated means or without using such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or determinable User of the website https://prozhektor.ru.
2.9. Personal data permitted by the subject of personal data for distribution — personal data whose access is provided to an unlimited circle of persons 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 the manner provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://prozhektor.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publishing personal data in mass media, placing them in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in a personal data information system and/or physical carriers of personal data are destroyed.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain reliable information and/or documents containing personal data from the subject of personal data;
— in case of withdrawal of consent by the subject of personal data to the processing of personal data, as well as upon receipt of a request demanding cessation of personal data processing, the Operator may continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, upon their request, information concerning the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of subjects of personal data, upon request from this body, the necessary information within 10 days from the date of receiving such a request;
— publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.
4. Key Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand from the Operator clarification of their personal data, their blocking, or destruction in the event that personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as send a request demanding cessation of personal data processing;
— appeal to the authorized body for the protection of the rights of subjects of personal data or in a court of law against unlawful actions or inaction of the Operator when processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable information about themselves;
— notify the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another subject of personal data without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing shall be processed.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption for the removal or clarification of incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing personal data, unless a storage period for personal data is established by federal law, a contract, a party to which, a beneficiary or guarantor of which is the subject of personal data. Processed personal data are destroyed or anonymized upon achieving the purposes of processing or in the event of loss of need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing |
informing the User by sending electronic emails |
Personal data |
· surname, first name, patronymic · email address · telephone numbers |
Legal grounds |
· charter (founding) documents of the Operator · Federal Law "On Information, Information Technologies and Protection of Information" dated 27.07.2006 No. 149-FZ |
Types of personal data processing |
· Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data · Sending informational emails to the email address · Automated transfer to the Yandex.Metrica service |
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or a law, for the implementation of functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a court decision, a decision of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of a contract, a party to which, or a beneficiary or guarantor of which, is the subject of personal data, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the implementation of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant objectives, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. Processing of personal data is carried out, access to which to an unlimited circle of persons is provided by the subject of personal data or at their request (hereinafter — publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully meet the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or in the event that the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator to the Operator's email address info@prozhektor.ru with the subject "Personal Data Update".
8.4. The term for processing personal data is determined by achieving the purposes for which the personal data were collected, unless another term is provided for by a contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@prozhektor.ru with the subject "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Restrictions established by the subject of personal data on transfer (except providing access), as well as on processing or conditions of processing (except obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing personal data, unless a storage period for personal data is established by federal law, a contract, a party to which, a beneficiary or guarantor of which is the subject of personal data.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent term of the subject of personal data, the withdrawal of consent by the subject of personal data, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without them.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities on the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such a notification is sent separately from the notification of intention to carry out personal data processing).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned, the corresponding information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email info@prozhektor.ru.
12.2. Any changes to the Operator's policy on processing personal data will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://prozhektor.ru/policy.