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Policy
"RIGRAISER RUS" LLC policy regarding the processing and protection of personal data
1. General Provisions
1.1. The policy regarding the processing and protection of personal data is developed in accordance with Federal Law of July 27, 2006 No. 152-ФЗ "About Personal Data" (further - ФЗ-152). This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in SP Lekontseva A. Legal address of the company:12 Kutuzovsky Avenue, Corp/St. 10, quarter. 2/I/1, Moscow, Russia, 121248, INN: 7730254770 (further - Operator) in order to protect the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of rights to privacy, personal and family secrets.
1.2. In this Policy the following basic concepts are used: - automated processing of personal data - processing of personal data using computer technology; - blocking of personal data - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data); - the totality of personal data contained in the databases and the processing of information technologies and technical means; - depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific subject of personal data; - processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval , use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data; - personal data - any information relating directly or indirectly to a defined or determined individual (subject of personal data); - provision of personal data - actions aimed at disclosing personal data to a specific person or a certain people; - spread of personal data - actions aimed at the disclosure of personal data to an indefinite number of persons (transfer of personal data) or to familiarization with personal data of an unlimited number of people, including the publication of personal data in the media, placement in information and telecommunication networks or providing access personal data in any other way; - destruction of personal data - actions, as a result of which it is impossible to restore 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. The operator is obliged to publish or otherwise provide unlimited access to this Policy for the processing of personal data in accordance with Part 2 of Art. 18.1. FZ 152.
1.3 The operator has the right to make changes to the Policy. When making changes in a current edition, the date of the last update is indicated. The new version of the Policy comes out from the moment it is posted on the Operator's website, unless otherwise provided by the new version of the Policy. The current version of the Policy is always on the website in public access at: https://silvashi.com Personal data of the subject of personal data The subject of personal data decides to provide his personal data and agrees to its processing freely, by his own will and in his interests. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form allowing confirming the fact of its receipt, unless otherwise provided by federal law or the terms of the Regulation. By entering personal data in a web form on the Operator's website, by clicking the "Send" button, the personal data subject (PD subject) decides to provide his personal data and agrees to its processing by his own will and in his interest, and such consent of the PD subject is concrete and conscious. The site administration does not verify the accuracy of the personal information provided by the subjects of PD, and does not verify their legal capacity. At the same time, the Site Administration proceeds from the fact that the information transmitted by it from users is reliable. The subject of PD is responsible for the provision of personal data of a third party. Personal data entered by the PD subject when filling out the web form can be used by the Site Administration to prepare and send an offer, complete a transaction, perform a service or improve the quality of services.
3. Processing of personal data of subjects of personal data Acceptance of the terms of this Policy regarding provisions for the processing of personal data is carried out by affixing the subject of personal data the appropriate mark when filling out any web form on the Operator's website and is the expressed informed consent of the subject of personal data to the processing of personal data. PD subject agrees that the Site Administration has the right to store and process, including automated, any information related to the user's personal data in accordance with Federal Law of July 27, 2006 No. 152-FZ "About Personal Data", including collection, systematization, accumulation, storage, clarification, use, distribution (including transfer), depersonalization, blocking, destruction of personal data provided by the user when filling out a web form on the Operator's website. Consent to the processing of personal data can be revoked at any time by the subject of personal information by written request to the site Administration. If the user withdraws consent to the processing of personal data, the Site Administration deletes the personal data of the subject of personal data and cannot use it in the future.
4. Principles and conditions for the processing of personal data
4.1. Principles of processing personal data Processing of personal data with the Operator is based on the following principles:
§ legality and fair basis;
§ restrictions on the processing of personal data by achieving specific, predetermined and legitimate goals;
§ preventing personal data processing incompatible with the purposes of collecting personal data;
§ processing only those personal data that meet the purposes of their processing; compliance of the content and volume of processed personal data with the declared processing goals;
§ preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;
§ ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
§ destruction or depersonalization of personal data upon achievement of the purposes of its processing or in case of loss of need to achieve these purposes, if it is impossible to eliminate the committed violations of personal data by the Operator, unless otherwise provided by the federal law.
4.2. Personal data processing conditions
4.2.1. The operator processes personal data in the presence of at least one of the following conditions:
§ processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
§ the processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or the law, to implement and fulfill the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation;
§ the processing of personal data is necessary for the administration of justice, the execution of judicial acts, the actions of another body or authorized person to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;
§ the processing of personal data is necessary for the execution of the contract, which is either beneficiary or guarantor is a personal data subject, as well as for the conclusion of a contract under which the personal data subject will be the beneficiary or guarantor;
§ 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 this does not violate the rights and freedoms of the subject of personal data;
§ the processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request ( referred to as publicly available personal data);
§ the processing of personal data, to publication or mandatory disclosure in accordance with federal law is carried out.
4.2.2. PD processing is terminated, and collected PDs are destroyed or termination of PD processing and their destruction is ensured (if processing is carried out by another person acting on behalf of the Operator) in the following cases and within the time established by Federal Law No. 152, unless otherwise provided by the legislation of the Russian Federation:
§ upon expiration of the established period for processing PD;
§ upon reaching the purposes of processing PD or when the loss of the need to achieve them;
§ upon withdrawal by the PD subject of consent to the processing of his PD, if such consent is required in accordance with the legislation of the Russian Federation;
§ at the request of the subject of PD or the Authorized body for the protection of the rights of subjects of PD - if personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
§ in case of revealing illegal processing of personal data by the Operator or by a person acting on his behalf, if it is impossible to ensure the legitimacy of processing personal data.
4.3 Purpose of processing personal data. The Operator processes the personal data of the PD subject to achieve the goals stipulated by the international treaty of the Russian Federation or the law, to carry out and fulfill the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation, as well as to provide the user with information about the services provided, special offers and other information on behalf of the Operator; conducting marketing and other research; implementation of civil law relations.
4.4 Confidentiality of personal data The Operator and other persons who have gained the 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 the federal law.
4.5. An order to process personal data to another person 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 federal law, on the basis of an agreement concluded with that person. A person who processes personal data on behalf of the Operator is required to comply with the principles and rules for the processing of personal data provided for in Federal Law-152 and this Policy. The operator has the right to transfer personal data of the subject of personal data to third parties in the following cases:
§ the PD subject expressed his consent to such actions;
§ the transfer is necessary for the execution of the contract or the provision of the service, where the party or beneficiary is the subject of personal data,
§ the transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;
§ such a transfer occurs within the framework of a sale or other transfer of a business (in whole or in part), and all obligations to comply with the terms of this Policy with respect to received PD are transferred to the acquirer. The operator may carry out cross-border transfer of PD in cases stipulated by the legislation of the Russian Federation, treaties and agreements with international organizations or companies. At the same time, the provisions on ensuring adequate protection of the rights of PD subjects (including provisions on ensuring the safety of PD) should be included in these treaties and agreements.
5. Rights of the subject of personal data The subject of personal data has the right to receive information regarding the processing of his personal data, including containing: - confirmation of the fact of processing personal data by the operator; - legal grounds and purposes of processing personal data; - purposes and methods used by the operator for processing personal data; - name and location of the operator, information about persons (with the exception of operator's employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the operator or on the basis of federal law; - processed personal data relating to the relevant subject of personal data, the source of their receipt, unless otherwise provided for by federal law; - terms for processing personal data, including periods for their storage; - the procedure for the exercise by the subject of personal data of the rights provided for by the Law "About Personal Data"; - information on completed or proposed cross-border data transfer; - name or surname, name, middle name and address of the person who processes personal data on behalf of the operator, if processing is or will be entrusted to such a person; - other information provided by this Law or other federal laws. A PD subject has the right to require the operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take measures prescribed by law to protect their rights.
6. Ensuring the security of personal data The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection. To prevent unauthorized access to personal data by the Operator, the following organizational and technical measures are applied:
§ the appointment of officials responsible for organizing the processing and protection of personal data;
§ limiting the composition of persons allowed to process personal data;
§ familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator for the processing and protection of personal data;
§ organization of accounting, storage and circulation of media containing information with personal data;
§ verification of the readiness and effectiveness of the use of information security;
§ use of antivirus and recovery tools for the protection of personal data;
§ the use of firewalls, intrusion detection, security analysis and cryptographic information protection tools, if necessary. Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data. Operator employees guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws. Using the site, the subject of PD expresses their specific and informed consent with this Policy. If the user does not agree with this Policy, he must immediately leave the site. Further use of the site after making changes to this policy will be considered as the consent of the user (PD subject) with these changes.
1. General Provisions
1.1. The policy regarding the processing and protection of personal data is developed in accordance with Federal Law of July 27, 2006 No. 152-ФЗ "About Personal Data" (further - ФЗ-152). This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in SP Silvashi S.A. (location address: 394016, Voronezh, Moskovsky Prospect, 56. OGRNIP 319463200005671, TIN 463241942186) (further - Operator) in order to protect the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of rights to privacy, personal and family secrets.
1.2. In this Policy the following basic concepts are used: - automated processing of personal data - processing of personal data using computer technology; - blocking of personal data - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data); - the totality of personal data contained in the databases and the processing of information technologies and technical means; - depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific subject of personal data; - processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval , use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data; - personal data - any information relating directly or indirectly to a defined or determined individual (subject of personal data); - provision of personal data - actions aimed at disclosing personal data to a specific person or a certain people; - spread of personal data - actions aimed at the disclosure of personal data to an indefinite number of persons (transfer of personal data) or to familiarization with personal data of an unlimited number of people, including the publication of personal data in the media, placement in information and telecommunication networks or providing access personal data in any other way; - destruction of personal data - actions, as a result of which it is impossible to restore 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. The operator is obliged to publish or otherwise provide unlimited access to this Policy for the processing of personal data in accordance with Part 2 of Art. 18.1. FZ 152.
1.3 The operator has the right to make changes to the Policy. When making changes in a current edition, the date of the last update is indicated. The new version of the Policy comes out from the moment it is posted on the Operator's website, unless otherwise provided by the new version of the Policy. The current version of the Policy is always on the website in public access at: https://silvashi.com Personal data of the subject of personal data The subject of personal data decides to provide his personal data and agrees to its processing freely, by his own will and in his interests. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form allowing confirming the fact of its receipt, unless otherwise provided by federal law or the terms of the Regulation. By entering personal data in a web form on the Operator's website, by clicking the "Send" button, the personal data subject (PD subject) decides to provide his personal data and agrees to its processing by his own will and in his interest, and such consent of the PD subject is concrete and conscious. The site administration does not verify the accuracy of the personal information provided by the subjects of PD, and does not verify their legal capacity. At the same time, the Site Administration proceeds from the fact that the information transmitted by it from users is reliable. The subject of PD is responsible for the provision of personal data of a third party. Personal data entered by the PD subject when filling out the web form can be used by the Site Administration to prepare and send an offer, complete a transaction, perform a service or improve the quality of services.
3. Processing of personal data of subjects of personal data Acceptance of the terms of this Policy regarding provisions for the processing of personal data is carried out by affixing the subject of personal data the appropriate mark when filling out any web form on the Operator's website and is the expressed informed consent of the subject of personal data to the processing of personal data. PD subject agrees that the Site Administration has the right to store and process, including automated, any information related to the user's personal data in accordance with Federal Law of July 27, 2006 No. 152-FZ "About Personal Data", including collection, systematization, accumulation, storage, clarification, use, distribution (including transfer), depersonalization, blocking, destruction of personal data provided by the user when filling out a web form on the Operator's website. Consent to the processing of personal data can be revoked at any time by the subject of personal information by written request to the site Administration. If the user withdraws consent to the processing of personal data, the Site Administration deletes the personal data of the subject of personal data and cannot use it in the future.
4. Principles and conditions for the processing of personal data
4.1. Principles of processing personal data Processing of personal data with the Operator is based on the following principles:
§ legality and fair basis;
§ restrictions on the processing of personal data by achieving specific, predetermined and legitimate goals;
§ preventing personal data processing incompatible with the purposes of collecting personal data;
§ processing only those personal data that meet the purposes of their processing; compliance of the content and volume of processed personal data with the declared processing goals;
§ preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;
§ ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
§ destruction or depersonalization of personal data upon achievement of the purposes of its processing or in case of loss of need to achieve these purposes, if it is impossible to eliminate the committed violations of personal data by the Operator, unless otherwise provided by the federal law.
4.2. Personal data processing conditions
4.2.1. The operator processes personal data in the presence of at least one of the following conditions:
§ processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
§ the processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or the law, to implement and fulfill the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation;
§ the processing of personal data is necessary for the administration of justice, the execution of judicial acts, the actions of another body or authorized person to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;
§ the processing of personal data is necessary for the execution of the contract, which is either beneficiary or guarantor is a personal data subject, as well as for the conclusion of a contract under which the personal data subject will be the beneficiary or guarantor;
§ 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 this does not violate the rights and freedoms of the subject of personal data;
§ the processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request ( referred to as publicly available personal data);
§ the processing of personal data, to publication or mandatory disclosure in accordance with federal law is carried out.
4.2.2. PD processing is terminated, and collected PDs are destroyed or termination of PD processing and their destruction is ensured (if processing is carried out by another person acting on behalf of the Operator) in the following cases and within the time established by Federal Law No. 152, unless otherwise provided by the legislation of the Russian Federation:
§ upon expiration of the established period for processing PD;
§ upon reaching the purposes of processing PD or when the loss of the need to achieve them;
§ upon withdrawal by the PD subject of consent to the processing of his PD, if such consent is required in accordance with the legislation of the Russian Federation;
§ at the request of the subject of PD or the Authorized body for the protection of the rights of subjects of PD - if personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
§ in case of revealing illegal processing of personal data by the Operator or by a person acting on his behalf, if it is impossible to ensure the legitimacy of processing personal data.
4.3 Purpose of processing personal data. The Operator processes the personal data of the PD subject to achieve the goals stipulated by the international treaty of the Russian Federation or the law, to carry out and fulfill the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation, as well as to provide the user with information about the services provided, special offers and other information on behalf of the Operator; conducting marketing and other research; implementation of civil law relations.
4.4 Confidentiality of personal data The Operator and other persons who have gained the 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 the federal law.
4.5. An order to process personal data to another person 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 federal law, on the basis of an agreement concluded with that person. A person who processes personal data on behalf of the Operator is required to comply with the principles and rules for the processing of personal data provided for in Federal Law-152 and this Policy. The operator has the right to transfer personal data of the subject of personal data to third parties in the following cases:
§ the PD subject expressed his consent to such actions;
§ the transfer is necessary for the execution of the contract or the provision of the service, where the party or beneficiary is the subject of personal data,
§ the transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;
§ such a transfer occurs within the framework of a sale or other transfer of a business (in whole or in part), and all obligations to comply with the terms of this Policy with respect to received PD are transferred to the acquirer. The operator may carry out cross-border transfer of PD in cases stipulated by the legislation of the Russian Federation, treaties and agreements with international organizations or companies. At the same time, the provisions on ensuring adequate protection of the rights of PD subjects (including provisions on ensuring the safety of PD) should be included in these treaties and agreements.
5. Rights of the subject of personal data The subject of personal data has the right to receive information regarding the processing of his personal data, including containing: - confirmation of the fact of processing personal data by the operator; - legal grounds and purposes of processing personal data; - purposes and methods used by the operator for processing personal data; - name and location of the operator, information about persons (with the exception of operator's employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the operator or on the basis of federal law; - processed personal data relating to the relevant subject of personal data, the source of their receipt, unless otherwise provided for by federal law; - terms for processing personal data, including periods for their storage; - the procedure for the exercise by the subject of personal data of the rights provided for by the Law "About Personal Data"; - information on completed or proposed cross-border data transfer; - name or surname, name, middle name and address of the person who processes personal data on behalf of the operator, if processing is or will be entrusted to such a person; - other information provided by this Law or other federal laws. A PD subject has the right to require the operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take measures prescribed by law to protect their rights.
6. Ensuring the security of personal data The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection. To prevent unauthorized access to personal data by the Operator, the following organizational and technical measures are applied:
§ the appointment of officials responsible for organizing the processing and protection of personal data;
§ limiting the composition of persons allowed to process personal data;
§ familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator for the processing and protection of personal data;
§ organization of accounting, storage and circulation of media containing information with personal data;
§ verification of the readiness and effectiveness of the use of information security;
§ use of antivirus and recovery tools for the protection of personal data;
§ the use of firewalls, intrusion detection, security analysis and cryptographic information protection tools, if necessary. Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data. Operator employees guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws. Using the site, the subject of PD expresses their specific and informed consent with this Policy. If the user does not agree with this Policy, he must immediately leave the site. Further use of the site after making changes to this policy will be considered as the consent of the user (PD subject) with these changes.
"RIGRAISER RUS" LLC policy regarding the processing and protection of personal data
1. General Provisions
1.1. The policy regarding the processing and protection of personal data is developed in accordance with Federal Law of July 27, 2006 No. 152-ФЗ "About Personal Data" (further - ФЗ-152). This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in SP Lekontseva A. Legal address of the company:12 Kutuzovsky Avenue, Corp/St. 10, quarter. 2/I/1, Moscow, Russia, 121248, INN: 7730254770 (further - Operator) in order to protect the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of rights to privacy, personal and family secrets.
1.2. In this Policy the following basic concepts are used: - automated processing of personal data - processing of personal data using computer technology; - blocking of personal data - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data); - the totality of personal data contained in the databases and the processing of information technologies and technical means; - depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific subject of personal data; - processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval , use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data; - personal data - any information relating directly or indirectly to a defined or determined individual (subject of personal data); - provision of personal data - actions aimed at disclosing personal data to a specific person or a certain people; - spread of personal data - actions aimed at the disclosure of personal data to an indefinite number of persons (transfer of personal data) or to familiarization with personal data of an unlimited number of people, including the publication of personal data in the media, placement in information and telecommunication networks or providing access personal data in any other way; - destruction of personal data - actions, as a result of which it is impossible to restore 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. The operator is obliged to publish or otherwise provide unlimited access to this Policy for the processing of personal data in accordance with Part 2 of Art. 18.1. FZ 152.
1.3 The operator has the right to make changes to the Policy. When making changes in a current edition, the date of the last update is indicated. The new version of the Policy comes out from the moment it is posted on the Operator's website, unless otherwise provided by the new version of the Policy. The current version of the Policy is always on the website in public access at: https://silvashi.com Personal data of the subject of personal data The subject of personal data decides to provide his personal data and agrees to its processing freely, by his own will and in his interests. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form allowing confirming the fact of its receipt, unless otherwise provided by federal law or the terms of the Regulation. By entering personal data in a web form on the Operator's website, by clicking the "Send" button, the personal data subject (PD subject) decides to provide his personal data and agrees to its processing by his own will and in his interest, and such consent of the PD subject is concrete and conscious. The site administration does not verify the accuracy of the personal information provided by the subjects of PD, and does not verify their legal capacity. At the same time, the Site Administration proceeds from the fact that the information transmitted by it from users is reliable. The subject of PD is responsible for the provision of personal data of a third party. Personal data entered by the PD subject when filling out the web form can be used by the Site Administration to prepare and send an offer, complete a transaction, perform a service or improve the quality of services.
3. Processing of personal data of subjects of personal data Acceptance of the terms of this Policy regarding provisions for the processing of personal data is carried out by affixing the subject of personal data the appropriate mark when filling out any web form on the Operator's website and is the expressed informed consent of the subject of personal data to the processing of personal data. PD subject agrees that the Site Administration has the right to store and process, including automated, any information related to the user's personal data in accordance with Federal Law of July 27, 2006 No. 152-FZ "About Personal Data", including collection, systematization, accumulation, storage, clarification, use, distribution (including transfer), depersonalization, blocking, destruction of personal data provided by the user when filling out a web form on the Operator's website. Consent to the processing of personal data can be revoked at any time by the subject of personal information by written request to the site Administration. If the user withdraws consent to the processing of personal data, the Site Administration deletes the personal data of the subject of personal data and cannot use it in the future.
4. Principles and conditions for the processing of personal data
4.1. Principles of processing personal data Processing of personal data with the Operator is based on the following principles:
§ legality and fair basis;
§ restrictions on the processing of personal data by achieving specific, predetermined and legitimate goals;
§ preventing personal data processing incompatible with the purposes of collecting personal data;
§ processing only those personal data that meet the purposes of their processing; compliance of the content and volume of processed personal data with the declared processing goals;
§ preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;
§ ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
§ destruction or depersonalization of personal data upon achievement of the purposes of its processing or in case of loss of need to achieve these purposes, if it is impossible to eliminate the committed violations of personal data by the Operator, unless otherwise provided by the federal law.
4.2. Personal data processing conditions
4.2.1. The operator processes personal data in the presence of at least one of the following conditions:
§ processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
§ the processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or the law, to implement and fulfill the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation;
§ the processing of personal data is necessary for the administration of justice, the execution of judicial acts, the actions of another body or authorized person to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;
§ the processing of personal data is necessary for the execution of the contract, which is either beneficiary or guarantor is a personal data subject, as well as for the conclusion of a contract under which the personal data subject will be the beneficiary or guarantor;
§ 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 this does not violate the rights and freedoms of the subject of personal data;
§ the processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request ( referred to as publicly available personal data);
§ the processing of personal data, to publication or mandatory disclosure in accordance with federal law is carried out.
4.2.2. PD processing is terminated, and collected PDs are destroyed or termination of PD processing and their destruction is ensured (if processing is carried out by another person acting on behalf of the Operator) in the following cases and within the time established by Federal Law No. 152, unless otherwise provided by the legislation of the Russian Federation:
§ upon expiration of the established period for processing PD;
§ upon reaching the purposes of processing PD or when the loss of the need to achieve them;
§ upon withdrawal by the PD subject of consent to the processing of his PD, if such consent is required in accordance with the legislation of the Russian Federation;
§ at the request of the subject of PD or the Authorized body for the protection of the rights of subjects of PD - if personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
§ in case of revealing illegal processing of personal data by the Operator or by a person acting on his behalf, if it is impossible to ensure the legitimacy of processing personal data.
4.3 Purpose of processing personal data. The Operator processes the personal data of the PD subject to achieve the goals stipulated by the international treaty of the Russian Federation or the law, to carry out and fulfill the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation, as well as to provide the user with information about the services provided, special offers and other information on behalf of the Operator; conducting marketing and other research; implementation of civil law relations.
4.4 Confidentiality of personal data The Operator and other persons who have gained the 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 the federal law.
4.5. An order to process personal data to another person 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 federal law, on the basis of an agreement concluded with that person. A person who processes personal data on behalf of the Operator is required to comply with the principles and rules for the processing of personal data provided for in Federal Law-152 and this Policy. The operator has the right to transfer personal data of the subject of personal data to third parties in the following cases:
§ the PD subject expressed his consent to such actions;
§ the transfer is necessary for the execution of the contract or the provision of the service, where the party or beneficiary is the subject of personal data,
§ the transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;
§ such a transfer occurs within the framework of a sale or other transfer of a business (in whole or in part), and all obligations to comply with the terms of this Policy with respect to received PD are transferred to the acquirer. The operator may carry out cross-border transfer of PD in cases stipulated by the legislation of the Russian Federation, treaties and agreements with international organizations or companies. At the same time, the provisions on ensuring adequate protection of the rights of PD subjects (including provisions on ensuring the safety of PD) should be included in these treaties and agreements.
5. Rights of the subject of personal data The subject of personal data has the right to receive information regarding the processing of his personal data, including containing: - confirmation of the fact of processing personal data by the operator; - legal grounds and purposes of processing personal data; - purposes and methods used by the operator for processing personal data; - name and location of the operator, information about persons (with the exception of operator's employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the operator or on the basis of federal law; - processed personal data relating to the relevant subject of personal data, the source of their receipt, unless otherwise provided for by federal law; - terms for processing personal data, including periods for their storage; - the procedure for the exercise by the subject of personal data of the rights provided for by the Law "About Personal Data"; - information on completed or proposed cross-border data transfer; - name or surname, name, middle name and address of the person who processes personal data on behalf of the operator, if processing is or will be entrusted to such a person; - other information provided by this Law or other federal laws. A PD subject has the right to require the operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take measures prescribed by law to protect their rights.
6. Ensuring the security of personal data The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection. To prevent unauthorized access to personal data by the Operator, the following organizational and technical measures are applied:
§ the appointment of officials responsible for organizing the processing and protection of personal data;
§ limiting the composition of persons allowed to process personal data;
§ familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator for the processing and protection of personal data;
§ organization of accounting, storage and circulation of media containing information with personal data;
§ verification of the readiness and effectiveness of the use of information security;
§ use of antivirus and recovery tools for the protection of personal data;
§ the use of firewalls, intrusion detection, security analysis and cryptographic information protection tools, if necessary. Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data. Operator employees guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws. Using the site, the subject of PD expresses their specific and informed consent with this Policy. If the user does not agree with this Policy, he must immediately leave the site. Further use of the site after making changes to this policy will be considered as the consent of the user (PD subject) with these changes.
1. General Provisions
1.1. The policy regarding the processing and protection of personal data is developed in accordance with Federal Law of July 27, 2006 No. 152-ФЗ "About Personal Data" (further - ФЗ-152). This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in SP Silvashi S.A. (location address: 394016, Voronezh, Moskovsky Prospect, 56. OGRNIP 319463200005671, TIN 463241942186) (further - Operator) in order to protect the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of rights to privacy, personal and family secrets.
1.2. In this Policy the following basic concepts are used: - automated processing of personal data - processing of personal data using computer technology; - blocking of personal data - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data); - the totality of personal data contained in the databases and the processing of information technologies and technical means; - depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific subject of personal data; - processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval , use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data; - personal data - any information relating directly or indirectly to a defined or determined individual (subject of personal data); - provision of personal data - actions aimed at disclosing personal data to a specific person or a certain people; - spread of personal data - actions aimed at the disclosure of personal data to an indefinite number of persons (transfer of personal data) or to familiarization with personal data of an unlimited number of people, including the publication of personal data in the media, placement in information and telecommunication networks or providing access personal data in any other way; - destruction of personal data - actions, as a result of which it is impossible to restore 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. The operator is obliged to publish or otherwise provide unlimited access to this Policy for the processing of personal data in accordance with Part 2 of Art. 18.1. FZ 152.
1.3 The operator has the right to make changes to the Policy. When making changes in a current edition, the date of the last update is indicated. The new version of the Policy comes out from the moment it is posted on the Operator's website, unless otherwise provided by the new version of the Policy. The current version of the Policy is always on the website in public access at: https://silvashi.com Personal data of the subject of personal data The subject of personal data decides to provide his personal data and agrees to its processing freely, by his own will and in his interests. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form allowing confirming the fact of its receipt, unless otherwise provided by federal law or the terms of the Regulation. By entering personal data in a web form on the Operator's website, by clicking the "Send" button, the personal data subject (PD subject) decides to provide his personal data and agrees to its processing by his own will and in his interest, and such consent of the PD subject is concrete and conscious. The site administration does not verify the accuracy of the personal information provided by the subjects of PD, and does not verify their legal capacity. At the same time, the Site Administration proceeds from the fact that the information transmitted by it from users is reliable. The subject of PD is responsible for the provision of personal data of a third party. Personal data entered by the PD subject when filling out the web form can be used by the Site Administration to prepare and send an offer, complete a transaction, perform a service or improve the quality of services.
3. Processing of personal data of subjects of personal data Acceptance of the terms of this Policy regarding provisions for the processing of personal data is carried out by affixing the subject of personal data the appropriate mark when filling out any web form on the Operator's website and is the expressed informed consent of the subject of personal data to the processing of personal data. PD subject agrees that the Site Administration has the right to store and process, including automated, any information related to the user's personal data in accordance with Federal Law of July 27, 2006 No. 152-FZ "About Personal Data", including collection, systematization, accumulation, storage, clarification, use, distribution (including transfer), depersonalization, blocking, destruction of personal data provided by the user when filling out a web form on the Operator's website. Consent to the processing of personal data can be revoked at any time by the subject of personal information by written request to the site Administration. If the user withdraws consent to the processing of personal data, the Site Administration deletes the personal data of the subject of personal data and cannot use it in the future.
4. Principles and conditions for the processing of personal data
4.1. Principles of processing personal data Processing of personal data with the Operator is based on the following principles:
§ legality and fair basis;
§ restrictions on the processing of personal data by achieving specific, predetermined and legitimate goals;
§ preventing personal data processing incompatible with the purposes of collecting personal data;
§ processing only those personal data that meet the purposes of their processing; compliance of the content and volume of processed personal data with the declared processing goals;
§ preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;
§ ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
§ destruction or depersonalization of personal data upon achievement of the purposes of its processing or in case of loss of need to achieve these purposes, if it is impossible to eliminate the committed violations of personal data by the Operator, unless otherwise provided by the federal law.
4.2. Personal data processing conditions
4.2.1. The operator processes personal data in the presence of at least one of the following conditions:
§ processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
§ the processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or the law, to implement and fulfill the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation;
§ the processing of personal data is necessary for the administration of justice, the execution of judicial acts, the actions of another body or authorized person to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;
§ the processing of personal data is necessary for the execution of the contract, which is either beneficiary or guarantor is a personal data subject, as well as for the conclusion of a contract under which the personal data subject will be the beneficiary or guarantor;
§ 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 this does not violate the rights and freedoms of the subject of personal data;
§ the processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request ( referred to as publicly available personal data);
§ the processing of personal data, to publication or mandatory disclosure in accordance with federal law is carried out.
4.2.2. PD processing is terminated, and collected PDs are destroyed or termination of PD processing and their destruction is ensured (if processing is carried out by another person acting on behalf of the Operator) in the following cases and within the time established by Federal Law No. 152, unless otherwise provided by the legislation of the Russian Federation:
§ upon expiration of the established period for processing PD;
§ upon reaching the purposes of processing PD or when the loss of the need to achieve them;
§ upon withdrawal by the PD subject of consent to the processing of his PD, if such consent is required in accordance with the legislation of the Russian Federation;
§ at the request of the subject of PD or the Authorized body for the protection of the rights of subjects of PD - if personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
§ in case of revealing illegal processing of personal data by the Operator or by a person acting on his behalf, if it is impossible to ensure the legitimacy of processing personal data.
4.3 Purpose of processing personal data. The Operator processes the personal data of the PD subject to achieve the goals stipulated by the international treaty of the Russian Federation or the law, to carry out and fulfill the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation, as well as to provide the user with information about the services provided, special offers and other information on behalf of the Operator; conducting marketing and other research; implementation of civil law relations.
4.4 Confidentiality of personal data The Operator and other persons who have gained the 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 the federal law.
4.5. An order to process personal data to another person 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 federal law, on the basis of an agreement concluded with that person. A person who processes personal data on behalf of the Operator is required to comply with the principles and rules for the processing of personal data provided for in Federal Law-152 and this Policy. The operator has the right to transfer personal data of the subject of personal data to third parties in the following cases:
§ the PD subject expressed his consent to such actions;
§ the transfer is necessary for the execution of the contract or the provision of the service, where the party or beneficiary is the subject of personal data,
§ the transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;
§ such a transfer occurs within the framework of a sale or other transfer of a business (in whole or in part), and all obligations to comply with the terms of this Policy with respect to received PD are transferred to the acquirer. The operator may carry out cross-border transfer of PD in cases stipulated by the legislation of the Russian Federation, treaties and agreements with international organizations or companies. At the same time, the provisions on ensuring adequate protection of the rights of PD subjects (including provisions on ensuring the safety of PD) should be included in these treaties and agreements.
5. Rights of the subject of personal data The subject of personal data has the right to receive information regarding the processing of his personal data, including containing: - confirmation of the fact of processing personal data by the operator; - legal grounds and purposes of processing personal data; - purposes and methods used by the operator for processing personal data; - name and location of the operator, information about persons (with the exception of operator's employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the operator or on the basis of federal law; - processed personal data relating to the relevant subject of personal data, the source of their receipt, unless otherwise provided for by federal law; - terms for processing personal data, including periods for their storage; - the procedure for the exercise by the subject of personal data of the rights provided for by the Law "About Personal Data"; - information on completed or proposed cross-border data transfer; - name or surname, name, middle name and address of the person who processes personal data on behalf of the operator, if processing is or will be entrusted to such a person; - other information provided by this Law or other federal laws. A PD subject has the right to require the operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take measures prescribed by law to protect their rights.
6. Ensuring the security of personal data The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection. To prevent unauthorized access to personal data by the Operator, the following organizational and technical measures are applied:
§ the appointment of officials responsible for organizing the processing and protection of personal data;
§ limiting the composition of persons allowed to process personal data;
§ familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator for the processing and protection of personal data;
§ organization of accounting, storage and circulation of media containing information with personal data;
§ verification of the readiness and effectiveness of the use of information security;
§ use of antivirus and recovery tools for the protection of personal data;
§ the use of firewalls, intrusion detection, security analysis and cryptographic information protection tools, if necessary. Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data. Operator employees guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws. Using the site, the subject of PD expresses their specific and informed consent with this Policy. If the user does not agree with this Policy, he must immediately leave the site. Further use of the site after making changes to this policy will be considered as the consent of the user (PD subject) with these changes.
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