Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law") and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC NPO "Etalon" (hereinafter referred to as the "Operator").
1.1. The Operator sets as its most important goal and condition for its activities the observance of human and citizen's rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator can obtain about visitors to the website https://npoetalon.ru.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphical and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://npoetalon.ru.
2.4. Personal data information system — a set of personal data contained in databases and ensuring their processing information technologies and technical means.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or individual, independently or jointly 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 specific or identifiable User of the website https://npoetalon.ru.
2.9. Personal data permitted by the subject of personal data for dissemination - personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any visitor to the website https://npoetalon.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific 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 at familiarizing with personal data of an unlimited circle of persons, including the publication of personal data in the mass media, posting in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – 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.
2.14. Destruction of personal data – any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and (or) as a result of which 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 the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of 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 subject of personal data, upon his request, with information concerning the processing of his personal data;
– to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
– to respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– to report to the authorized body for the protection of the rights of personal data subjects, upon the request of this body, the necessary information within 30 days from the date of receipt of such a request;
– to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
– to take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
– to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
– to perform other duties 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 receive information concerning the processing of his personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except in cases 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;
– to require the operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
– to set the condition of prior consent when processing personal data for the purpose of promoting goods, works, services on the market;
– to withdraw consent to the processing of personal data;
– to 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 when processing 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 themselves;
– to inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Also, the site collects and processes anonymized data about visitors (including "cookies") using Internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The above data further in the text of the Policy are united by the general concept of Personal Data.
5.6. The processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
5.7. The processing of personal data permitted for dissemination, from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law, is allowed if the prohibitions and conditions provided for 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 personal data. At the same time, the conditions provided for, in particular, by 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 consent to the processing of personal data permitted for dissemination is provided by the User directly to the Operator.
5.8.2 The Operator is obliged, no later than three business days from the moment of receiving the said consent of the User, to publish information on the conditions of processing, on the existence of prohibitions and conditions for the processing by an unlimited circle of persons of personal data permitted for dissemination.
5.8.3 The transfer (distribution, provision, access) of personal data permitted by the personal data subject for dissemination must be terminated at any time at the request of the personal data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request can be processed only by the Operator to whom it is sent.
5.8.4 The consent to the processing of personal data permitted for dissemination ceases to be effective from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. The processing of personal data is carried out 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 of collecting personal data is not allowed.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
6.4. Only personal data that meet the purposes of their processing are subject to processing.
6.5. The content and volume of the processed personal data 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.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achieving the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data:
– informing the User by sending emails;
– conclusion, execution and termination of civil law contracts.
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 can always refuse to receive informational messages by sending the Operator a letter to the email address info@npoetalon.ru with the note "Refusal of notifications about new products and services and special offers".
7.3. Anonymized User data collected using Internet statistics services serve to collect information about the Users' actions on the site, improve the quality of the site and its content.
8. Legal Grounds for Processing Personal Data
8.1. The legal grounds for the processing of personal data by the Operator are:
– list the regulatory legal acts regulating relations related to your activities, for example, if your activity is related to information technology, in particular with the creation of websites, then here you can specify the Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 N 149-FZ;
– the Operator's statutory documents;
– contracts concluded between the operator and the subject of personal data;
– federal laws, other regulatory legal acts in the field of personal data protection;
– Users' consents to the processing of their personal data, to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://npoetalon.ru or sent to the Operator via email. By filling out 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 it is allowed in the User's browser settings (saving "cookies" and using JavaScript technology are enabled).
8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, of his own will and in his interest.
9. Conditions for Processing Personal Data
9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, for the implementation of 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, 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.
9.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or a 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 a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6. The processing of personal data is carried out, access to which is provided to an unlimited circle of persons by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
9.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
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.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude 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 the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@npoetalon.ru with the note "Updating personal data".
10.4. The period for processing 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 the contract or current legislation.
The User can at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@npoetalon.ru with the note "Withdrawal of consent to the processing of personal data".
10.5. All information that is collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to independently familiarize themselves with the said documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator, when processing personal data, ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with the Received Personal Data
11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
11.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended to be carried out provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements can be carried out only if the personal data subject has given written consent to the cross-border transfer of his personal data and/or 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 to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email at info@npoetalon.ru.
14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid 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://npoetalon.ru/privacy.