Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ «On Personal Data» dated July 27, 2006 (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 undertaken by Anna Valeryevna Bystrova, Sole Proprietor (hereinafter referred to as the «Operator»).
1.1. The Operator’s highest priority goal and condition for its operations is the observance of human and citizen’s rights and freedoms when processing their personal data, including the 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://webnbpro.com/.
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 personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphical and informational materials, as well as computer programs and databases ensuring their availability on the internet at the network address https://webnbpro.com/.
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. Anonymization of personal data — actions resulting in the impossibility 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 with or without the use of automation 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 or natural person, independently or jointly with other persons organizing and/or processing personal data, as well as determining 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://webnbpro.com/.
2.9. Personal data permitted by the data subject for dissemination – 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 dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as «personal data permitted for dissemination»).
2.10. User – any visitor to the website https://webnbpro.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 familiarizing an unlimited circle of persons with personal data, including the publication of personal data in 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 authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of the material media of personal data.
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 case the data subject revokes consent to the processing of personal data, the Operator has the right to continue processing personal data without the data subject’s consent 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 fulfillment of obligations stipulated by the Personal Data Law and adopted normative legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
* To provide the data subject, upon their request, with information regarding the processing of their personal data;
* To organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
* To respond to appeals and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
* To report to the authorized body for the protection of the rights of data subjects, upon request of this body, the necessary information within 30 days from the date of receipt of such request;
* To publish or otherwise provide unrestricted access to this Policy on the processing of personal data;
* To take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions regarding personal data;
* To 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;
* To perform other duties stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data Subjects have the right:
* To receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form and shall not contain personal data relating to other 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;
* To demand from the Operator the clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and to take legal measures to protect their rights;
* To set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
* To withdraw consent to the processing of personal data;
* To appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or inaction of the Operator during the processing of their personal data;
* To exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data Subjects are obliged:
* To provide the Operator with accurate data about themselves;
* To inform the Operator about the clarification (updating, change) of their personal data.
4.3. Persons who provided the Operator with inaccurate information about themselves or information about another data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Personal Data of the User that the Operator may process
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The site also collects and processes anonymized data about visitors (including «cookies») using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The aforementioned data are hereinafter collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data permitted for dissemination, from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law, is permitted if the prohibitions and conditions stipulated by Article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for dissemination is executed separately from other consents to the processing of their personal data. The conditions stipulated, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of data subjects.
5.8.1 Consent to the processing of personal data permitted for dissemination is provided by the User directly to the Operator.
5.8.2 The Operator is obliged to publish, no later than three business days from the receipt of the said User consent, information about the processing conditions, prohibitions, and conditions for processing by an unlimited number of persons of personal data permitted for dissemination.
5.8.3 The transfer (distribution, provision, access) of personal data permitted by the data subject for dissemination must be terminated at any time at the request of the data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request can only be processed by the Operator to whom it is directed.
5.8.4 Consent to the processing of personal data permitted for dissemination ceases to be effective from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
6.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
6.4. Only personal data that meets the purposes of their processing is subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data relative to the stated purposes of their processing is not permitted.
6.6. 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.
6.7. Storage of personal data is carried out in a form that allows identification of the data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. Purposes of processing the User’s personal data:
* Informing the User by sending emails;
* Conclusion, execution, and termination of civil law contracts;
* Providing the User with access to services, information, and/or materials contained on the website https://webnbpro.com/.
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending the Operator an email to the email address with the note «Refusal of notifications about new products and services and special offers.»
7.3. Anonymized User data collected using 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 Grounds for Personal Data Processing
8.1. The legal grounds for the processing of personal data by the Operator are:
* The Operator’s statutory (constituent) documents;
* Contracts concluded between the operator and the subject of personal data;
* Federal laws, other regulatory legal acts in the field of personal data protection;
* Users’ consents to the processing of their personal data, to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the site https://webnbpro.com/ or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User’s browser settings (saving «cookies» and using JavaScript technology are enabled).
8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, by their own will, and in their interest.
9. Conditions for Personal Data Processing
9.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, for the performance of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body, or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party or a beneficiary or guarantor, as well as for concluding a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the data subject are not violated.
9.6. Processing of personal data is carried out, access to which is provided to an unlimited number of persons by the data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. 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.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. 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 data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address with the note «Updating personal data.»
10.4. The period for processing personal data 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 their consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s email address with the note «Withdrawal of consent to the processing of personal data.»
10.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by said persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or User is obliged to independently familiarize themselves with the said documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator, when processing personal data, ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows identification of the data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor.
10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the data subject’s consent or withdrawal of consent by the data subject, as well as the identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunication networks.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements can only be carried out if the data subject has given written consent to the cross-border transfer of their personal data and/or performance of a contract to which the data subject is a party.
13. 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 data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@webnbpro.com.
14.2. This document will reflect any changes to the Operator’s personal data processing policy. 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://webnbpro.com/privacy-policy/.New chat