Privacy Policy
Personal Data Processing Policy
1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by "128" LLC (hereinafter referred to as the Operator).
1.1. The Operator's most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including protection of the right to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://128-bpm.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 personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website – a combination of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://128-bpm.ru.
2.4. Personal Data Information System – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of Personal Data – actions that make it impossible, without using additional information, to determine the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of Personal Data – any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, 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 who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, 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://128-bpm.ru.
2.9. Personal Data Permitted by the Data Subject for Distribution – personal data to which access by an unlimited number of persons has been provided by the data subject by giving consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as Personal Data Permitted for Distribution).
2.10. User – any visitor to the website https://128-bpm.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 making personal data available to an unlimited number of persons, including the publication of personal data in the media, placement 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 individual, or a foreign legal entity.
2.14. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive from the personal data subject reliable information and/or documents containing personal data;
— In the event of the personal data subject withdrawing consent to the processing of personal data, as well as submitting a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment 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 personal data subject, upon their request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Report to the authorized body for the protection of the rights of personal data subjects, upon request of that body, the necessary information within 10 days from the date of receipt of such request;
— Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions regarding personal data;
— Cease the transfer (distribution, provision, access) of personal data, cease 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 personal data subject by the Operator in an accessible form and should not contain personal data relating to other personal data subjects, except in cases where 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;
— Demand that the operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— Impose a condition of 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 submit a request to cease processing personal data;
— Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in 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 reliable information about themselves;
— Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The 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 allowed.
5.3. Merging databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in the event of the loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Informing the User by sending emails
Personal data:
· Last name, first name, patronymic
· Phone numbers
Legal grounds: Agreements concluded between the operator and the personal data subject
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
7. Conditions for Processing Personal Data
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to fulfill the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Personal data processing 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. Personal data processing is necessary for the execution of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding 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.
7.5. Personal data processing 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 personal data subject are not violated.
7.6. Processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
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 Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, 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 security of personal data and takes all possible measures to prevent 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 the execution of current legislation or if the personal data subject 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. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address privacy@thismywebsite.com with the note "Personal Data Update."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation.
The User may at any time withdraw consent to the processing of personal data by sending the Operator a notification via email to the Operator's email address privacy@thismywebsite.com with the note "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to independently familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, 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. The Operator, when processing personal data, ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Conditions for terminating the processing of personal data may include the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to cease processing 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 performs 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 performs automated processing of personal data with receipt and/or transmission of the received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities on cross-border transfer of personal data, the Operator is obliged to 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 is obliged to obtain from the authorities of the foreign state, foreign individuals, foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained 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.
12. Final Provisions
12.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at privacy@thismywebsite.com.
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://128-bpm.ru.
1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by "128" LLC (hereinafter referred to as the Operator).
1.1. The Operator's most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including protection of the right to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://128-bpm.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 personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website – a combination of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://128-bpm.ru.
2.4. Personal Data Information System – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of Personal Data – actions that make it impossible, without using additional information, to determine the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of Personal Data – any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, 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 who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, 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://128-bpm.ru.
2.9. Personal Data Permitted by the Data Subject for Distribution – personal data to which access by an unlimited number of persons has been provided by the data subject by giving consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as Personal Data Permitted for Distribution).
2.10. User – any visitor to the website https://128-bpm.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 making personal data available to an unlimited number of persons, including the publication of personal data in the media, placement 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 individual, or a foreign legal entity.
2.14. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive from the personal data subject reliable information and/or documents containing personal data;
— In the event of the personal data subject withdrawing consent to the processing of personal data, as well as submitting a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment 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 personal data subject, upon their request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Report to the authorized body for the protection of the rights of personal data subjects, upon request of that body, the necessary information within 10 days from the date of receipt of such request;
— Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions regarding personal data;
— Cease the transfer (distribution, provision, access) of personal data, cease 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 personal data subject by the Operator in an accessible form and should not contain personal data relating to other personal data subjects, except in cases where 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;
— Demand that the operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— Impose a condition of 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 submit a request to cease processing personal data;
— Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in 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 reliable information about themselves;
— Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The 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 allowed.
5.3. Merging databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in the event of the loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Informing the User by sending emails
Personal data:
· Last name, first name, patronymic
· Phone numbers
Legal grounds: Agreements concluded between the operator and the personal data subject
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
7. Conditions for Processing Personal Data
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to fulfill the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Personal data processing 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. Personal data processing is necessary for the execution of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding 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.
7.5. Personal data processing 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 personal data subject are not violated.
7.6. Processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
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 Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, 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 security of personal data and takes all possible measures to prevent 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 the execution of current legislation or if the personal data subject 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. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address privacy@thismywebsite.com with the note "Personal Data Update."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation.
The User may at any time withdraw consent to the processing of personal data by sending the Operator a notification via email to the Operator's email address privacy@thismywebsite.com with the note "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to independently familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, 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. The Operator, when processing personal data, ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Conditions for terminating the processing of personal data may include the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to cease processing 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 performs 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 performs automated processing of personal data with receipt and/or transmission of the received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities on cross-border transfer of personal data, the Operator is obliged to 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 is obliged to obtain from the authorities of the foreign state, foreign individuals, foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained 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.
12. Final Provisions
12.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at privacy@thismywebsite.com.
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://128-bpm.ru.