Personal Data Processing Policy
1. General provisions
This personal data processing policy is developed in accordance with the requirements of Federal Law No. 152-FZ dated 07/27/2006 “On Personal Data” (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the safety of personal data taken by OOO RSK Stroy (OGRN (Primary State Registration Number) 1177746199377, INN (Taxpayer Identification Number) 7722391638), registered at: office 1, floor 2, str. 2, bld. 28, Podsosensky pereulok, Moscow, 101000 (hereinafter referred to as the Operator).
1.1. This Operator’s policy regarding the personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://rskst.ru (hereinafter referred to as the Website), which were voluntarily provided by visitors to the Website.
2. Basic definitions used in Policy
2.1. Automated personal data processing is the personal data processing using computer technology.
2.2. Blocking of personal data is the temporary termination of personal data processing (except where processing is necessary for personal data rectification).
2.3. A website is a collection of graphic and informational materials, as well as software application and databases that ensure their availability on the Internet at the web address https://rskst.ru.
2.4. The personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalisation of personal data is an action resulting in impossibility to determine, without using additional information, whether personal data belong to a specific User or other personal data subject.
2.6. Processing of personal data is any action (operation) or set of actions (operations) performed with the use of automation means or without the use of such means to personal data, including collection, recording, systematization, accumulation, storage, rectification (updating and changing), extraction, use, disclosure (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. The operator is OOO RSK Stroy (OGRN (Primary State Registration Number) 1177746199377, INN (Taxpayer Identification Number) 7722391638), independently or jointly with other persons arranging and/or processing personal data, as well as determining the purposes of personal data processing, the scope of personal data for processing, actions (operations) performed with personal data.
2.8. Personal data is any information related directly or indirectly to a specific or identifiable User of the Website.
2.9. Personal data authorized by the personal data subject for distribution is personal data, access to which is provided by the User to an unlimited number of persons by giving consent to the personal data processing authorized by the personal data subject for distribution in accordance with the procedure provided for by the Law on Personal Data (hereinafter — personal data authorized for distribution).
2.10. A user is any individual who is a visitor to a Website and is a personal data subject.
2.11. Provision of personal data is any actions aimed at disclosing personal data to a certain person or a certain number of persons.
2.12. Distribution of personal data is any actions aimed at disclosing personal data to an any number of persons (disclosure of personal data) or familiarization with personal data of an unlimited number of persons, including the publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way. 2.13. Destruction of personal data is any actions resulting in personal data being permanently destroyed with the inability to further restore the content of personal data in the personal data information system and/or the material media bearing the personal data are destroyed.
3. Basic rights and responsibilities of the Operator
3.1. The operator has the right to:
— receive reliable information and/or documents containing personal data from the User;
— if User withdraws consent to the personal data processing, as well as sending a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the User’s consent if there are grounds specified in the Law on Personal Data;
— independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise stated by the Law on Personal Data or other federal laws.
3.2. The operator shall:
— to provide the User, at his/her request, with information concerning the processing of his/her personal data;
— arrange the personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to inquiries and requests from Users and their legal representatives in accordance with the requirements of the Law on Personal Data;
— to inform the authorized body for the protection of the rights of subjects of personal data at the request of this body of the necessary information within 10 days from the date of receipt of such a request;
— to publish or otherwise provide unlimited access to this Policy regarding the personal data processing;
— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, as well as destruction, modification, blocking, copying, provision, distribution of personal data, and from other illegal actions in relation to personal data;
— to stop the disclosure (distribution, provision, access) of personal data, to stop processing and destroy personal data as and where stipulated by the Law on Personal Data;
— perform other duties provided for by the Law on Personal Data.
4. Basic rights and responsibilities of Users
4.1. Users have the right to:
— receive information regarding the processing of his/her personal data, except in cases provided for by federal laws. The information is provided to the User by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for its obtaining is established by the Law on Personal Data;
— to demand the Operator to rectify his/her personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
— to set a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
— to withdraw the consent to the personal data processing, as well as to send a request to stop the processing of personal data;
— to lodge a complaint to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or failure of the Operator to act during the processing of his/her personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Users shall:
— provide the Operator with reliable information about themselves;
— inform the Operator about the rectification (updating, changing) 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 bear responsibility as set forth by the law 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. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. It is not allowed to combine databases containing personal data, whose processing purposes are incompatible.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated processing purposes. Redundancy of the processed personal data in relation to the stated processing purposes is not allowed.
5.6. The processing of personal data ensures the accuracy of personal data, their sufficiency, and, if needed, relevance in relation to the purposes of personal data processing. The Operator takes the necessary measures and/or ensures that they are taken to delete or rectify incomplete or inaccurate data.
5.7. Personal data is stored in a way that allows to identify the subject of personal data only as long as it is needed for purposes of personal data processing, unless the period of personal data storage is established by federal law, an agreement where the User is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing purposes or if there is no further need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing:
provision of services/works to the User;
sending notifications to the User regarding the services/works provided;
preparing and sending responses to User requests;
sending information to the User, including advertising, information about the Operator’s events/goods/services/works.
first name, second name, patronymic name (if any);
other data provided by the User.
The Law on Personal Data;
Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” dated 07/27/2006
Types of personal data processing:
Sending information letters to the email address specified by the User;
Calls to the phone number specified by the User.
7. Terms of personal data processing
7.1. The processing of personal data is carried out with the User’s consent to the processing of his/her personal data, in accordance with the provisions of the Law on Personal Data. The User who has accepted this Policy represents and warrants to the Operator within the meaning of Article 431.2 of the Civil Code of the Russian Federation that he has read all the provisions of this Policy, understands the meaning and definition of the terms, as well as the terms for processing his/her personal data by the Operator.
7.2. The processing of personal data is necessary to achieve the purposes provided for in this Policy.
7.3. The processing of personal data is necessary for the execution of an agreement where the User is a party or beneficiary or guarantor, as well as for the conclusion of an agreement initiated by the User or an agreement under which the User will be a beneficiary or guarantor.
8. The procedure for the collection, storage, disclosure and other types of personal data processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of 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 prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data will never, under any circumstances, be disclosed to third parties, except in cases related to the implementation of current legislation, or if the User has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies of personal data, the User can update them independently by sending a notification to the Operator’s e-mail address firstname.lastname@example.org marked “Updating of personal data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which personal data was collected, unless another period is provided for by an agreement concluded between the Operator and the User, or by applicable law.
The User can withdraw his/her consent to the personal data processing at any time by sending a notification to the Operator’s e-mail address email@example.com marked “Withdrawal of consent to the processing of personal data”.
8.6. The prohibitions established by the User for the disclosure (except for granting access), as well as on the processing or processing terms (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in the state, social and other public interests defined by the legislation of the Russian Federation.
8.7. The operator ensures the confidentiality of personal data when processing it.
8.8. The Operator stores personal data in a way that allows to identify the subject of personal data only as long as it is needed for the purposes of processing personal data, unless the period of storage of personal data is established by federal law, an agreement to which the User is a party, beneficiary or guarantor.
8.9. The termination condition for the personal data processing may be the achievement of the purposes for personal data processing, the expiration of the User’s consent, the withdrawal of consent by the User or the requirement to terminate the processing of personal data, as well as the identification of illegal processing of personal data.
9. List of operations performed by the Operator to the received personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, rectifies (updates, changes), extracts, uses, discloses (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated processing of personal data with or without receiving and/or disclosing the information received via information and telecommunication networks.
10. Confidentiality of personal data
The Operator who has gained access to personal data shall not disclose and distribute personal data to third parties without the appropriate consent of the User, unless otherwise provided by regulatory legal acts.
11. Final provisions
11.1. The User can receive any explanations on issues of interest related to the processing of his/her personal data by contacting the Operator via e-mail at: firstname.lastname@example.org. The time for consideration of the User’s request by the Operator shall not exceed 30 (thirty) days from the date of its receipt by the Operator.
11.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy remains in force without limit of time until it is replaced by a new version. The Operator adopts the new version of this Policy by publishing it on the Website, the effective date of the new Policy version shall be the date of its publishing on the Website.
11.3. The up-to-date version of the Policy is at free access on the Internet at: https://rskst.ru/en/privacy-policy. (link to the policy page) 11.4. The User shall independently monitor the update of this Policy on the Operator’s Website.