Personal Data Processing Policy
Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been drawn up
in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006
“On Personal Data” (hereinafter —
the Personal Data Law) and defines the procedure for processing
personal data and measures to ensure the security of personal
data taken by LLC “Master Plit” (hereinafter — the Operator).
1.1. The Operator’s most important goal and condition for carrying out
its activities is respect for the rights and freedoms of individuals
when processing their personal data, including protection of the right
to privacy, personal and family secrets.
1.2. This Operator policy regarding the processing of personal
data (hereinafter — the Policy) applies to all information
that the Operator may obtain about visitors to the website https://mp-khv.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 suspension
of processing of personal data (except in cases where 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://mp-khv.ru/.
2.4. Personal data information system — a combination
of personal data contained in databases and information
technologies and technical means that ensure
their processing.
2.5. Depersonalization of personal data — actions
as a result of which it is impossible to determine, without using
additional information, whether personal data belong to a specific
User or other subject of personal data.
2.6. Processing of personal data — any action (operation)
or set of actions (operations) performed using
automation tools or without using such tools
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 body,
legal entity or individual that independently or jointly with other
persons organizes and/or carries out the processing of personal data,
as well as determines the purposes of processing personal data, the composition
of personal data to be processed, and the actions (operations) performed
with personal data.
2.8. Personal data — any information
relating directly or indirectly to a specific or identifiable
User of the website https://mp-khv.ru/.
2.9. Personal data permitted by the subject of personal data for
distribution, — personal data to which unlimited
access has been granted by the subject of personal data by giving consent to the processing of personal data permitted by the subject
of personal data for distribution in the manner provided for by
the Personal Data Law (hereinafter — personal data
permitted for distribution).
2.10. User — any visitor to the website https://mp-khv.ru/.
2.11. Provision of personal data — actions aimed
at disclosing personal data to a specific person or a specific
group of persons.
2.12. Distribution of personal data — any actions
aimed at disclosing personal data to an indefinite circle of persons
(transfer of personal data) or at familiarizing an unlimited circle of persons with personal
data, including publication
of personal data in the 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 an authority
of a foreign state, a foreign individual, or a foreign
legal entity.
2.14. Destruction of personal data — any actions
as a result of which personal data are destroyed irreversibly
with no possibility of further restoration of the content of personal
data in the personal data information system
and/or destruction of
material carriers of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data reliable
information and/or documents containing personal data;
— if the subject of personal data withdraws consent
to the processing of personal data, as well as when sending a request
to stop processing personal data,
the Operator may continue processing personal data without the consent
of the subject of personal data if there are grounds specified in the
Personal Data Law;
— independently determine the composition and list of measures
necessary and sufficient to ensure fulfillment of obligations
provided for by the Personal Data Law and regulatory legal acts adopted
in accordance with it, unless otherwise
provided for by the Personal Data Law or other
federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, at their request,
with information regarding the processing of their personal data;
— organize the processing of personal data in the manner
established by the current legislation of the Russian Federation;
— respond to inquiries and requests from subjects
of personal data and their lawful representatives
in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights
of subjects of personal data, at the request of that body, with the necessary
information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unlimited access
to this Policy on personal data processing;
— take legal, organizational, and technical measures to
protect personal data from unlawful or accidental access
to them, destruction, modification, blocking, copying,
provision, distribution of personal data, as well as
from other unlawful actions regarding personal data;
— stop transfer (distribution, provision, access)
of personal data, stop processing, and destroy personal
data in the manner and cases provided for by the
Personal Data Law;
— fulfill other obligations provided for by the
Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal
data, except in cases provided for 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 lawful grounds for
disclosure of such personal data. The list of information and the procedure
for obtaining it are established by the Personal Data Law;
— require the operator to clarify their personal data,
block or destroy them in cases where personal data are
incomplete, outdated, inaccurate, unlawfully obtained, or
not necessary for the stated purpose of processing, as well as
take measures provided by law to protect their rights;
— require prior consent when processing
personal data for the purpose of promoting goods, works,
and services on the market;
— withdraw consent to the processing of personal data,
as well as send a request to stop processing
personal data;
— appeal to the authorized body for the protection of the rights
of personal data subjects or to a court regarding unlawful
actions or inaction of the Operator when processing their personal data;
— exercise other rights provided for by
the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator about clarification (updating, modification)
of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or
information about another subject of personal data without the latter’s consent
bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful
and fair basis.
5.2. Processing of personal data is limited to achieving specific,
predetermined, and lawful purposes. Processing of
personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal
data processed for purposes incompatible with
each other is not permitted.
5.4. Only personal data that meet the purposes of
their processing are subject to processing.
5.5. The content and volume of processed personal data
correspond to the stated purposes of processing. Excessive
processing of personal data in relation to the stated purposes of
their processing is not permitted.
5.6. When processing personal data, the accuracy of personal
data, their sufficiency, and, where necessary,
relevance in relation to the purposes of processing personal
data are ensured. The Operator takes the necessary measures and/or ensures
their adoption to delete or clarify incomplete or inaccurate
data.
5.7. Personal data are stored in a form that allows
identification of the subject of personal data for no longer than required by
the purposes of processing personal data, unless the retention period of personal data
is established by federal law, contract, or the subject
of personal data is a party, beneficiary, or guarantor under such a contract. Processed personal data are destroyed or
depersonalized upon achievement of the processing purposes or if there is no longer a need
to achieve these purposes, unless otherwise provided for by
federal law.
6. Purposes of Personal Data Processing
| Purpose of processing | informing the User by sending emails |
|---|---|
| Personal data |
|
| Legal grounds |
|
| Types of personal data processing |
|
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the
subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes
provided for by an international treaty of the Russian Federation or by law,
to perform functions, powers, and obligations imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice,
execution of a judicial act, an act of another body or official
subject to execution in accordance with the legislation of the
Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract,
to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding a contract
at the initiative of the subject of personal data or a contract under
which the subject of personal data will be a
beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights
and legitimate interests of the operator or third parties, or to achieve
publicly significant goals, provided that the rights
and freedoms of the subject of personal data are not violated.
7.6. Processing is carried out of personal data to which unlimited
access has been granted by the subject of personal data or
at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out of personal data subject to publication
or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator
is ensured through the implementation of legal, organizational, and technical
measures necessary to fully comply with the requirements of the current
legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes
all possible measures to exclude access to personal data by
unauthorized persons.
8.2. The User’s personal data will never, under any circumstances,
be transferred to third parties, except in cases related
to compliance with current legislation or if
the subject of personal data has given consent to the Operator to transfer
data to a third party for the performance of obligations under
a civil law contract.
8.3. If inaccuracies in personal data are identified,
the User may update them independently by sending
a notice to the Operator’s email address office@mp-khv.ru
with the subject line “Personal data update”.
8.4. The period of processing of personal data is determined by the achievement of the purposes for
which personal data were collected, unless another period
is provided for by contract or current
legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notice by email to the Operator’s email address office@mp-khv.ru with the subject line “Withdrawal of consent to personal data processing”.
The User may at any time withdraw their consent to the processing of personal data by sending a notice by email to the Operator’s email address office@mp-khv.ru with the subject line “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including
payment systems, communication tools, and other service providers,
is stored and processed by those persons (Operators)
in accordance with their User Agreement
and Privacy Policy. The subject of personal data
is responsible for familiarizing themselves with those documents. The Operator is not responsible
for the actions of third parties, including the service providers
specified in this paragraph.
8.6. Restrictions established by the subject of personal data on transfer
(except provision of access), as well as on processing or conditions
of processing (except obtaining access) of personal data permitted for
distribution do not apply in cases of processing personal
data in state, public, and other public interests
defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures
the confidentiality of personal data.
8.8. The Operator stores personal data in a form that
allows identification of the subject of personal data for no longer than
required by the purposes of processing personal data, unless the retention period of
personal data is established by federal law, contract,
or the subject of personal data is a party, beneficiary, or guarantor under such a contract.
8.9. Conditions for termination of processing of personal data may include
achievement of the purposes of processing personal data, expiration of the
consent of the subject of personal data, withdrawal of consent by the subject of personal
data or a request to stop processing personal data,
as well as detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation,
storage, clarification (updating, modification), extraction, use,
transfer (distribution, provision, access), depersonalization,
blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data
with receipt and/or transfer of received information
via information and telecommunication networks or without such transfer.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving
cross-border transfer of personal data, the Operator must notify
the authorized body for the protection of the rights of personal data subjects
of its intention to carry out cross-border transfer of personal
data (such notification is sent separately from the notification
of intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain
relevant information from authorities of a foreign state, foreign individuals,
or foreign legal entities to whom cross-border transfer of
personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged
not to disclose personal data to third parties and not to distribute personal
data without the consent of the subject of personal data, unless otherwise
provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on matters
relating to the processing of their personal data by contacting
the Operator by email at office@mp-khv.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected
in this document. The Policy is valid indefinitely
until it is replaced by a new version.
12.3. The current version of the Policy is freely available
on the Internet at https://mp-khv.ru/licenses-personal-data/.
