Personal Data Processing Policy
1. General Provisions
This personal data processing policy is compiled in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ “On Personal Data” (hereinafter referred to as the “Law on Personal Data”) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by ООО “Alex” (hereinafter referred to as the “Operator”).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of man and citizen in the processing of his/her 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 referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the website https://alex-ltd.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 cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://alex-ltd.ru/.
2.4. Personal data information system — a collection of personal data contained in databases and information technologies and technical means that ensure 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 belonging 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 using automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, 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://alex-ltd.ru/.
2.9. Personal data authorized by the subject of personal data for distribution — personal data, access to which an unlimited number of persons is granted by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in accordance with the procedure provided for by the Law on Personal Data (hereinafter referred to as “personal data authorized for distribution”).
2.10. User — any visitor to the website https://alex-ltd.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. Dissemination 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 — the transfer of personal data to the territory of a foreign state to a government 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 irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
Receive accurate information and/or documents containing personal data from the subject of personal data;
In the event that the subject of personal data withdraws consent to the processing of personal data, as well as submits a request to terminate the 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 Law on Personal Data;
Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
Provide the subject of personal data, at his/her request, with information regarding the processing of his/her personal data;
Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
Report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 10 days from the date of receipt of such a 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 unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
Terminate the transfer (dissemination, provision, access) of personal data, terminate processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
Fulfill other obligations stipulated by the Law on Personal Data.
4. Main Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:
Receive information regarding the processing of their personal data, with the exception of cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it 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 Law on Personal Data;
Require the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
Put forward 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 to send a request to terminate the processing of personal data;
Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator in the processing of 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 data about themselves;
Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the consent of the latter, 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 legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of its processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data, for no longer than the purposes of processing personal data require, unless the storage period of personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of Processing | Informing the User by sending emails |
| Personal Data | Name, middle name, address, phone numbers |
| Legal Basis | Agreements concluded between the operator and the personal data subject |
| Types of Personal Data Processing | Recording, systematization, accumulation, storage, destruction, and anonymization of personal data |
7. Conditions for Processing Personal Data
7.1. Personal data is processed with the consent of the personal data subject to the processing of his/her 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 a law, to exercise the functions, powers, and obligations assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, which are subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is either a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed, access to which an unlimited number of persons is granted by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
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 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 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 fulfillment of obligations under a civil law contract.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address foundersm@yandex.ru with the note “Personal Data Update”.
8.4. The term of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different term is provided for by a contract or current legislation.
The user may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator by e-mail to the Operator’s e-mail address foundersm@yandex.ru with the note “Withdrawal of consent to the processing of personal data.”
8.5. All information that is collected by third-party services, including payment systems, communication facilities, 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 and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases of personal data processing in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, for no longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. A condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the validity period of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (disseminates, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before starting activities on the 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 the cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the 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 to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can get any clarification on questions of interest regarding the processing of his personal data by contacting the Operator via email foundersm@yandex.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://alex-ltd.ru/en/policy/.
