Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter the Personal Data Law) and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by EURO TELECOM LLC (hereinafter the Operator).
1.1. The Operator considers it its most important goal and a condition of its activities to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy and to personal and family confidentiality.
1.2. This Operator's policy on the processing of personal data (hereinafter the Policy) applies to all information that the Operator may obtain about visitors to the website https://шбз.рф.
2. Key terms used in the Policy
2.1. Automated processing of personal data – the processing of personal data using computer technology.
2.2. Blocking of personal data – the temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, that make them accessible on the internet at the network address https://шбз.рф.
2.4. Personal data information system – the aggregate of personal data contained in databases and the information technologies and technical means that enable its processing.
2.5. Anonymization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine that personal data belongs to a specific User or other personal data subject.
2.6. Personal data processing – any action (operation) or set of actions (operations) performed on personal data, with or without the use of automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and 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 carries out the processing of personal data, and determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://шбз.рф.
2.9. Personal data permitted by the personal data subject for dissemination - personal data to which an unlimited number of persons has been granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for dissemination).
2.10. User – any visitor to the website https://шбз.рф.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in the mass media, posting it on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are destroyed irreversibly, making it impossible to restore the content of the personal data in the personal data information system, and/or the physical media containing personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
– to receive from the personal data subject accurate information and/or documents containing personal data;
– where the personal data subject withdraws consent to the processing of personal data, the Operator may continue processing the personal data without the subject's consent if there are grounds for doing so as specified in the Personal Data Law;
– to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
– provide the personal data subject, upon request, with information concerning the processing of their personal data;
– organize the processing of personal data in the manner established by the current legislation of Russia;
– respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide the authorized body for the protection of the rights of personal data subjects, upon that body's request, with the necessary information within 30 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 unlawful or accidental access, destruction, modification, blocking, copying, provision, or dissemination, as well as from other unlawful actions in relation to personal data;
– cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
– to perform other obligations provided for by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
– to receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
– require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take the measures provided by law to protect their rights;
– require prior consent as a condition for the processing of personal data for the purpose of promoting goods, works and services on the market;
– to withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in the processing of their personal data;
– to exercise other rights provided for by the legislation of Russia.
4.2. Personal data subjects are obliged to:
– provide the Operator with accurate information about themselves;
– notify the Operator of any clarification (updating, modification) of their 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 Russia.
5. The Operator may process the following personal data of the User
5.1. Last name, first name, and patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. The Site also collects and processes anonymized data about visitors (including cookies) using web analytics services (Yandex Metrica, Google Analytics and others).
5.5. The data listed above is hereinafter referred to collectively in this Policy as Personal Data.
5.6. The Operator does not process special categories of personal data relating to race, ethnicity, political opinions, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data permitted for dissemination that falls within the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted provided that the prohibitions and conditions set out in Article 10.1 of the Personal Data Law are observed.
5.8. The User's consent to the processing of personal data permitted for dissemination is executed separately from other consents to the processing of his or her personal data. In doing so, the conditions set out in particular in Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 The User gives consent to the processing of personal data permitted for dissemination directly to the Operator.
5.8.2 No later than three business days from the receipt of the User's said consent, the Operator shall publish information on the conditions of processing and on the existence of prohibitions and conditions on the processing of personal data permitted for dissemination by an unlimited number of persons.
5.8.3 The transfer (dissemination, provision, access) of personal data permitted by the personal data subject for dissemination must be ceased at any time upon the request of the personal data subject. Such a request must include the surname, first name and patronymic (if any) of the personal data subject, their contact information (telephone number, email address or postal address), and a list of the personal data whose processing is to be ceased. The personal data specified in such a request may be processed only by the Operator to whom it is addressed.
5.8.4 Consent to the processing of personal data permitted for dissemination ceases to be effective from the moment the Operator receives the request referred to in clause 5.8.3 of this Policy on the processing of personal data.
6. Principles of Personal Data Processing
6.1. Personal data is processed on a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which it was collected is not permitted.
6.3. It is not permitted to merge databases containing personal data that is processed for purposes incompatible with one another.
6.4. Only personal data that meets the purposes of its processing is subject to processing.
6.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of its processing.
6.6. When processing personal data, the accuracy of the personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing shall be ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than is required by the purposes of processing, unless the retention period for the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized once the purposes of processing have been achieved or the need to achieve those purposes no longer exists, unless otherwise provided by federal law.
7. Purposes of personal data processing
7.1. Purpose of processing the User's personal data:
– informing the User by sending emails;
– conclusion, performance and termination of civil law contracts;
– providing the User with access to the services, information, and/or materials contained on the website https://шбз.рф.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may opt out of receiving informational messages at any time by sending the Operator an email to 79013211115@mail.ru marked “Opt out of notifications about new products, services, and special offers”.
7.3. Anonymized User data collected through web analytics services is used to gather information about Users' actions on the site and to improve the quality of the site and its content.
8. Legal grounds for the processing of personal data
8.1. The legal grounds for the processing of personal data by the Operator are:
– Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" of July 27, 2006;
– federal laws and other regulatory legal acts in the field of personal data protection;
– the Users' consent to the processing of their personal data and to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User's personal data only if the User fills in and/or submits them independently through the special forms located on the site https://шбз.рф or sent to the Operator by email. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted by the settings of the User's browser (cookie storage and the use of JavaScript technology are enabled).
8.4. The personal data subject decides independently whether to provide his or her personal data and gives consent freely, of his or her own will, and in his or her own interest.
9. Conditions for the processing of personal data
9.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to exercise the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act, or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5. 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 purposes, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Personal data is processed to which access for an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter – publicly available personal data).
9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
10. 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 through the implementation of the legal, organizational, and technical measures required to fully comply with the applicable personal data protection legislation.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
10.3. If inaccuracies are found in their personal data, the User may update it themselves by sending a notice to the Operator's email address 79013211115@mail.ru marked “Personal Data Update”.
10.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable law.
The User may withdraw his or her consent to the processing of personal data at any time by sending a notice to the Operator by email to the Operator's email address 79013211115@mail.ru marked “Withdrawal of consent to the processing of personal data”.
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to review these documents in a timely manner on their own. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
10.6. Prohibitions established by the personal data subject on the transfer (other than granting access) of personal data permitted for dissemination, as well as on its processing or the conditions of its processing (other than obtaining access), do not apply where personal data is processed in the state, public, or other public interests defined by the legislation of Russia.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than is required by the purposes of processing, unless the retention period for the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The processing of personal data may be terminated upon achievement of the purposes of processing the personal data, expiry of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as upon detection of unlawful processing of personal data.
11. List of actions performed by the Operator with the personal data obtained
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion and destruction of personal data.
11.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the resulting information via information and telecommunications networks.
12. Cross-border transfer of personal data
12.1. Before commencing a cross-border transfer of personal data, the Operator shall make sure that the foreign state to whose territory the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only with the written consent of the personal data subject to the cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final provisions
14.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator by email 79013211115@mail.ru.
14.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://шбз.рф/policy.