Privacy Policy

Consent to the processing of personal data

The user, leaving a request on the site, accepts this Consent to the processing of personal data (hereinafter– Consent). Acting freely, by his will and in his interest, as well as confirming his legal capacity, the User gives his consent to the processing of his personal data with the following conditions:

1. This consent is Given to the processing of personal data, both without the use of automation, and with their use.

2. Consent is given to the processing of the following my personal data: Personal data that are not special or biometric: contact phone numbers; e-mail addresses; place of work and position; user data (location information; OS type and version; browser type and version; Device type and resolution of its screen; source from where the user came to the site; from what site or advertising; OS and Browser language; which pages opens and which buttons the user clicks; ip-address.

3. Personal data are not publicly available.

4. The purpose of processing of personal data: processing of incoming requests of individuals in order to provide advice; Analytics of the actions of an individual on the website and the functioning of the website; advertising and newsletters.

5. The basis for the processing of personal data is: article 24 of the Constitution of the Russian Federation; article 6 of the Federal law No152-FZ "on personal data"; the Charter of the Company; this consent to the processing of personal data.

6. In the course of processing personal data will be carried out the following steps: collecting; recording; systematization; accumulation; retention; clarification (updating, change); retrieval; use; transfer (distribution, granting, access); blocking; removal; destruction.

7. Personal data is processed until the individual unsubscribes from advertising and newsletters. Also, the processing of personal data may be terminated at the request of the subject of personal data. Storage of personal data recorded on paper is carried out in accordance with the Federal law No125-FZ "on archival business in the Russian Federation" and other normative legal acts in the field of archival business and archival storage.

8. Consent may be withdrawn by the personal data subject or his representative by sending a written application to the Company or his representative at the address specified at the beginning of this Consent.

9. In case of withdrawal of the personal data subject or his representative consent to the processing of personal data, the Company has the right to continue the processing of personal data without the consent of the personal data subject in the presence of the grounds specified in paragraphs 2-11 of part 1 of article 6, part 2 of article 10 and part 2 of article 11 of the Federal law No152-FZ "on personal data" of 27.07.2006.

10. This consent is valid all the time until the termination of the processing of personal data specified in paragraph 7 and paragraph 8 of this Consent.

Company policy regarding the processing of personal data

Rostov-on-don, 2018

1. GENERALITIES

2. THE PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

2.1 Principles of personal data processing

2.2 Условия обработки персональных данных

2.3 Confidentiality of personal data

2.4 Public sources of personal data

2.5 Special categories of personal data

2.6 Biometric personal data

2.7 Ordering the processing of personal data to another person

2.8. Processing of personal data of citizens of the Russian Federation

2.9. Cross-border transfer of personal data

3. RIGHTS OF THE DATA SUBJECT

3.1 Consent of the personal data subject to the processing of his / her personal data

3.2 Rights of the personal data subject

4. SECURITY OF PERSONAL DATA

5. FINAL PROVISION

1. GENERALITIES

The policy of personal data processing (hereinafter-the Policy) is developed in accordance with the Federal law of 27.07.2006. No. 152-FZ "on personal data" (hereinafter-FZ-152).

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in order to protect the rights and freedoms of man and citizen in the processing of his personal data, including the protection of rights to privacy, personal and family secrets.

The Policy uses the following basic concepts:

automated processing of personal data – processing of personal data by means of computer technology;

blocking of personal data - temporary termination of the processing of personal data (except if the processing is necessary to clarify personal data);

personal data information system - the set of personal data contained in the databases, and ensuring their processing of information technologies and technical means;

depersonalization of personal data - actions as a result of which it is impossible to determine the ownership of personal data to a particular personal data subject without using additional information;

personal data processing - 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 (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

operator - state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purpose of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;

personal data – any information relating directly or indirectly to a specific or identifiable natural person (personal data subject);

provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of persons; distribution of personal data-actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or at acquaintance with personal data of an unlimited number of persons, including disclosure of personal data in the media, placement in information and telecommunication networks or provision of access to personal data in any other way;

cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign natural or foreign legal entity;

destruction of personal data - actions as a result of which it is impossible to restore the content of personal data in the information system of personal data and (or) as a result of which the material carriers of personal data are destroyed.

The company shall publish or otherwise provide unrestricted access to this personal data processing Policy in accordance with part 2 of article 18.1. FZ-152.

2. THE PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

2.1 Principles of personal data processing

The processing of personal data by the Operator is based on the following principles:

- legality and fairness;

- limitations on the processing of personal data to achieve specific, pre-defined and legitimate purposes;

- prevention of personal data processing incompatible with the purposes of personal data collection;

- prevention of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

- processing only those personal data that meet the purposes of their processing;

- compliance of the content and volume of personal data processed with the stated purposes of processing;

- prevention of processing of personal data excessive in relation to the stated purposes of their processing;

- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;

- destruction or depersonalization of personal data on achievement of the purposes of their processing or in case of loss of need for achievement of these purposes, at impossibility of elimination by the Operator of the allowed violations of personal data if other is not provided by the Federal law.

2.2 Terms of personal data processing

The operator processes personal data in the presence of at least one of the following conditions:

- 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 objectives stipulated by an international agreement of the Russian Federation or the law, for the implementation and performance of the functions, powers and obligations imposed by the legislation of the Russian Federation on the operator;

- the processing of personal data is necessary for the administration of justice, the execution of a judicial act, the act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;

- the processing of personal data is necessary for the execution of the agreement to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of the agreement on the initiative of the personal data subject or the agreement under which the personal data subject will be a beneficiary or guarantor;

- 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;

- processing of personal data is carried out, access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter-public personal data);

- the processing of personal data subject to publication or mandatory disclosure in accordance with the Federal law.

2.3 Confidentiality of personal data

The operator and other persons who have received access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by Federal law.

2.4 Public sources of personal data

In order to provide information, the Operator may create publicly available sources of personal data of personal data subjects, including directories and address books. With the written consent of the personal data subject, the public sources of personal data may include his / her surname, name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data reported by the personal data subject.

Data on the subject of personal data shall be excluded at any time from public sources of personal data at the request of the subject of personal data, the authorized body for protection of the rights of subjects of personal data or by a court decision.

2.5 Special categories of personal data

Processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, sex life is allowed in cases where:

- the personal data subject has agreed in writing to the processing of his / her personal data;

- personal data is made publicly available by the subject of personal data;

- processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on pensions for state pensions, on labor pensions;

- processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject or the life, health or other vital interests of other persons and obtaining the consent of the personal data subject is impossible;

- the processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, provide medical and medical social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities and is obliged in accordance with the legislation of the Russian Federation to maintain medical secrecy;

- the processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;

- processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with the insurance legislation. Processing of special categories of personal data, carried out in the cases provided for in paragraph 4 of article 10 of the Federal law-152 shall be immediately terminated if the reasons for their processing were eliminated, unless otherwise provided by Federal law. Processing of personal data on criminal record can be carried out by the Operator only in cases and in the manner determined in accordance with Federal laws.

2.6 Biometric personal data

Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity-biometric personal data - can be processed by the Operator only with the consent of the subject of personal data in writing.

2.7 Ordering the processing of personal data to another person

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 Federal law, on the basis of a contract concluded with that person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided by the Federal law-152 and this Policy

2.8 Обработка персональных данных граждан Российской Федерации

According to article 2 of the Federal law of July 21, 2014 N 242-FZ "about modification of separate legal acts of the Russian Federation regarding refining of the order of processing of personal data in information and telecommunication networks" when collecting personal data, including by means of the information and telecommunication network "the Internet", the operator is obliged to provide record, systematization, accumulation, storage, clarification (updating, change), extraction of personal data of citizens of the Russian Federation with use of databases, - processing of personal data is necessary for the achievement of the purposes provided by the international Treaty of the Russian Federation or the law for implementation and performance of the functions, powers and duties assigned by the legislation of the Russian Federation to the operator;

- processing of personal data is necessary for execution of powers of Federal Executive authorities, bodies of the state off-budget funds, Executive bodies of the government of subjects of the Russian Federation, local governments and functions of the organizations participating in providing respectively the state and municipal services provided by the Federal law of July 27, 2010 N 210-FZ "About the organization of providing the state and municipal services», including registration of the personal data subject on the single portal of state and municipal services and (or) regional portals of state and municipal services;

- processing of personal data is necessary for the professional activities of a journalist and (or) legitimate activities of the media or scientific, literary or other creative activities, provided that the rights and legitimate interests of the subject of personal data are not violated.

2.9 Cross-border transfer of personal data

The operator is obliged to make sure that the foreign state, on the territory of which the transfer of personal data is supposed to be carried out, provides adequate protection of the rights of personal data subjects, before the beginning of such transfer.

Cross-border transfer of personal data on the territory of foreign States that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:

- availability of written consent of the personal data subject to cross-border transfer of his / her personal data;

- execution of the agreement to which the personal data subject is a party.

3. RIGHTS OF THE DATA SUBJECT

3.1 Consent of the personal data subject to the processing of his / her personal data

The personal data subject shall decide on the provision of his / her personal data and consent to their processing freely, by his / her will and in his / her interest. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form that allows to confirm the fact of its receipt, unless otherwise provided by Federal law.

3.2 Rights of the personal data subject

The personal data subject has the right to receive information from the Operator regarding the processing of his personal data, if such right is not limited in accordance with Federal laws. The personal data subject has the right to require the Operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights.

Processing of personal data for the purpose of promotion of goods, works, services on the market by means of direct contacts with the subject of personal data (potential consumer) by means of communication, as well as for political campaigning is allowed only with the prior consent of the subject of personal data.

The operator is obliged to immediately stop the processing of his / her personal data for the above purposes at the request of the personal data subject.

It is prohibited to make decisions on the basis of exclusively automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, except in cases provided for by Federal laws, or with the consent in writing of the subject of personal data.

If the personal data subject believes that the Operator processes his / her personal data in violation of the requirements of FZ-152 or otherwise violates his / her rights and freedoms, the personal data subject has the right to appeal against the actions or inaction of the Operator to the Authorized body for the protection of the rights of personal data subjects or in court.

The personal data subject has the right to protection of his / her rights and legitimate interests, including compensation for damages and (or) compensation for moral damage.

4. SECURITY OF PERSONAL DATA

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of Federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

- appointment of officials responsible for the organization of processing and protection of personal data;

- restriction of the composition of persons admitted to the processing of personal data;

- familiarization of subjects with the requirements of Federal legislation and regulatory documents of the Operator on processing and protection of personal data;

- organization of accounting, storage and circulation of media containing information with personal data;

- definition of threats to the security of personal data during their processing, formation on their basis of models of threats;

- development of a personal data protection system based on the threat model;

- verification of readiness and effectiveness of the use of information security tools;

- differentiation of users ' access to information resources and software and hardware information processing;

- registration and accounting of actions of users of information systems of personal data;

- the use of antivirus tools and means of restoring the system of protection of personal data;

- application in necessary cases of means of inter-network shielding, intrusion detection, security analysis and cryptographic protection of information;

- organization of access to the Operator's territory, protection of premises with technical means of personal data processing.

5. FINAL PROVISION

Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data.

Employees of the Operator who are guilty of violating the rules governing the processing and protection of personal data shall bear material, disciplinary, administrative, civil or criminal liability in accordance with the procedure established by Federal laws.