Policy regarding the processing of personal data

1. General provisions

This personal data processing policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Alexander Agranovskiy (hereinafter - the Operator).

1.1. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen when processing his 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 may obtain about visitors to the website https://seoeleven.ru/.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer equipment.

2.2. Blocking of personal data – temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data).

2.3. Website - a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://seoeleven.ru/.

2.4. Information system of personal data is a set of personal data contained in databases and information technologies and technical means providing their processing.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subject of personal data.

2.6. Personal data processing - any action (operation) or set of actions (operations) performed with or without the use of such means with personal data, including the collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator is a state body, municipal body, legal or natural person, independently or together with other persons organizing and / or carrying out the processing of personal data, as well as determining 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 certain or defined User website https://seoeleven.ru/.

2.9. Personal data allowed by the subject of personal data for distribution - personal data, access of an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner prescribed by the Law on personal data (hereinafter - personal data allowed for distribution).

2.10. User - any visitor of the website https://seoeleven.ru/.

2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data is the 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 irretrievably with the impossibility of further restoration of the content of personal data in the personal data information system and / or material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The operator has the right to:

• receive from the subject of personal data reliable information and / or documents containing personal data;
• in case of withdrawal of consent to the processing of personal data by the subject of personal data, as well as sending a request to stop the processing of personal data, the Operator has the right to continue the processing of personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The operator shall:

• provide the subject of personal data at his request with information regarding the processing of his personal data;
• organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
• respond to requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
• inform the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
• stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner 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 regarding the processing of his 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 should 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 its receipt is established by the Law on Personal Data;
• to require the operator to clarify his personal data, block them or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
• put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
• to withdraw consent to the processing of personal data, as well as to request the termination of the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator during the processing of his personal data;
• to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with reliable data about himself;
• inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have transmitted false information about themselves to the Operator, or information about another subject of personal data without the consent of the latter, 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 lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. The 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 are subject to processing.

5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The 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 processing personal data are 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 purpose of processing personal data requires, unless the period of storage of personal data is established by federal law, a contract to which the beneficiary or guarantor is the subject of personal data. The processed personal data is destroyed or anonymized upon achievement of the purposes of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6. Purposes of personal data processing

7. Conditions for processing personal data

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.

7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to carry out 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 implementation 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 Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the execution of a contract to which the beneficiary or guarantor is the subject of personal data, as well as for the conclusion of a contract on 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. 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. Personal data is processed, access to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for 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 safety of personal data and takes all possible measures to 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 in the event that the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s e-mail address info@seoeleven.ru with the mark “Update of personal data”.

8.4. The period of processing of personal data is determined by the achievement of the purposes for which personal data were collected, unless another period is provided for by the contract or applicable law. The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator by e-mail to the Operator’s e-mail address info@seoeleven.ru marked “Withdrawal of consent to the processing of personal data”.

8.5. All information that is 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 these documents. The operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

8.6. The prohibitions established by the subject of personal data on the transfer (except for the provision of 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 personal data processing in the state, public and other public interests determined by the legislation of the Russian Federation.

8.7. When processing personal data, the operator ensures the confidentiality of personal data.

8.8. The operator stores personal data in a form that allows 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, a contract to which the beneficiary or guarantor is the subject of personal data.

8.9. A condition for the termination of the processing of personal data may be the achievement of the goals of processing personal data, the expiration of the period of validity of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or the requirement to stop 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, refines (updates, changes), extracts, uses, transfers (distribution, provision, access), anonymizes, blocks, deletes and destroys personal data.

9.2. The operator carries out automated processing of personal data with the receipt and / or transfer of the received information via information and telecommunication networks or without it.

10. Cross-border transfer of personal data

10.1. The operator, prior to the commencement of cross-border transfer of personal data, 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 intention to process personal data).

10.2. The operator, before submitting the above notification, is obliged to receive relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to which cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The operator and other persons who have access to personal data are obliged not to disclose 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 can receive any clarifications on the issues of interest relating to the processing of his personal data by contacting the Operator by e-mail info@seoeleven.ru.

12.2. This document will reflect any changes in the personal data processing policy of the Operator. The policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://seoeleven.ru/privacy-policy.