Personal data processing policy
1. General provisions
This personal data processing policy has been drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 «On Personal Data» (hereinafter — the Personal Data Law) and sets out the procedure for processing personal data and the security measures taken by ООО «АКАДЕМИЯ АЛГОРИТМОВ ДИЗАЙНА» (hereinafter — the Operator).
1.1. The Operator regards respect for human and civil rights and freedoms in the processing of personal data — including the right to privacy and to personal and family confidentiality — as the paramount aim and condition of its activity.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website http://designalgorithm.ru.
2. Key terms used in the Policy
2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary suspension of processing (except where processing is necessary to correct the data).
2.3. Website — the set of graphic and information materials, computer programs and databases that make them available on the internet at the address http://designalgorithm.ru.
2.4. Personal data information system — the set of personal data contained in databases together with the information technologies and technical means used to process them.
2.5. Anonymisation of personal data — actions after which it is impossible, without additional information, to attribute the personal data to a specific User or other data subject.
2.6. Processing of personal data — any action or set of actions performed on personal data with or without automation, including collection, recording, systematisation, accumulation, storage, correction (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.
2.7. Operator — a state or municipal body, legal entity or individual which, alone or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of processing, the categories of personal data to be processed and the operations performed on them.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website http://designalgorithm.ru.
2.9. Personal data authorised by the data subject for distribution — personal data to which access by an unlimited number of persons has been granted by the data subject through consent to the processing of personal data authorised for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data authorised for distribution).
2.10. User — any visitor to the website http://designalgorithm.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 group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in the media, posting on information and telecommunication networks or granting 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 public authority, or to a foreign individual or legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed, with no possibility of recovering their content in the personal data information system, and/or the physical media containing the personal data are destroyed.
3. Principal rights and obligations of the Operator
3.1. The Operator has the right to: receive from the data subject accurate information and/or documents containing personal data; where the data subject withdraws consent to processing or submits a request to stop processing, continue processing without the data subject's consent on the grounds set out in the Personal Data Law; determine on its own the composition and list of measures necessary and sufficient to fulfil the obligations laid down by the Personal Data Law and the regulations adopted thereunder, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to: provide the data subject, at their request, with information concerning the processing of their personal data; organise the processing of personal data in the manner established by the applicable law of the Russian Federation; respond to enquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law; provide the authorised body for the protection of data subjects' rights with the necessary information within 10 days of receiving its request; publish or otherwise ensure unrestricted access to this Policy; take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions; stop transferring and processing personal data and destroy them in the cases and in the manner provided for by the Personal Data Law; fulfil the other obligations laid down by the Personal Data Law.
4. Principal rights and obligations of data subjects
4.1. Data subjects have the right to: receive information concerning the processing of their personal data, except in the cases provided for by federal laws; require the operator to correct, block or destroy their personal data if the data are incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing; make processing for the purpose of promoting goods, works and services subject to their prior consent; withdraw consent to processing and submit a request to stop processing; appeal against unlawful acts or omissions of the Operator to the authorised body for the protection of data subjects' rights or in court; exercise the other rights provided for by the law of the Russian Federation.
4.2. Data subjects are obliged to: provide the Operator with accurate information about themselves; inform the Operator of any correction (updating, change) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or with information about another data subject without that subject's consent, bear liability in accordance with the law of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data are processed on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, pre-defined and lawful purposes. Processing that is incompatible with the purposes of collection is not permitted.
5.3. It is not permitted to merge databases containing personal data processed for mutually incompatible purposes.
5.4. Only personal data that correspond to the purposes of their processing are processed.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Personal data that are excessive in relation to those purposes are not processed.
5.6. When processing personal data, their accuracy and sufficiency and, where necessary, their currency in relation to the purposes of processing are ensured. The Operator takes, or ensures the taking of, the necessary measures to delete or correct incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. The personal data processed are destroyed or anonymised once the purposes of processing have been achieved or when there is no longer any need to achieve them, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing — to give the User access to the services, information and/or materials on the website. Personal data: surname, first name and patronymic; email address; telephone numbers. Legal grounds: the Operator's constituent documents; contracts concluded between the operator and the data subject. Types of processing: collection, recording, systematisation, accumulation, storage, destruction and anonymisation of personal data.
7. Conditions for processing personal data
7.1. Personal data are processed with the data subject's consent to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties assigned to the operator by Russian legislation.
7.3. The processing of personal data is necessary for the administration of justice and for the enforcement of a judicial act or an act of another body or official subject to enforcement under Russian legislation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, and for concluding a contract at the data subject's initiative.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or of third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not thereby infringed.
7.6. Personal data are processed to which access by an unlimited number of persons has been granted by the data subject or at their request (hereinafter — publicly available personal data).
7.7. Personal data are processed that are subject to publication or mandatory disclosure under federal law.
8. Procedure for collecting, storing, transferring and otherwise processing personal data
The security of the personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to comply in full with the requirements of the applicable personal data protection legislation.
8.1. The Operator ensures the safekeeping of personal data and takes every possible measure to prevent access to personal data by unauthorised persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except where required by the applicable law or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies are found in the personal data, the User may update them by sending the Operator a notice to p.moro@techne-group.com marked «Updating of personal data».
8.4. The period of processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by contract or by the applicable law. The User may withdraw consent to processing at any time by sending the Operator a notice by email to p.moro@techne-group.com marked «Withdrawal of consent to the processing of personal data».
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by those parties (Operators) in accordance with their own user agreements and privacy policies. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions established by the data subject on the transfer (other than granting access), and on the processing or conditions of processing (other than obtaining access) of personal data authorised for distribution do not apply where personal data are processed in state, public or other public interests defined by Russian legislation.
8.7. When processing personal data, the Operator ensures their confidentiality.
8.8. The Operator stores personal data in a form that allows the data subject to be identified for no longer than the purposes of processing require.
8.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiry of the data subject's consent, withdrawal of consent or a request to stop processing, or upon detection of unlawful processing of personal data.
9. List of actions performed by the Operator with the personal data received
9.1. The Operator collects, records, systematises, accumulates, stores, corrects (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymises, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the information obtained over information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before starting any cross-border transfer of personal data, the Operator must notify the authorised body for the protection of data subjects' rights of its intention to carry out such transfers.
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign public authorities, foreign individuals or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons who have obtained access to personal data must not disclose them to third parties or distribute them without the data subject's consent, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarification on questions concerning the processing of their personal data by contacting the Operator by email at p.moro@techne-group.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at http://designalgorithm.ru/privacy.