1. General provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC SMP "Mark IV" (hereinafter referred to as the Operator).
1.1. The Operator considers it its most important goal and condition for carrying out its activities to respect the rights and freedoms of man and citizen in the processing of his personal data, including protection of the rights to inviolability of private life, personal and family secrets.
1.2. This Operator's policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://mark4.ru
/en.2. Main concepts used in Policy
2.1. Automated processing of personal data - processing of personal data using computer equipment.
2.2. Blocking of personal data - temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website - a combination of graphic and informational materials, as well as computer programs and databases that provide accessibility in the internet network at the network address https://mark4.ru.
2.4. Personal data information system - a combination of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization 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 User or other personal data subject.
2.6. Personal data processing is any action (operation) or combination of actions (operations) performed using automated means or without such means with personal data, including collection, recording, systematization, accumulation, storage, refinement (updating, alteration), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. The operator is a government agency, municipal body, legal or physical person who independently or jointly with others organizes and (or) carries out the processing of personal data, as well as determines the objectives of personal data processing, the composition of personal data to be processed, the actions (operations) performed with personal data.
2.8. Personal data is any information related directly or indirectly to a specific or determinable User of the website https://mark4.ru/en.
2.9. Personal data permitted by the personal data subject for dissemination - personal data that is accessible to everyone as a result of the personal data subject's consent to its dissemination or distribution through the Internet.
2.10. User - Any visitor to the website https://mark4.ru.
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 undefined circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the mass media, placing in information and telecommunications 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 physical or legal person.
2.14. Destruction of personal data - any actions as a result of which personal data is destroyed irreversibly without the possibility of further restoration of the content of personal data in the personal data information system.3. Main rights and obligations of the Operator
3.1. Operator's main rights and obligations:
- The operator has the right to receive reliable information and/or documents containing personal data from the data subject.
- In case of revocation of the data subject's consent to the processing of personal data, the operator is entitled to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law.
- To independently determine the composition and list of measures necessary and sufficient to fulfill the obligations provided for by the Personal Data Law and the normative 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 obligated to:
4. Main rights and obligations of personal data subjects
- Provide the data subject with information concerning the processing of their personal data upon request;
- Organize the processing of personal data in accordance with the provisions of Russian Federation law;
- Respond to inquiries and requests from data subjects and their authorized representatives in accordance with the requirements of the Law on Personal Data;
- Report to the authorized body for the protection of the rights of personal data subjects upon request within 30 days from the date of receipt of such a request;
- Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
- Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, and from other unauthorized actions regarding personal data;
- Cease the transfer (dissemination, provision, access) of personal data if the requirements for the processing of personal data are not fulfilled;
- Ensure the confidentiality of personal data during its processing.
4.1. Personal data subjects have the right to:
- receive information about the processing of their personal data, except for cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data relating to other personal data subjects, except for cases when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
- require the operator to clarify its personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the declared processing purpose, as well as take measures provided for by law to protect their rights;
- impose a condition of prior consent for processing personal data for the purpose of promoting goods, works, and services on the market;
- recall the consent to process personal data for direct marketing purposes;
- object to the processing of personal data for purposes of carrying out statistical surveys, or for other research purposes;
- take measures provided for by law to protect its rights if the personal data is processed in violation of the requirements of the law.
4.2. Subjects of personal data are obliged to:
- provide the Operator with reliable information about themselves;
- inform the Operator of any clarifications (updates, changes) to their personal data.
4.3. Persons who provide unreliable information about themselves or information about another subject of personal data without the latter's consent shall be held responsible in accordance with Russian Federation legislation.5. The operator can process the following User personal data:
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymous data about visitors (including "cookies" files) using internet statistics services (such as Yandex Metrica and Google Analytics, among others).
5.6. Processing of special categories of personal data regarding race, national origin, political views, religious or philosophical beliefs, sexual life is not carried out by the Operator.
5.7. Processing of personal data that is permitted for distribution from the special categories of personal data listed in sec. 1 of Art. 10 of the Personal Data Law is allowed, if the prohibitions and conditions specified in sec. 10.1 of the Personal Data Law are observed.
5.8. User's consent for processing of personal data permitted for dissemination is given separately from other consents for processing their personal data. This shall be in accordance with the provisions, in particular, of Article 10.1 of the Personal Data Law. The requirements for the content of such consent shall be established by the authorized body for protection of the rights of personal data subjects.
5.8.1 User provides Operator directly with consent for processing of personal data permitted for dissemination.
5.8.2 The Operator is obliged within three working days from receipt of the User's specified consent to publish information about the processing conditions, the presence of restrictions and conditions for the processing of personal data permitted for dissemination to an unlimited circle of individuals.
5.8.3 Transfer (dissemination, provision, access) of personal data permitted for dissemination by the personal data subject must be terminated at any time upon the request of the personal data subject. This request must include the cessation of further dissemination and storage of the personal data6. 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 the achievement of specific, previously defined and lawful purposes. Processing of personal data that is inconsistent with the purposes of collecting personal data is not allowed.
6.3. Merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, is not allowed.
6.4. Processing is only allowed for personal data that meets the purposes of processing.
6.5. The content and volume of processed personal data corresponds to the declared processing purposes. Excessive processing of personal data in relation to the declared processing purposes is not allowed.
6.6. When processing personal data, the accuracy of personal data, its sufficiency, and if necessary, its relevance to the processing purposes of personal data are ensured. The operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows the identification of the personal data subject, not longer than required by the processing purposes of personal data, unless the storage period of personal data is established by federal law, a contract of which the personal data subject is a party, beneficiary or guarantor. The processed personal data is destroyed or anonymized upon achieving the processing goals or in case of loss of necessity to achieve these goals, unless otherwise provided by federal law.7. The objectives of personal data processing:
7.1. The purpose of processing User's personal data:
- informing the User by sending emails;
- conclusion, execution, and termination of civil-law contracts;
- providing the User access to the services, information, and/or materials contained on the website https://mark4.ru/en.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending the Operator an email to the email address firstname.lastname@example.org/en with the subject "Opt-out from notifications of new products and services and special offers".
7.3. The anonymized data of Users collected through internet statistics services is used to collect information about User actions on the site, improve the quality of the site and its content.8. Legal basis for processing personal data
8.1. The legal basis for processing personal data by the Operator are:
- the charter (founding) documents of the Operator;
- agreements entered into between the operator and the personal data subject;
- federal laws and other normative legal acts in the field of personal data protection;
- Users' consent to the processing of their personal data, consent to the processing of personal data that is permitted for dissemination.
8.2. The Operator processes the User's personal data only in the case of their filling in and/or sending by the User themselves through special forms located on the website https://mark4.ru
or sent to the Operator via email. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.4. The personal data subject independently determines the scope of their personal data that they provide to the Operator during their use of the https://mark4.ru
website. The personal data subject has the right to refuse to provide personal data, however, this may result in the inability to use some services of the website.9. Conditions for processing personal data
9.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.
9.2. Processing of personal data is necessary to achieve the goals specified in an international agreement of the Russian Federation or by law, to perform the functions, powers and responsibilities imposed by legislation of the Russian Federation on the operator.
9.3. Processing of personal data is necessary to enforce the law, execute a court order, act of another body or official, which must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the execution of a contract, of which the subject of personal data is either the beneficiary or the guarantor, and also for the conclusion of a contract initiated by the subject of personal data or a contract in which the subject of personal data will be the beneficiary or guarantor.
9.5. Processing of personal data is necessary for the exercise of the operator's rights and lawful interests or for the achievement of publicly significant goals provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Processing of personal data is carried out, access to which is provided by the subject of personal data or at his request to an unlimited circle of persons (hereinafter referred to as publicly accessible personal data).
9.7. Processing of personal data that is to be published or mandatory disclosure is carried out in accordance with federal law.10. The Order of Collection, Storage, Transfer, and Other Forms of Processing Personal Data
The safety of personal data processed by the Operator is ensured by the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
10.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. User's personal data will never be transferred to third parties, except for cases related to the execution of current legislation or if the personal data subject has given the Operator consent to transfer the data to a third party for the fulfillment of obligations under a civil-law contract.
10.3. In case of inaccuracies in personal data, the User can update it independently by sending a notification to the Operator's email address email@example.com with the note "Updating personal data."
10.4. The processing time for personal data is determined by the achievement of the goals for which the personal data was collected, unless a different time is specified by agreement or applicable legislation. The user may revoke their consent to processing of personal data at any time by sending a notification to the Operator via email to firstname.lastname@example.org with the subject "Withdrawal of consent for processing of personal data."
10.6. The restrictions imposed by the data subject on the transfer (other than providing access) and on the processing or conditions of processing (other than accessing) of personal data allowed for dissemination do not apply in the case of processing personal data in the public, state, and other public interests as defined by the legislation of the Russian Federation.
10.7. The operator ensures the confidentiality of personal data when processing it.
10.8. The operator stores personal data in a form that allows identifying the data subject, not longer than is required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, agreement, by a party, by a beneficiary, or by a guarantor of which the data subject is.
10.9. The condition for discontinuing the processing of personal data may be the attainment of the purposes of processing personal data, the expiration of the data subject's consent period, or the revocation of the data subject's consent...11. Actions performed by the Operator with the received personal data:
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (disseminates, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The Operator carries out automated processing of personal data, obtaining and/or transmitting the information obtained through information and telecommunications networks or without such networks.12. Cross-Border Transfer of Personal Data
12.1. Before carrying out a cross-border transfer of personal data, the operator must ensure that the foreign state to which the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
12.2. The cross-border transfer of personal data to foreign states that do not meet the aforementioned requirements may only be carried out with the written consent of the personal data subject or in the case of the execution of a contract with the personal data subject as a party.13. Confidentiality of Personal Data
The operator and other persons who have 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 federal law.14. Final Provisions
14.1. The user can receive any clarifications on questions of interest regarding the processing of their personal data by addressing the Operator through email email@example.com
14.2. Any changes in the processing of personal data policy by the Operator will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://mark4.ru/privacy