Data Protection Policy
1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 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 undertaken by ATSAL LLC (hereinafter — the Operator).
1.1. The Operator’s most important goal and condition for carrying out its activities is the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s 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://atsal.com.
2. Basic concepts used in the Policy
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://atsal.com.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymisation of personal data — actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data 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 with or without the use of automation means on personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual, organising and/or carrying out the processing of personal data independently or jointly with other persons, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or determinable User of the website https://atsal.com.
2.9. Personal data authorised for dissemination by the subject of personal data — personal data to which access by an unlimited circle of persons is granted by the subject of personal data by giving consent to the processing of personal data authorised by the subject of personal data for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data authorised for dissemination).
2.10. User — any visitor to the website https://atsal.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarising an unlimited circle of persons with personal data, including publishing personal data in the mass media, posting 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 actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
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;
— in the event that the subject of personal data revokes consent to the processing of personal data, as well as sends a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
— to provide the subject of personal data, upon their request, with information concerning the processing of their personal data;
— to organise the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— to respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— to notify the authorised body for the protection of the rights of subjects of personal data, at the request of that body, of the necessary information within 10 days from the date of receipt of such request;
— to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— to take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
— to stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to perform other obligations provided for by the Personal Data Law.
4. Basic rights and obligations of subjects of personal data
4.1. Subjects of personal data have the right:
— to receive information concerning 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 shall not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— to require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
— to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
— to revoke consent to the processing of personal data, as well as to submit a request to cease processing of personal data;
— to appeal to the authorised body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged:
— to provide the Operator with reliable data about themselves;
— to inform the Operator of any clarification (updating, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of processing personal data
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Merging of databases containing personal data, the processing of which is carried out 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 scope of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed 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, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that makes it possible to identify the subject of personal data, for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data are destroyed or anonymised upon achievement of the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided for by federal law.
6. Purposes of processing personal data
| Purpose of processing | informing the User by sending emails |
|---|---|
| Personal data |
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| Legal grounds |
|
| Types of processing of personal data |
|
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 the functions, powers and duties assigned by the legislation of the Russian Federation to the operator.
7.3. Processing of personal data is necessary for the administration of justice, the 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, beneficiary or guarantor, as well as for the conclusion of 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 socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data to which access by an unlimited circle of persons is granted by the subject of personal data or at their request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for collection, storage, transfer and other types of processing of personal data
Procedure for collection, storage, transfer and other types of processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organisational and technical measures necessary to fully comply with the requirements of 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 prevent unauthorised persons from accessing personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfil obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator at the Operator’s email address [email protected] with the note “Updating of personal data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the contract or current legislation.
The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator by email to the Operator’s email address [email protected] with the note “Revocation of consent to the processing of personal data”.
8.5. All information that is collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data should familiarise themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data authorised for dissemination, established by the subject of personal data, do not apply in cases of processing personal data in state, public and other public interests determined 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 makes it possible to identify the subject of personal data, for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for termination of processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, revocation of consent by the subject of personal data or a request to cease processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before commencing activities on the cross-border transfer of personal data, the Operator is obliged to notify the authorised body for the protection of the rights of subjects of personal data 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 is obliged to obtain relevant information from the foreign state authorities, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
12. Final provisions
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://atsal.com/privacy-policy/