Personal Data Processing Policy
1. General provisions
This Personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "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 taken by AOT LLC (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website russianconcierge.ru/en.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary termination of the processing of personal data (except in cases where the processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address russianconcierge.ru/en.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine whether personal data belongs to a specific User or other personal data subject without using additional information.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, transfer) of personal data. access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and / or performs 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 related directly or indirectly to a specific or identifiable User of the website russianconcierge.ru/en.
2.9. Personal data authorized for distribution by the personal data subject — personal data that an unlimited number of persons have access to by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as personal data authorized for Distribution).
2.10. User — any visitor to the website russianconcierge.ru/en.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publishing personal data in the mass media, posting it in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign natural or legal person.
2.14. Destruction of personal data — any actions, as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
- receive reliable information and / or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data, as well as sends a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, 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 stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
- provide the personal data subject, upon request, with information related to the processing of his / her personal data;
- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within 10 days from the date of receipt of such a request;
- publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
- stop transmitting (distributing, providing, accessing) personal data, stop processing and destroy personal data in accordance with the procedure and cases provided for by the Law on Personal Data;
- perform other duties stipulated by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to::
- receive information related to the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- require the operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- make a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator when processing their personal data;
- to exercise other rights stipulated by the legislation of the Russian Federation.
4.2. Personal data subjects are required to::
- provide the Operator with reliable data about yourself;
- inform the Operator about updating (updating, changing) your personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, pre-defined and legitimate goals. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4.Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Redundancy of the 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, if necessary, their relevance in relation to the purposes of personal data processing is ensured. The Operator takes the necessary measures and / or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of processing personal data require, unless the period of storage of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized when the purposes of processing are achieved or when it is no longer necessary to achieve these goals, unless otherwise provided by federal law.
6. Purposes of personal data processing
7. Terms of personal data processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his / her personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or a law, and to perform the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6.Processing of personal data is carried out, access to which is granted to an unlimited number of persons by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the collection, storage, transfer and other types of 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 comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures that exclude access to personal data of 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 the current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator's email address ivanzakharov2009@gmail.com marked "Updating personal data".
8.4. The term of personal data processing is determined by the achievement of the purposes for which personal data was collected, unless another term is provided for in the contract or current legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address ivanzakharov2009@gmail.com marked "Revocation of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions imposed by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing of personal data in the 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 makes it possible to determine the subject of personal data, no longer than the purposes of processing personal data require, unless the period of storage of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the request to terminate the processing of personal data, as well as the identification of illegal processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transmits (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.
10. Cross-border transfer of personal data
10.1. The Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data) prior to the implementation of activities on cross-border transfer of personal data.
10.2.Before submitting the above-mentioned notification, the Operator is obliged to receive relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The operator and other persons who have obtained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User can get any clarifications on the issues of interest related to the processing of his personal data by contacting the Operator via e-mail ivanzakharov2009@gmail.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced with a new version.
12.3. The current version of the Policy is freely available on the Internet at russianconcierge.ru/privacy-policy-cn.
1. General provisions
This Personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "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 taken by AOT LLC (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website russianconcierge.ru/en.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary termination of the processing of personal data (except in cases where the processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address russianconcierge.ru/en.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine whether personal data belongs to a specific User or other personal data subject without using additional information.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, transfer) of personal data. access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and / or performs 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 related directly or indirectly to a specific or identifiable User of the website russianconcierge.ru/en.
2.9. Personal data authorized for distribution by the personal data subject — personal data that an unlimited number of persons have access to by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as personal data authorized for Distribution).
2.10. User — any visitor to the website russianconcierge.ru/en.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publishing personal data in the mass media, posting it in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign natural or legal person.
2.14. Destruction of personal data — any actions, as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
- receive reliable information and / or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data, as well as sends a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, 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 stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
- provide the personal data subject, upon request, with information related to the processing of his / her personal data;
- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within 10 days from the date of receipt of such a request;
- publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
- stop transmitting (distributing, providing, accessing) personal data, stop processing and destroy personal data in accordance with the procedure and cases provided for by the Law on Personal Data;
- perform other duties stipulated by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to::
- receive information related to the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- require the operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- make a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator when processing their personal data;
- to exercise other rights stipulated by the legislation of the Russian Federation.
4.2. Personal data subjects are required to::
- provide the Operator with reliable data about yourself;
- inform the Operator about updating (updating, changing) your personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, pre-defined and legitimate goals. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4.Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Redundancy of the 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, if necessary, their relevance in relation to the purposes of personal data processing is ensured. The Operator takes the necessary measures and / or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of processing personal data require, unless the period of storage of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized when the purposes of processing are achieved or when it is no longer necessary to achieve these goals, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing | informing the User by sending emails |
Personal data | last name, first name, middle name email address phone numbers |
Legal basis | the Operator's statutory (constitutive) documents agreements concluded between the operator and the subject of personal data |
Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data Sending informational emails to email addresses |
7. Terms of personal data processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his / her personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or a law, and to perform the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6.Processing of personal data is carried out, access to which is granted to an unlimited number of persons by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the collection, storage, transfer and other types of 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 comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures that exclude access to personal data of 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 the current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator's email address ivanzakharov2009@gmail.com marked "Updating personal data".
8.4. The term of personal data processing is determined by the achievement of the purposes for which personal data was collected, unless another term is provided for in the contract or current legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address ivanzakharov2009@gmail.com marked "Revocation of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions imposed by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing of personal data in the 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 makes it possible to determine the subject of personal data, no longer than the purposes of processing personal data require, unless the period of storage of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the request to terminate the processing of personal data, as well as the identification of illegal processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transmits (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.
10. Cross-border transfer of personal data
10.1. The Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data) prior to the implementation of activities on cross-border transfer of personal data.
10.2.Before submitting the above-mentioned notification, the Operator is obliged to receive relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The operator and other persons who have obtained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User can get any clarifications on the issues of interest related to the processing of his personal data by contacting the Operator via e-mail ivanzakharov2009@gmail.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced with a new version.
12.3. The current version of the Policy is freely available on the Internet at russianconcierge.ru/privacy-policy-cn.
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