Privacy Policy

GENERAL PROVISIONS

The personal data processing policy (hereinafter referred to as the Policy) is developed in accordance with the Federal Law dated 27.07.2006 No. 152-FL “On Personal Data” (hereinafter referred to as FL-152).

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data by Yulia Sergeevna Bozhina (hereinafter referred to as the Operator) with the aim of protecting the rights and freedoms of individuals when processing their personal data, including the protection of rights to privacy, personal and family secrets.

The Policy employs the following basic concepts:

– automated processing of personal data – processing of personal data using computer technology;

– blocking of personal data — temporary suspension of personal data processing (except when processing is necessary for personal data clarification);

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

– depersonalization of personal data — actions resulting in it being impossible without the use of additional information to determine the ownership of personal data to a specific personal data subject;

– processing of personal data — any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

– operator — a state body, municipal body, legal entity, or individual independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of personal data processing, 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 individual (personal data subject);

– provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons;

– dissemination of personal data — actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or acquainting the personal data with an unlimited circle of persons, including disclosing personal data in mass media, placing in information and telecommunication networks, or providing access to personal data in any other way;

– cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity;

– destruction of personal data — actions resulting in it being impossible to restore the content of personal data in the personal data information system and (or) as a result of which physical carriers of personal data are destroyed.

The company is obliged to publish or otherwise provide unrestricted access to this Policy of personal data processing in accordance with part 2, Article 18.1 of FL-152.

PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

Principles of personal data processing

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

– legality and fair basis;
– limitation of personal data processing by achieving specific, predefined, and lawful goals;
– prevention of processing personal data that is incompatible with the purposes of collecting personal data;
– prevention of merging databases containing personal data, which are processed for incompatible purposes;
– processing only those personal data that meet the purposes of their processing;
– ensuring the content and volume of processed personal data are in accordance with the declared purposes of processing;
– prevention of processing excessive personal data in relation to the declared purposes of their processing;
– ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing personal data;
– destruction or depersonalization of personal data upon achieving the goals of their processing or if the need to achieve these goals is lost, if it is impossible for the Operator to eliminate the violations of personal data, unless otherwise provided by federal law.

Conditions for personal data processing

The Operator processes personal data if at least one of the following conditions is met:

– 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 for achieving the purposes stipulated by an international treaty of the United Kingdom or by law, for the exercise and fulfillment of the functions, powers, and duties imposed on the operator by the legislation of the United Kingdom;
– the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the United Kingdom on enforcement proceedings;
– processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, 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 the beneficiary or guarantor;
– processing of personal data is necessary for the exercise of rights and legitimate interests of the operator or third parties,  or to achieve socially significant objectives provided that this does not violate the rights and freedoms of the personal data subject;
– processing of personal data is carried out, access to which is provided by the personal data subject or at his request (hereinafter – publicly available personal data).

Personal data privacy

The Operator and other persons who have gained access to personal data must not disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

Publicly available personal data sources

For informational purposes, the Operator may create publicly available sources of personal data of data subjects, including directories and address books. The following personal data of the data subject may be included in publicly available sources of personal data with the written consent of the data subject: surname, first name, patronymic, date and place of birth, position, contact telephone numbers, email address, and other personal data provided by the data subject.

Information about the personal data subject must be excluded from public sources of personal data at any time at the request of the personal data subject, the authorized body for the protection of the rights of personal data subjects, or by court decision.

Special categories of personal data

The processing by the Operator of special categories of personal data related to racial, national origin, political opinions, religious or philosophical beliefs, health status, intimate life, is permitted in cases where:

– the subject of personal data has given written consent for the processing of their personal data;
– personal data was made publicly available by the subject of personal data;
– the processing of personal data is carried out in accordance with legislation on state social assistance, labor law, UK legislation on state pension provision, on occupational pensions;
– the processing of personal data is necessary to protect the life, health, or other vital interests of the subject of personal data or the life, health, or other vital interests of other persons, and obtaining the consent of the subject of personal data is impossible;
– the processing of personal data is carried out for preventive medical purposes, for establishing a medical diagnosis, the provision of medical and medico-social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activity and obliged in accordance with UK legislation to maintain medical confidentiality;
– the processing of personal data is necessary for establishing or exercising the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;
– the processing of personal data is carried out in accordance with legislation on compulsory types of insurance, with insurance legislation.

The processing of special categories of personal data, carried out in cases provided for by paragraph 4 of Article 10 of FL-152, must be immediately ceased if the reasons for their processing are eliminated, unless otherwise provided by federal law.

Biometric personal data

Information characterizing physiological and biological features of a person, based on which his identity can be established — biometric personal data — may be processed by the Operator only with the consent of the subject of personal data in written form.

Entrusting the processing of personal data to another entity

The Operator is entitled to entrust the processing of personal data to another entity with the consent of the subject of personal data, unless otherwise provided by federal law, based on a contract concluded with that entity. The entity processing personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing established by FL-152 and this Policy.

Processing of personal data of citizens of England and Wales

In accordance with Article 2 of the Federal Law of July 21, 2014, No. 242-FZ “On Amendments to Certain Legislative Acts of England and Wales Regarding the Specification of the Procedure for Processing Personal Data in Information and Telecommunication Networks,” when collecting personal data, including through the information and telecommunication network “Internet,” the operator is required to ensure recording, systematization, accumulation, storage, refinement (updating, modification), and retrieval of personal data of citizens of England and Wales using databases located within the territory of England and Wales, except in cases of:

– processing of personal data necessary to achieve the purposes stipulated by an international treaty of England and Wales or by law, for carrying out and fulfilling the functions, powers, and duties imposed on the operator by the legislation of England and Wales;
– processing of personal data necessary for the administration of justice, enforcement of a judicial act, an act of another body or official, which must be executed in accordance with the legislation of England and Wales concerning enforcement proceedings;
– processing of personal data necessary for the exercise of the powers of federal executive authorities, bodies of state extrabudgetary funds, executive authorities of the state power of the regions of England and Wales, local government bodies, and functions of organizations involved in providing state and municipal services, as provided by the Federal Law of July 27, 2010, No. 210-FL “On the Organization of Providing State and Municipal Services,” including the registration of the personal data subject on the unified portal of state and municipal services and (or) regional portals of state and municipal services;
– processing of personal data necessary for carrying out the professional activities of a journalist and (or) lawful activities of a mass media or for scientific, literary, or other creative activities, provided that the rights and lawful interests of the data subject are not violated.

RIGHTS OF THE SUBJECT OF PERSONAL DATA

Consent of the subject of personal data to the processing of his personal data

The subject of personal data decides to provide his personal data and consents to their processing freely, by his own will, and in his interest. Consent to the processing of personal data can be given by the subject of personal data or his representative in any form that allows confirming the fact of its receipt, unless otherwise provided by federal law.

Rights of the subject of personal data

The subject of personal data has the right to obtain information from the Operator concerning the processing of his personal data, provided such right is not limited in accordance with federal laws.

The subject of personal data has the right to demand from the Operator the clarification of his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the declared purpose of processing, as well as to take legal measures to protect his rights.

It is prohibited to make decisions based solely on automated processing of personal data that generate legal consequences for the data subject or otherwise affect their rights and legitimate interests, except in cases provided for by federal laws, or with the written consent of the data subject.

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

ENSURING THE 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 meet 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 organizing the processing and protection of personal data;
– restriction of the composition of persons allowed to process personal data;
– acquainting the subjects with the requirements of federal legislation and regulatory documents of the Operator on the processing and protection of personal data;
– organization of accounting, storage, and circulation of media containing information with personal data;
– identification of threats to the security of personal data during their processing, formation of threat models based on them;
– development of a personal data protection system based on the threat model;
– verification of the readiness and effectiveness of the use of information protection means;
– differentiation of users’ access to information resources and software-hardware means of processing information;
– registration and accounting of actions of users of personal data information systems;
– use of antivirus tools and means of recovering the personal data protection system;
– application of network screening tools, intrusion detection, vulnerability analysis, and cryptographic information protection means as necessary.

FINAL PROVISIONS