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Privacy and Personal Data Processing Policy
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) defines the general principles and procedure for processing personal data, as well as other data of Users and measures to ensure their security I P Afanasyeva Sofya Vladimirovna (TIN: 784 301 796 552) (hereinafter referred to as “Operator”).
TERMS AND DEFINITIONS
The Policy uses the following terms with the meanings below: Service is a set of software products owned by the Operator, including an Internet resource (website on the internet), located at the address of the main page: adsperformance.ru/ Personal data — any information relating to directly or indirectly a specific or identifiable individual (User);
User —an individual who gains access to the Service; Operator —I P Afanasyeva Sofya Vladimirovna (TIN: 784 301 796 552) independently or jointly with other persons organizing and (or) carrying out the processing of Personal Data (Data), as well as determining the purposes of processing Personal Data (Data), composition of Personal Data (Data) to be processed, actions (operations) performed with Personal Data (Data);
Messenger —an information system and (or) computer program that is intended and (or) used for the exchange of electronic messages exclusively between users of these information systems and (or) computer programs, in which the sender of the electronic message determines the recipient or recipients of the electronic message, it is not possible for Internet users to post public information on the Internet and transmit electronic messages to an indefinite number of persons;
Processing of Personal Data (Processing) - any action (operation) or set of actions (operations) performed with or without the use of automation tools with Personal Data (Data), including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data (Data); Automated processing of Personal data — Processing of personal data using computer technology;
Blocking of Personal Data —temporary termination of Processing of Personal Data (Data), except for cases when Processing is necessary to clarify Personal Data (Data); Destruction of Personal Data - actions as a result of which it is impossible to restore the content of Personal Data (Data) in the Personal Data Information System or as a result of which the material media of Personal Data (Data) are destroyed;
Confidentiality of Personal Data is the obligation of the Operator or other person who has access to the User’s Personal Data (Data) not to disclose to third parties and not to distribute Personal Data (Data) without the consent of the relevant User, unless otherwise provided by the Legislation;
The Operator’s database is a collection of information and data located in the Personal Data Information System for the purpose of storing Personal Data (Data) of Users and other information.
1. GENERAL PROVISIONS
1.1. This Policy regarding the Processing of Personal Data has been developed in accordance with the provisions of Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data”, other legislative and regulatory legal acts and defines the procedure for working with Personal Data ( Data) of Users and requirements for ensuring their security.
1.2. The processing of Personal Data by the Operator is carried out in accordance with the following principles: · legality and fair basis for the Processing of Personal Data. The Operator takes all necessary measures to comply with the requirements of the Legislation, does not process Personal Data (Data) in cases where this is not permitted by Law, does not use Personal Data (Data) to harm the User;
processing only those Personal Data (Data) that meet the pre-announced purposes of their Processing. Compliance of the content and volume of processed Personal Data (Data) with the stated purposes of processing. Preventing the Processing of Personal Data incompatible with the purposes of collecting Personal Data (Data), as well as excessive in relation to the stated purposes of their Processing;
ensuring the accuracy, sufficiency and relevance of Personal Data (Data) in relation to the purposes of Processing Personal Data. The Operator takes all reasonable measures to maintain the relevance of the processed Personal Data (Data), including, but not limited to the exercise of the right of each User to receive their Personal Data (Data) for review and demand from the Operator their clarification, blocking or destruction in if the Personal Data (Data) is incomplete, outdated, inaccurate, illegally obtained or not necessary for the Processing purposes stated above;
· storage of Personal Data (Data) in a form that allows identifying the User for no longer than required by the purposes of Processing Personal Data, unless the storage period for Personal Data (Data) is not established by Legislation or an agreement to which the User is a party or beneficiary ; · inadmissibility of combining Databases of Personal Data Information Systems created for incompatible purposes.
2. PURPOSES OF PROCESSING PERSONAL DATA
2.1. The Processing of Users’ personal data by the Operator is carried out for the purposes provided for in clause 5, Part 1, Article 6 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”, since the collection of personal data is necessary for the execution of an agreement to which a party or a beneficiary or guarantor of which the subject of personal data is, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement in which the subject of personal data will be a beneficiary or guarantor. The content of the agreement concluded with the User is determined by the terms of the public offer posted in the Operator’s Service.
2.2. Execution of an agreement to which the User is a party, or a beneficiary or guarantor, may include: · ensuring registration and authorization of the User in the Operator’s Services; · ensuring the possibility of communication between the Operator's support service and the User in the process of fulfilling contractual obligations; · communication with Users if if necessary to send notifications, information and requests, including advertising information, as well as processing of applications, requests and applications of Users.
2.3. Composition of processed information: · pseudonym (nickname), or other information (including full name) specified by the User in the cross-platform instant messaging system Telegram and/or on the Operator’s website; · User's phone number; · User's e-mail.
2.4. To optimize interaction with the user and eliminate possible technical problems, the Operator collects and processes the following anonymized information of Users: · cookies; · IP addresses; · User ID assigned by the Service; · time of registration on the Service; · time and date of visiting the Service; · duration of the user session; · information about the User’s device; · information about the location of the User device, information about country settings; · information about language settings.
2.5. The Operator does not process Personal Data related to special categories and relating to race and nationality, political views, religious or philosophical beliefs, health status, intimate life of the User, the User’s membership in public associations, except in cases directly provided for by the Legislation.
2.6. The Operator does not process biometric Personal Data.
2.7. Personal data (Data) is collected, stored and processed on the territory of the Russian Federation.
2.8. The Operator stops Processing Personal Data upon achieving the purposes of Processing, in the case of the User’s withdrawal of his consent to Processing, as well as in other cases provided for by the Legislation. The Operator has the right to continue Processing Personal Data in cases provided for by law.
3. RIGHTS OF USERS AND RESPONSIBILITIES OF THE OPERATOR
3.1. The user has the right: · receive information regarding the Processing of his Personal Data; · demand clarification of his Personal Data (Data), their blocking or destruction if the Personal Data (Data) is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also accept those provided for by law measures to protect your rights;
· 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; · Exercise other rights provided for by Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data” and other legal acts regulating the processing of personal data.
3.2. The operator undertakes: · take measures necessary and sufficient to respect the rights of Users and fulfill the obligations provided for by the Legislation; · at the User’s request, provide the User with the requested information free of charge in an accessible form, within the limits limited by Part 7 of Article 14 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”;
if cases of unlawful Processing of Personal Data are identified, the Operator undertakes to stop such Processing. In the event that it is impossible to ensure the legality of the Processing of Personal Data, the Operator undertakes to destroy such Personal Data (Data) in the manner established by the Legislation; · if the fact of inaccuracy of the Personal Data (Data) is revealed, the Operator undertakes to block such Personal Data (Data) and clarify them in the order established by the Legislation; · bear other obligations provided for by Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data” and other legal acts regulating the processing of personal data.
4. FINAL PROVISIONS
4.1. This Policy has been developed in accordance with Federal Law dated 27.07.2006 No. 152-FZ “On personal data” and other legislative sources regulating the procedure for processing personal data. In all cases not regulated by this Policy, the provisions of the specified Federal Law and other legislative sources of the Russian Federation are subject to application.
4.2. Changes to this Policy are made by the operator unilaterally. The changes made come into force from the moment this Policy is published in the Operator’s services.
4.3. Details and contact information of the Operator:
Operator:
Individual entrepreneur
Afanasyeva Sofya Vladimirovna
Taxpayer Identification Number:
784 301 796 552
Email:
Info@adsperformance.ru
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) defines the general principles and procedure for processing personal data, as well as other data of Users and measures to ensure their security I P Afanasyeva Sofya Vladimirovna (TIN: 784 301 796 552) (hereinafter referred to as “Operator”).
TERMS AND DEFINITIONS
The Policy uses the following terms with the meanings below: Service is a set of software products owned by the Operator, including an Internet resource (website on the internet), located at the address of the main page: adsperformance.ru/ Personal data — any information relating to directly or indirectly a specific or identifiable individual (User);
User —an individual who gains access to the Service; Operator —I P Afanasyeva Sofya Vladimirovna (TIN: 784 301 796 552) independently or jointly with other persons organizing and (or) carrying out the processing of Personal Data (Data), as well as determining the purposes of processing Personal Data (Data), composition of Personal Data (Data) to be processed, actions (operations) performed with Personal Data (Data);
Messenger —an information system and (or) computer program that is intended and (or) used for the exchange of electronic messages exclusively between users of these information systems and (or) computer programs, in which the sender of the electronic message determines the recipient or recipients of the electronic message, it is not possible for Internet users to post public information on the Internet and transmit electronic messages to an indefinite number of persons;
Processing of Personal Data (Processing) - any action (operation) or set of actions (operations) performed with or without the use of automation tools with Personal Data (Data), including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data (Data); Automated processing of Personal data — Processing of personal data using computer technology;
Blocking of Personal Data —temporary termination of Processing of Personal Data (Data), except for cases when Processing is necessary to clarify Personal Data (Data); Destruction of Personal Data - actions as a result of which it is impossible to restore the content of Personal Data (Data) in the Personal Data Information System or as a result of which the material media of Personal Data (Data) are destroyed;
Confidentiality of Personal Data is the obligation of the Operator or other person who has access to the User’s Personal Data (Data) not to disclose to third parties and not to distribute Personal Data (Data) without the consent of the relevant User, unless otherwise provided by the Legislation;
The Operator’s database is a collection of information and data located in the Personal Data Information System for the purpose of storing Personal Data (Data) of Users and other information.
1. GENERAL PROVISIONS
1.1. This Policy regarding the Processing of Personal Data has been developed in accordance with the provisions of Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data”, other legislative and regulatory legal acts and defines the procedure for working with Personal Data ( Data) of Users and requirements for ensuring their security.
1.2. The processing of Personal Data by the Operator is carried out in accordance with the following principles: · legality and fair basis for the Processing of Personal Data. The Operator takes all necessary measures to comply with the requirements of the Legislation, does not process Personal Data (Data) in cases where this is not permitted by Law, does not use Personal Data (Data) to harm the User;
processing only those Personal Data (Data) that meet the pre-announced purposes of their Processing. Compliance of the content and volume of processed Personal Data (Data) with the stated purposes of processing. Preventing the Processing of Personal Data incompatible with the purposes of collecting Personal Data (Data), as well as excessive in relation to the stated purposes of their Processing;
ensuring the accuracy, sufficiency and relevance of Personal Data (Data) in relation to the purposes of Processing Personal Data. The Operator takes all reasonable measures to maintain the relevance of the processed Personal Data (Data), including, but not limited to the exercise of the right of each User to receive their Personal Data (Data) for review and demand from the Operator their clarification, blocking or destruction in if the Personal Data (Data) is incomplete, outdated, inaccurate, illegally obtained or not necessary for the Processing purposes stated above;
· storage of Personal Data (Data) in a form that allows identifying the User for no longer than required by the purposes of Processing Personal Data, unless the storage period for Personal Data (Data) is not established by Legislation or an agreement to which the User is a party or beneficiary ; · inadmissibility of combining Databases of Personal Data Information Systems created for incompatible purposes.
2. PURPOSES OF PROCESSING PERSONAL DATA
2.1. The Processing of Users’ personal data by the Operator is carried out for the purposes provided for in clause 5, Part 1, Article 6 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”, since the collection of personal data is necessary for the execution of an agreement to which a party or a beneficiary or guarantor of which the subject of personal data is, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement in which the subject of personal data will be a beneficiary or guarantor. The content of the agreement concluded with the User is determined by the terms of the public offer posted in the Operator’s Service.
2.2. Execution of an agreement to which the User is a party, or a beneficiary or guarantor, may include: · ensuring registration and authorization of the User in the Operator’s Services; · ensuring the possibility of communication between the Operator's support service and the User in the process of fulfilling contractual obligations; · communication with Users if if necessary to send notifications, information and requests, including advertising information, as well as processing of applications, requests and applications of Users.
2.3. Composition of processed information: · pseudonym (nickname), or other information (including full name) specified by the User in the cross-platform instant messaging system Telegram and/or on the Operator’s website; · User's phone number; · User's e-mail.
2.4. To optimize interaction with the user and eliminate possible technical problems, the Operator collects and processes the following anonymized information of Users: · cookies; · IP addresses; · User ID assigned by the Service; · time of registration on the Service; · time and date of visiting the Service; · duration of the user session; · information about the User’s device; · information about the location of the User device, information about country settings; · information about language settings.
2.5. The Operator does not process Personal Data related to special categories and relating to race and nationality, political views, religious or philosophical beliefs, health status, intimate life of the User, the User’s membership in public associations, except in cases directly provided for by the Legislation.
2.6. The Operator does not process biometric Personal Data.
2.7. Personal data (Data) is collected, stored and processed on the territory of the Russian Federation.
2.8. The Operator stops Processing Personal Data upon achieving the purposes of Processing, in the case of the User’s withdrawal of his consent to Processing, as well as in other cases provided for by the Legislation. The Operator has the right to continue Processing Personal Data in cases provided for by law.
3. RIGHTS OF USERS AND RESPONSIBILITIES OF THE OPERATOR
3.1. The user has the right: · receive information regarding the Processing of his Personal Data; · demand clarification of his Personal Data (Data), their blocking or destruction if the Personal Data (Data) is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also accept those provided for by law measures to protect your rights;
· 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; · Exercise other rights provided for by Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data” and other legal acts regulating the processing of personal data.
3.2. The operator undertakes: · take measures necessary and sufficient to respect the rights of Users and fulfill the obligations provided for by the Legislation; · at the User’s request, provide the User with the requested information free of charge in an accessible form, within the limits limited by Part 7 of Article 14 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”;
if cases of unlawful Processing of Personal Data are identified, the Operator undertakes to stop such Processing. In the event that it is impossible to ensure the legality of the Processing of Personal Data, the Operator undertakes to destroy such Personal Data (Data) in the manner established by the Legislation; · if the fact of inaccuracy of the Personal Data (Data) is revealed, the Operator undertakes to block such Personal Data (Data) and clarify them in the order established by the Legislation; · bear other obligations provided for by Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data” and other legal acts regulating the processing of personal data.
4. FINAL PROVISIONS
4.1. This Policy has been developed in accordance with Federal Law dated 27.07.2006 No. 152-FZ “On personal data” and other legislative sources regulating the procedure for processing personal data. In all cases not regulated by this Policy, the provisions of the specified Federal Law and other legislative sources of the Russian Federation are subject to application.
4.2. Changes to this Policy are made by the operator unilaterally. The changes made come into force from the moment this Policy is published in the Operator’s services.
4.3. Details and contact information of the Operator:
Operator:
Individual entrepreneur
Afanasyeva Sofya Vladimirovna
Taxpayer Identification Number:
784 301 796 552
Email:
Info@adsperformance.ru