Рolicy on personal data processing
General provisions and key terms
This Personal Data Processing Policy is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Personal Data Law) and establishes the procedure for processing personal data and measures to ensure security of personal data.
This Operator's policy regarding processing of personal data (hereinafter - the Policy) applies to all information which the Operator can obtain about the visitors of this website. 2.
2 Basic concepts used in the Policy
2.1 Automated processing of personal data - processing of personal data by means of computer equipment.
2.2 Blocking of personal data - is temporary termination of processing of personal data (except when the processing is necessary to clarify personal data)
2.3 Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet.
2.4 Personal data information system - a set of personal data contained in databases of personal data, and information technology and technical means ensuring their processing.
2.5 Anonymisation of personal data - actions, as a result of which it is impossible to determine, without the use of additional information, whether the personal data belongs to a particular User or another subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including 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 authority, legal entity or individual, independently or jointly with other persons, arranging and (or) carrying out processing of personal data, as well as determining the purpose of personal data processing, composition of personal data to be processed, actions (operations) performed with personal data.
2.8 Personal data - any information relating directly or indirectly to a particular or definable user of this site.
2.9. Personal data, authorized by the subject for distribution - personal data, access to which is granted to an unlimited range of persons by the subject of personal data by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, authorized for distribution).
2.10. User - any visitor to this site.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or to familiarize an unlimited circle of persons with personal data, including 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. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any action, as a result of which personal data is destroyed irretrievably with impossibility to further restore the content of personal data in the information system of personal data and (or) destroyed material media of personal data.
3 The basic rights and obligations of the Operator
3.1 The Operator has the right:
3.1.1 To receive from the subject of personal data reliable information and/or documents containing personal data;
3.1.2 In case the personal data subject withdraws their consent to the processing of personal data, the operator has the right to continue the processing of personal data without the consent of the personal data subject, if there are grounds specified in the Personal Data Law;
3.1.3 Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2 The Operator shall:
3.2.1 Provide to the subject of personal data, upon his/her request, information concerning the processing of his/her personal data;
3.2.2 Organize processing of personal data in the manner prescribed by applicable laws of the Russian Federation;
3.2.3. Respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
3.2.4. Inform the authorized body on protection of rights of subjects of personal data, on request of such body, necessary information within 30 days from the date of receipt of such request;
3.2.5 Publish or otherwise provide unrestricted access to this Policy on personal data processing;
3.2.6 Take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful actions in relation to personal data;
3.2.7 To stop transfer (distribution, provision, access) of personal data, to stop processing and to destroy personal data in the manner and cases provided by the Personal Data Law;
3.2.8 To perform other duties provided by the Personal Data Law.
4 Main rights and obligations of subjects of personal data
4.1 Personal data subjects have the right to:
4.1.1 Receive information relating to the processing of their personal data, except in cases stipulated by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
4.1.2 Demand that the operator clarify its personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and to take statutory measures to protect its rights;
4.1.3 To impose the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
4.1.4 To withdraw consent to personal data processing;
4.1.5 To complain to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or omissions of the Operator in the processing of his personal data;
4.1.6. To exercise other rights provided by the legislation of the Russian Federation.
4.2 Personal data subjects shall:
4.2.1. Provide the Operator with reliable data about themselves;
4.2.2 notify the Operator of the specification (updating, changing) of their personal data. 4.3.
Persons, who provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Russian Federation. 5.
5. The operator may process the following personal data of the User
Surname, first name, middle name, and patronymic 5.1.
Email address 5.2)
Phone numbers 5.3) and 5.4)
5.4 The site also collects and processes visitors' anonymized data from Internet statistical services (Yandex Metrika, Google Analytics and others).
5.5 The above-mentioned data are combined hereinafter in the text of the Policy with the general concept of Personal Data.
5.6 The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, and intimate life
5.7 Processing of personal data, authorized for dissemination, from among special categories of personal data, specified in Part 1 of Article 10 of the Personal Data Law, is allowed if the prohibitions and conditions stipulated by Article 10.1 of the Personal Data Law are observed.
5.8 The User's consent to the processing of personal data that is permitted for dissemination shall be executed separately from other consents to the processing of their personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. The requirements for the content of such consent shall be established by the competent authority for the protection of personal data subjects' rights.
5.8.1 The User's consent to the processing of personal data permitted for dissemination shall be provided by the User directly to the Operator.
5.8.2 The Operator shall, within three working days of receiving the User's consent, publish information about the processing conditions, prohibitions and conditions on the processing of personal data permitted for distribution to an unlimited number of persons.
5.8.3 The transfer (distribution, provision, access) of personal data, authorized by the subject of personal data for distribution, must be terminated at any time at the request of the subject of personal data. This requirement shall include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or mailing address) of the subject of personal data, as well as a list of personal data, processing of which shall be discontinued. The personal data specified in this request may only be processed by the Operator to which it is sent.
5.8.4. Consent to the processing of personal data, authorized for distribution, shall cease upon receipt by the Operator of the request, specified in paragraph 5.8.3 of this Policy in relation to the processing of personal data.
6. Principles of Personal Data Processing
6.1 Processing of personal data is carried out on a lawful and fair basis.
6.2 Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
6.3 Databases containing personal data, which are processed for purposes incompatible with each other, shall not be combined.
6.4 Only personal data that meets the purposes of processing shall be processed.
6.5 The content and scope of processed personal data correspond to the stated processing purposes. The redundancy of processed personal data in relation to the stated processing purposes shall not be allowed. 6.6.
When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purpose of personal data processing shall be ensured. The operator shall take necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
6.7 Personal data shall be stored in a form that makes it possible to identify the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalized upon attainment of processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.
7. Purposes of processing of personal data
7.1 Purpose of Processing of Personal Data of the User:
7.1.1 Informing the User by sending emails;
7.1.2.Concluding, executing and terminating civil law contracts;
7.1.3 Providing access to the User to the services, information and/or materials contained on the website.
7.2 Also the Operator has the right to send the User notifications about new products and services, special offers and different events. The User can always refuse to receive information messages by sending a letter to the Operator's e-mail address.
7.3 The anonymized data of the Users, collected with the help of Internet statistics services, serves for collecting information about the User's actions on the website, improving the quality of the website and its content.
8. Legal Basis for Processing of Personal Data
8.1 The legal basis for the processing of personal data by the Operator is:
8.1.1 List the laws and regulations governing the relationship related to your activities, for example, if your activities are related to information technology, in particular the creation of sites, then you can specify here the Federal Law "On Information, Information Technology and Information Protection" of 27.07.2006 N 149-FZ;
8.1.2. The statutory documents of the Operator;
8.1.3. Contracts entered into between the Operator and the subject of personal data;
8.1.4. Federal laws and other regulations in the area of personal data protection;
8.1.5. Consents of Users for the processing of their personal data, for the processing of personal data permitted for dissemination.
8.2. The Operator processes the User's personal data only in case the User fills them in and/or sends them by himself through the special forms located on the site or sent to the Operator by e-mail. By filling out the relevant forms and/or sending his personal data to the Operator, the User expresses his consent to this Policy.
8.3 The Operator processes impersonal data about the User if this is allowed in the User's browser settings (file saving and the use of JavaScript technology is enabled).
8.4 The subject of personal data independently decides to provide his personal data and gives consent freely, willingly and in his own interest.
9. Conditions for the processing of personal data
9.1 Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2 Processing of personal data is necessary for achievement of the objectives envisaged by an international treaty of the Russian Federation or by law, for implementation of the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
9.3 Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4 Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which the personal data subject is a party, as well as for conclusion of an agreement on the initiative of the personal data subject or an agreement, under which the personal data subject will be a beneficiary or guarantor.
9.5 Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially important goals, provided that this does not violate the rights and freedoms of the subject of personal data.
9.6 Personal data shall be processed if access to such data is granted to an unlimited number of persons by or at the request of the personal data subject (hereinafter, "publicly available personal data").
9.7 Processing of personal data subject to publication or mandatory disclosure in accordance with federal law (posted on the ruscred.site).
10. Procedure for collecting, storing, transferring and otherwise processing personal data
10.1. the operator shall ensure the safety of personal data and shall take all possible measures to exclude access to personal data by unauthorized persons.
10.2 The personal data of the User will never, under no circumstances be transmitted to third parties, except in cases related to the execution of the current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
10.3 In case of detection of inaccuracies in the personal data, the User may update them independently, by sending a notice to the Operator's e-mail address marked "Updating of personal data".
10.4 The term of processing of personal data is determined by achieving the purposes for which the personal data was collected, unless a different term is stipulated by the contract or by applicable law. The user may withdraw their consent to the processing of personal data at any time by sending a notice via email to the Operator's email address marked "Withdrawal of consent to the processing of personal data".
10.5 All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to get acquainted with the specified documents on his/her own in time. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.
10.6 The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or processing conditions (other than gaining access) of personal data permitted for distribution, shall not apply in cases of processing of personal data in state, public and other public interests as defined by Russian legislation.
10.7. The Operator ensures the confidentiality of personal data when processing personal data.
10.8. The operator shall store personal data in a form that allows to identify the subject of personal data, no longer than the objectives of personal data processing require, unless the period of storage of personal data is established by federal law, a contract, a party to which, a beneficiary or a guarantor under which the subject of personal data is a party.
10.9 A condition for termination of personal data processing may be achievement of personal data processing objectives, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as detection of unlawful personal data processing.
11. List of actions performed by the operator with received personal data
11.1 The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transmits (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
11.2 The operator carries out automated processing of personal data with or without receipt and/or transfer of received information via information and telecommunications networks.
12. cross-border transfer of personal data
12.1 The operator is obliged to make sure that the foreign country, to the territory of which the transfer of personal data is supposed to be carried out, provides reliable protection of personal data subjects' rights before starting trans-border transfer of personal data.
12.2 The transborder transfer of personal data to foreign countries, which do not meet the above requirements, may take place only if the personal data subject consents in writing to the transborder transfer of his/her personal data and / or fulfillment of the contract, to which the personal data subject is a party.
13. Confidentiality of personal data
13.1 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 subject of personal data, unless otherwise provided by federal law.
14. Final provisions
14.1 The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator by email.
14.2 This document will reflect any changes in the personal data processing policy of the Operator. The policy is valid indefinitely until replaced by a new version.
What is the Privacy Policy?
The Privacy Policy is an important document that discloses the ways in which a site collects and uses personal (private) information about its users. Almost every website collects information about its visitors in one way or another. This can be forms for applications, call backs, personal accounts, e-mail subscriptions, cookies, and so on. Such a resource must comply with privacy policy when collecting and storing personal data. By law, the document must be freely available on the site itself.
Why is it needed?
By law to protect the personal data of users.
Can I download a free example?
Sure, that's why we are here! Download or copy a sample Privacy Policy, paste your data and put it on your website. That's it, you're ready to use it. Everything is absolutely free.
Will this Privacy Policy template work for a Bitrix online store?
It is quite suitable. This is a universal template for any website.
What does the policy file contain?
In general terms, the user must give mandatory consent, the owner must not transfer data to third parties, and there is an explanation of what data is collected and for what purposes.
What are the responsibilities for not having a privacy policy on the site?
If a resource collects information but does not have a privacy policy file, it is a violation of the Federal Law 152 "On Personal Data" of 27.07.2006. There is an administrative penalty for the owner.