Personal Data Processing Policy
1. General provisions
This Personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by IP Teplukhin Dmitry Aleksandrovich TIN 673106124450 (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing their 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 can receive about visitors to the website https://stayfirst.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 termination of the processing of personal data (except in cases where the processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://stayfirst.ru.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine whether personal data belongs to a specific User or other personal data subject without using additional information.
2.6. Personal data processing – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), 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 that independently or jointly with other persons organizes and / or performs the processing of personal data, as well as determines 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 related directly or indirectly to a specific or identifiable User of the website https://stayfirst.ru.
2.9. Personal data authorized for distribution by the personal data subject – personal data that an unlimited number of persons have access to by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as personal data authorized for Distribution).
2.10. User – any user of the website https://stayfirst.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publishing personal data in the mass media, posting it in information and telecommunications 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 the authority of a foreign state, to a foreign natural or legal person.
2.14. Destruction of personal data – any actions, as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
– receive reliable information and / or documents containing personal data from the personal data subject;
– if the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, 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 stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
– provide the personal data subject, upon request, with information related to the processing of his / her personal data;
– organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
– respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within 30 days from the date of receipt of such request;
– publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
– stop transmitting (distributing, providing, accessing) personal data, stop processing and destroy personal data in accordance with the procedure 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 related to the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject 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 legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
– to require the operator to clarify his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, and also take legal measures to protect their rights;
– to propose the prior consent of the processing of personal data in order to advance in the market of goods, works and services;
– to revoke consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator when processing their 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 yourself;
– inform the Operator about updating (updating, changing) your 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 the Russian Federation.
5. The operator can process the following personal data
5.1. Personal data that is not special or biometric: surname, name, patronymic; contact phone numbers; email addresses; place of work and position; user data (location information; the type and version of the OS; the type and version; device type and resolution of its screen; the source whence came the website user; from which site or by which advertising; the language of the OS and Browser; which pages opens and which buttons the user presses; ip-address and more.
5.2. Also on site is the collection and processing of anonymous data about visitors (including cookies) using Internet statistics (Yandex Metric and Google Analytics and others).
5.3.The above-mentioned data are further united by the general concept of Personal data in the text of the Policy.
5.4.The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.5. Processing of personal data authorized for distribution 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 met.
5.6. The User’s consent to the processing of personal data allowed for distribution is issued separately from other consents to the processing of their personal data. At the same time, the conditions stipulated, in particular, by Article 10.1 of the Law on Personal Data 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.
5.6.1 The User provides consent to the processing of personal data allowed for distribution directly to the Operator.
5.6.2 The Operator is obliged to publish information about the processing conditions, prohibitions and conditions on the processing of personal data allowed for distribution by an unlimited number of persons no later than three working days after receiving the specified User consent.
5.6.3 The transfer (distribution, provision, access) of personal data authorized for distribution by the personal data subject must be terminated at any time at the request of the personal data subject. This requirement should 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 that is subject to termination of processing. The personal data specified in this request can only be processed by the Operator to whom it is sent.
5.6.4 Consent to the processing of personal data allowed for distribution is terminated from the moment the Operator receives the request specified in clause 5.6.3 of this Personal Data Processing Policy.
6. Principles of personal data processing
6.1. Personal data processing is carried out on a legal and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, pre-defined and legitimate goals. Processing of personal data that is incompatible with the purposes of personal data collection 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 meets the purposes of their processing are subject to processing.
6.5. The content and scope of the personal data processed correspond to the stated purposes of processing. 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, if necessary, their relevance in relation to the purposes of personal data processing is ensured. The Operator takes the necessary measures and / or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows determining 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, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized when the purposes of processing are achieved or when it is no longer necessary to achieve these goals, unless otherwise provided by federal law.
7. Purpose of processing of personal data
7.1. The purpose of the processing of personal data of the User informing the User by sending e-mails; the conclusion, execution and termination of civil contracts; providing User access to the services, information and/or content contained on the web site https://stayfirst.ru; clarify details of the order; conducting advertising and newsletters; Analytics of User actions on the web site and the functioning of the website; processing incoming User requests to provide advice.
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator’s email address email@example.com marked “Unsubscribe from notifications about new products and services and special offers”.
7.3. Depersonalized User data collected through Internet statistics services is used to collect information about User actions on the site, improve the quality of the site and its content.
8. The legal basis for the processing of personal data
8.1. Legal basis the processing of personal data by the Operator are: the Charter (constituent) documents of the Operator; the treaties concluded between the operator and the personal data subject; Federal laws and other normative legal acts in the field of personal data protection; User consent to the processing of their personal data, to the processing of personal data is allowed to propagate.
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 site https://stayfirst.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 agrees to this Policy.
8.4. The personal data subject independently makes a decision on the provision of his / her personal data and gives consent freely, voluntarily and in his / her own interest.
9. Terms of personal data processing
9.1. Personal data processing is carried out with the consent of the personal data subject to the processing of his / her personal data.
9.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or a law, and to perform the functions, powers and duties assigned to 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, or an act of another body or official that is 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 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 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.
9.6.Processing of personal data is carried out, access to which is granted to an unlimited number of persons by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
10. Procedure for collecting, storing, transmitting 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 security of personal data and takes all possible measures that exclude access to personal data of 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 implementation of the current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil contract.
10.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address firstname.lastname@example.org marked “Updating personal data”.
10.4. The term of personal data processing is determined by the achievement of the purposes for which personal data was collected, unless another term is provided for by the contract or current legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address email@example.com marked “Revocation of consent to the processing of personal data”.
10.6. Established by the personal data subject to the restrictions on transfer (except for the provision of access), as well as handling or processing conditions (except for access) personal data permitted to distribute, do not apply to cases of personal data processing in state, public and other public interests, defined by the legislation of the Russian Federation.
10.7. The operator in the processing of personal data to ensure the confidentiality of personal data.
10.8. The Operator stores personal data in a form that makes it possible 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, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
10.9. Termination of personal data processing may be subject to the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject or withdrawal of consent by the personal data subject, as well as detection of illegal processing of personal data.
11. List of actions performed by the Operator with the personal data received
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transmits (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
11.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.
12. Cross-border transfer of personal data
12.1. Before starting the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state, to whose territory it is supposed to transfer personal data, provides reliable protection of the rights of subjects of personal data.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the subject of personal data for the cross-border transfer of his personal data and / or execution of an agreement to which the subject of personal data is a party.
13. Confidentiality of personal data
The operator and other persons who have obtained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final provisions
14.1. The User can get any clarifications on the issues of interest related to the processing of his personal data by contacting the Operator via e-mail firstname.lastname@example.org.
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 with a new version.
14.3. The current version of the Policy is freely available on the Internet at https://stayfirst.ru/en/privacy-policy/.