1. GENERAL PROVISIONS

1.1. This Policy is implemented by [________] (hereinafter referred to as the “Operator”) regarding the processing and protection of personal data of individuals (personal data subjects) based on Article 24 of the Constitution of the Russian Federation and Federal Law No. 152-FZ “On Personal Data.”

1.2. The Policy applies to all personal data that may be obtained by the Operator in the course of business, including personal data of the Operator’s clients. The processing of personal data by the Operator is carried out in accordance with the following regulatory legal acts:

  • Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter – Federal Law “On Personal Data”);
  • Decree of the Government of the Russian Federation No. 687 dated September 15, 2008 “On Approval of the Regulation on the Peculiarities of Personal Data Processing Carried Out Without the Use of Automation Tools”;
  • Other regulatory legal acts of the Russian Federation and regulatory documents of executive authorities.

1.3. The purpose of the Policy is to provide persons who provide their personal data with necessary information allowing them to assess what personal data and for what purposes are processed by the Operator, what methods of ensuring their security are implemented, as well as establishing basic principles and approaches to processing and ensuring the security of personal data at the Operator.

1.4. The Policy ensures the protection of rights and freedoms of subjects during the processing of their personal data using automation tools or without such tools, and also establishes the responsibility of persons who have access to personal data for failure to comply with requirements regulating the processing and protection of personal data.

1.5. Users, by using the Operator’s services and services placed on the Operator’s website bigalmaz.ru (hereinafter – the Website), having communicated their personal data to the Operator, including through third parties, acknowledge their consent to the processing of personal data in accordance with this Policy. In case of disagreement with this Policy as a whole, as well as in case of disagreement with any clause of this Policy, the User must refrain from using the Services.

1.6. The Operator receives and begins processing the Subject’s personal data from the moment of receiving their consent. Consent to personal data processing can be given by the Personal Data Subject in a form allowing to confirm the fact of receiving consent, unless otherwise established by federal law:

  • in writing and/or
  • through the Personal Data Subject performing conclusive actions (checking the box under the corresponding personal data input form) when using services on the Operator’s website, using feedback forms and accepting offers containing provisions on personal data processing in accordance with current legislation. In the absence of consent from the Personal Data Subject to process their personal data, such processing is not carried out.

1.7. Consent to personal data processing may be withdrawn by the personal data subject. In case of withdrawal of consent for personal data processing by the personal data subject, the operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified by current legislation.

1.8. This Policy may be changed by the Operator. The Operator has the right at any time at its own discretion to make changes to this Policy, subject to prior notification of the User about this. When making changes, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is posted on the web server unless otherwise provided by the new version of the Policy.

1.9. This Policy applies only to information about the User obtained during the use of the Operator’s Services. The Operator does not control and is not responsible for the processing of information about the User by third-party websites that the User may visit via links available on the Operator’s official web server.

1.10. TERMS USED IN THIS POLICY:

  • personal data – any information relating directly or indirectly to a specific or identifiable individual (personal data subject)
  • personal data operator (operator) – a state body, municipal body, legal entity or individual who independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
  • personal data processing – any action (operation) or set of actions (operations) with personal data performed using automation tools or without their use. Personal data processing includes, among others: collection; recording; systematization; accumulation; storage; clarification (update, change); extraction; use; transfer (distribution, provision, access); depersonalization; blocking; deletion; destruction.
  • automated processing of personal data – processing of personal data using computer technology;
  • distribution of personal data – actions aimed at disclosure of personal data to an indefinite circle of persons;
  • provision of personal data – actions aimed at disclosure of personal data to a certain person or certain circle of persons;
  • destruction of personal data – actions resulting in the impossibility to restore the content of personal data in the personal data information system and (or) resulting in the destruction of physical media containing personal data;
  • personal data information system – a combination of personal data contained in databases and information technologies and technical means ensuring their processing;
  • personal data subject – an individual who is directly or indirectly defined or definable based on Personal Data relating to them.

2. CONCEPT AND COMPOSITION OF PERSONAL DATA

2.1. For the purposes of this Policy, personal data means any information relating directly or indirectly to a specific individual (personal data subject).

2.2. Depending on the personal data subject, the Operator may process personal data of the following categories of subjects to carry out its activities and fulfill its obligations:

  • Client data – information necessary for the Operator to fulfill its obligations under contractual relations with the Client and to comply with the requirements of the legislation of the Russian Federation. This also includes data provided by potential clients, client representatives authorized to represent clients; directors and chief accountants of legal entities that are clients of the Operator, persons who have concluded civil law contracts with the Operator for the provision of Operator’s services; employees of the Operator’s partners and other legal entities having contractual relations with the Operator, with whom the Operator’s employees interact within their activities;
  • Client’s personal data provided during registration on the Website, as well as when using services, communication forms posted on the website;
  • personal data of other individuals who have consented to the processing of their personal data by the Operator or individuals whose personal data processing is necessary for the Operator to achieve goals provided for by international treaty of the Russian Federation or law, to exercise and fulfill the powers and duties assigned by the legislation of the Russian Federation;
  • personal data of individuals that they have made publicly available, and their processing does not violate their rights and corresponds to the requirements established by the Legislation on personal data.

2.3. The Operator hereby informs Personal Data Subjects that within the framework of services provided on the Operator’s Website, subject to the Personal Data Subject’s consent to personal data processing, expressed in checking the corresponding box under the personal data collection form or clicking on the corresponding button, the following personal data may be processed: first name, last name, phone number; email address.

3. GROUNDS AND PURPOSES OF PERSONAL DATA PROCESSING

3.1. The Operator processes personal data to carry out its activities, including providing services to Clients. The Operator has the right to:

  • carry out the functions assigned to the Operator by the legislation of the Russian Federation in accordance with the Federal Law “On Personal Data” and other laws and regulatory legal acts of the Russian Federation, as well as the Charter and regulatory acts of the Operator;
  • The Operator collects and stores personal data of the Client necessary for providing services, fulfilling agreements and contracts, fulfilling obligations to the Client.

3.2. The Operator processes personal data only if at least one of the following conditions exists:

  • personal data processing is carried out with the consent of the personal data subject to process their personal data;
  • personal data processing is necessary to achieve goals provided for by law, to exercise and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
  • personal data processing is necessary for the execution of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor;
  • personal data processing is necessary for the exercise of rights and legitimate interests of the Company or third parties or to achieve socially significant goals, 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 has been provided by the personal data subject to an unlimited number of persons or at their request;
  • processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

3.3. The Operator and other persons who have gained 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.

3.4. The Operator may process personal data of personal data subjects for the following purposes:

  • to identify the personal data subject;
  • to communicate with the personal data subject if necessary, including sending proposals, notifications, information and requests, both related and not related to the provision of services, as well as processing applications, requests and applications from the Client;
  • improving the quality of services provided by the Operator.

3.5. The Operator does not process special categories of Personal Data concerning racial, national origin, political views, religious or philosophical beliefs, intimate life.

4. TERMS OF PERSONAL DATA PROCESSING

4.1. The terms of personal data processing are determined based on the purposes of processing in the Operator’s information systems, in accordance with the term of the agreement, agreement with the personal data subject.

4.2. The condition for terminating personal data processing may be the achievement of the purposes of personal data processing according to the terms of agreements concluded between the Operator and the personal data subject, the expiration of the consent or withdrawal of consent of the personal data subject to process their personal data, as well as the detection of unlawful processing of personal data.

5. CIRCLE OF PERSONS AUTHORIZED TO PROCESS PERSONAL DATA

5.1. To achieve the goals of Article 3 of this Policy, only those employees of the Operator who have been assigned such an obligation in accordance with their official (labor) duties are allowed to process personal data. Access by other employees may be provided only in cases provided for by law. The Operator requires its employees to maintain confidentiality and ensure the security of personal data during their processing.

5.2. The Operator has the right to transfer personal data to third parties in the following cases:

  • The Personal Data Subject has explicitly expressed their consent to such actions;
  • The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by legislation.

In this case, all obligations to comply with the conditions of this Policy in relation to the received data pass to the acquirer.

5.3. Upon a motivated request from an authorized body and according to current legislation, the subject’s personal data may be transferred without their consent to:

  • judicial bodies in connection with the administration of justice;
  • police, federal security service, prosecutor’s office, investigative committee;
  • other bodies and Operators authorized by current legislation and applicable legal norms in cases established in regulatory legal acts that are mandatory for the operator to execute.

6. PROCEDURE AND METHODS OF PERSONAL DATA PROCESSING

6.1. In the process of providing services, when carrying out internal economic activities, the Operator uses automated and non-automated processing of personal data.

6.2. 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 the legislation of the Russian Federation, on the basis of an agreement concluded with this person, a mandatory condition of which is compliance by this person with the principles and rules of Personal Data Processing provided for by the Federal Law “On Personal Data.”

6.3. Personal data is not disclosed to third parties and is not distributed in any other way without the consent of the Personal Data Subject, unless otherwise provided by the legislation of the Russian Federation.

6.4. Representatives of state authorities (including controlling, supervisory, law enforcement and other bodies) receive access to Personal Data processed by the Operator in the scope and manner established by the legislation of the Russian Federation.

6.5. Within the framework of personal data processing, the following rights are defined for the Personal Data Subject and the Operator.

6.5.1. The Personal Data Subject has the right to:

  • receive information regarding the processing of their personal data in the manner, form and terms established by the Legislation on personal data;
  • require clarification of their personal data, their Blocking or Destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, is not necessary for the stated purpose of processing or is used for purposes not previously stated when the Personal Data Subject provided consent for personal data processing;
  • take measures provided by law to protect their rights;
  • withdraw their consent to personal data processing.

6.5.2. The Operator has the right to:

  • process personal data of the Personal Data Subject in accordance with the stated purpose;
  • require from the Personal Data Subject the provision of reliable personal data necessary for the execution of the agreement, provision of services, identification of the Personal Data Subject, as well as in other cases provided for by the Legislation on personal data; restrict the Personal Data Subject’s access to their personal data if the Processing of personal data is carried out in accordance with anti-money laundering and terrorist financing legislation, access by the Personal Data Subject to their personal data violates the rights and legitimate interests of third parties, as well as in other cases provided for by the legislation of the Russian Federation;
  • process publicly available personal data of individuals;
  • carry out processing of personal data subject to publication or mandatory disclosure in accordance with the legislation of the Russian Federation;
  • entrust personal data processing to another person with the consent of the Personal Data Subject.

6.6. If the fact of inaccuracy of personal data or unlawfulness of their processing is confirmed, the personal data shall be updated by the operator, and processing must be terminated.

6.7. When the purposes of personal data processing are achieved, as well as in case of withdrawal of consent for their processing by the personal data subject, personal data is subject to destruction, unless:

  • otherwise provided by the agreement to which the personal data subject is a party, beneficiary or guarantor;
  • the Operator has the right to carry out processing without the consent of the personal data subject on the grounds provided for by the Federal Law “On Personal Data” or other federal laws;
  • otherwise provided by another agreement between the Operator and the personal data subject.

6.8. The Operator is obliged to inform the personal data subject or their representative about the processing of personal data of such subject at their request.

6.9. The Operator also has other rights and bears other obligations established by the Federal Law “On Personal Data.”

7. All suggestions or questions regarding this Privacy Policy should be sent to the email address hoyakap@gmail.com


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