Privacy policy

PERSONAL DATA PROTECTION AND PROCESSING POLICY
(PRIVACY POLICY)

  1. GENERAL PROVISIONS

1.1. This Privacy Policy has been adopted by Processor so as to inform visitors of the website https://apkbg.info/ directly, as well as the persons involved in processing such data, of the Processor’s compliance with the legislation on protection of Personal Data.

  1. In this Privacy Policy (hereinafter referred to as the “Policy”) we use the following terms and definitions:

        “Processor” refers to Rudenko Alexey Viktorovich, whose address is Apartment 18, 7 Bazhova St., Moscow, 129128;

“Personal Data” refers to any information relating directly or indirectly to a certain individual (Data Subject);

 “Processing of Personal Data” refers to any action (operation) or a set of actions (operations) which is performed on Personal Data, whether automated or not, including collection, recording, organization, accumulation, storage, rectification (updating, modifying), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, erasure, destruction.

“Automated processing of Personal Data” refers to processing of Personal Data by means of computer technology;

“Provision of Personal Data” refers to actions aimed at disclosure of Personal Data to a certain person or a certain scope of persons;

 “Blocking of Personal Data” refers to temporary termination of Personal Data processing (except for cases when processing is necessary for rectification of Personal Data);

“Destruction of Personal Data” refers to actions rendering Personal Data inaccessible, irretrievable in the Personal Data system and (or) as a result of which physical data storage of Personal Data is destroyed;

“Depersonalization of Personal Data” refers to actions resulting in impossibility to identify a particular individual to whom Personal Data relates without the use of additional information;

“Personal Data system” refers to a set of Personal Data contained in Personal Data databases as well as information technologies and technical means ensuring its processing.

  1. The Privacy Policy is applicable to any Personal Data that the Processor may obtain in the course of use of the website https://apkbg.info/ (hereinafter referred to as the “Website”) by Data Subjects.
  2. The Processor shall process Personal Data in accordance with applicable laws and regulations of the Russian Federation concerning Personal Data processing, including, but not limited to: Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as Federal Law “On Personal Data”); Federal Law “On Information, Information Technologies and Information Protection” of 27.07.2006 N 149-FZ, etc.

1.4. The Privacy Policy protects the rights and freedoms of Data Subjects when processing their Personal Data whether automated or not.

1.5. By using the Website services and providing their Personal Data to the Processor, also made including an intermediary of the third party, Website Users acknowledge that the Processor processes their Personal Data in accordance with this Policy. Thus, using Website services, including, but not limited to registration and using feedback forms means that a Data Subject consents to the processing of their Personal Data, including cookies. In case of any disagreement with this Policy in general, as well as in case of disagreement with any paragraph of this Policy, Website visitors shall refrain from using Website services.

1.5.1. The Processor receives and begins to process Personal Data of Data Subject upon receipt of their consent. In the absence of such consent the processing shall not be carried out, unless other provided by applicable law.

1.6. Data Subject has the right to withdraw their consent to Personal Data processing at any time. If Data Subject does so, Processor is entitled to continue processing of Personal Data without Data Subject’s consent should it be prescribed by applicable law.

1.7. The Processor is entitled to modify this Privacy Policy. The Processor has the right to make changes to the present Privacy Policy at any time at its own discretion without prior notification of the User. In case of any changes to the current edition, the date of the last update shall be indicated. A new version of the Policy shall take effect upon the date of its publication on the Website, unless otherwise provided by the new version of the Policy. The up-to-date version of the Privacy Policy can be found at the following link: https://apkbg.info/privacy-policy/.

1.8. The Policy applies only to information about the User received while using the Website. The Processor does not control and is not responsible for the processing of information about the User by websites of the third party, which the User can access through the links available on the Website

  1. SCOPE OF PERSONAL DATA

2.1.  The Processor is entitled to process Personal Data of Website Users (previously and hereinafter referred to as the “User”) in order to provide services through the Website.

2.3. The User consents to processing of the following Personal Data:

Full name;

Country of residence;

City of residence;

Organization which the User works for or represents;

Job title;

Contact telephone number;

E-mail.

  1. BASIS, PRINCIPLES AND PURPOSES OF PERSONAL DATA PROCESSING

3.1. The Processor shall process Personal Data guided by the following principles:

Purposes and methods of Personal Data processing shall be lawful;

Personal Data shall be processed in accordance with the principle of good faith;

The scope of processed Personal Data, as well as the methods of processing shall not be incompatible with the stated processing purposes;

Personal Data shall be accurate and adequate and, where necessary, kept up- to-date in relation to stated purposes of data processing;

When the purposes of data processing are achieved, Persona Data shall be destroyed in the way that renders it irretrievable;

Combining of Personal Data databases which are processed for incompatible purposes is inadmissible.

3.2. The Processor may process Personal Data provided that at least one of the following requirements is met:

Personal Data are processed with consent of a Data Subject;

Personal Data processing is necessary to achieve the purposes prescribed by law, to implement and perform the functions, powers and duties imposed on the Processor by the legislation of the Russian Federation;

The Processor processes Personal Data, public access to which is provided by a Data Subject or at their request;

The Processor shall process Personal Data subject to publication or mandatory disclosure in accordance with applicable law.

3.3. Organizations and other persons given access to Personal Data shall not disclose Personal Data to a third party and shall not distribute such Data without a Data Subject’s consent, unless otherwise provided by applicable law.

3.4.  Personal Data is processed for the following purposes:

To identify a Data Subject and to provide an individual approach to such Data Subjects using Website services;

To enable registration/creation of individual user account and provision of services on the Website;

To contact a Data Subject, if necessary, including sending offers, notifications, information and requests, whether related to use of the Website or not, as well as processing applications, claims and requests;

To improve the quality of the services provided by the Processor;

To provide services placed on the Website and provided by the Processor;

To provide information necessary for providing the services of the Website;

To organize technical cooperation.

3.4.1. Data for the above mentioned purposes may be collected in the following cases:

Service name

Data type

Purpose of processing

Registration on the Website

Surname, Name, Patronymic;

e-mail

Identification of a Data Subject;

Creation of the individual user account;

Contacting a Data Subject so as to provide information necessary for service provision.

Thus, we use your Personal Data in order to

register you on the Website;

create your profile;

provide support, information on your account and respond to your inquiries;

provide individual approach when using the services.

Registration for information and telecommunications events as part of The Safe City Hardware and Software System

Surname, Name, Patronymic;

 

Country of residence;

 

City of residence;

 

Organization which the User works for or represents;

 

Job title;

 

Contact telephone number;

E-mail

Identification of Data Subject;

Contacting a Data Subject so as to provide information which is necessary for provision of services of information and telecommunications events as part The Safe City Hardware and Software System.

Thus, we use your Personal Data in order to

register you for a relevant information and telecommunications event;

create your profile;

provide support, information on the event and respond to your inquiries;

provide an individual approach when using the services.

Registration of organizations for the purpose of technical cooperation

Full name of organization representative;

 

Organization name

Identification of a Data Subject;

Contacting a Data Subject so as to provide information necessary for technical cooperation.

Thus, we use your Personal Data in order to

create your profile;

provide support, information on new projects of The Safe City Hardware and Software System and respond to your inquiries;

provide individual approach when arranging cooperation*.

 

*registration as a technical partner shall not be considered as a public offer to cooperate and shall not give a potential participant any advantages

 

 

3.5. The Processor does not process special categories of Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual life and biometrics data.

 

  1. TIME LIMITS FOR PERSONAL DATA PROCESSING

4.1. Time limits for Personal Data processing are determined based on the purposes for which such data was collected.

4.1.1. Processed Personal Data is subject to destruction or depersonalization upon occurrence of the following conditions:

If the purposes of Data Processing have been fulfilled or maximum retention period has expired, Personal Data shall be destroyed or depersonalized within thirty (30) days from the date when the purpose was fulfilled;

In case of no further need for achieving the purposes of Personal Data processing, Personal Data shall be destroyed or depersonalized within thirty (30) days from the date when fulfillment of such purposes has become unnecessary;

If a Data Subject or their legal representative submit confirmation of the fact that the Data are obtained illegally or are not necessary for the stated purpose of processing, Personal Data shall be destroyed or depersonalized within seven (7) days from the date of such submission;

If Data Subject withdraws their consent to Personal Data processing, Personal Data shall be destroyed or depersonalized within thirty (30) days from the date of such withdrawal.

  1. PERSONS ALLOWED TO PROCESS PERSONAL DATA

5.1. The Processor is entitled to transfer Personal Data to the third party in the following cases:

Personal Data may be transferred to LLC “NCI” (OGRN 1147746450994) so as to provide services for information and telecommunications events as part of The Safe City Hardware and Software System.

The transfer complies with the current legislation.

In this case the transferee undertakes all obligations to comply with the terms of this Policy in relation to the Data received from the Processor.

5.3. Upon a motivated request of an authorized body and in accordance with the current legislation Personal Data of a Data Subject may be transferred without the latter’s consent to the following public authorities and bodies:

Judicial authorities in connection with the administration of justice;

Police, Federal Security Service, Prosecutor General’s Office, Investigative Committee;

Other bodies and organizations authorized by the current legislation in cases stipulated by legal acts and regulations which are mandatory for the Processor.

  1. PERSONAL DATA PROCESSING METHODS AND PROCEDURE

6.1. When providing services of the Website the Processor applies automated, non-automated and mixed of personal data processing procedures.

6.2. The Processor has the right to assign Personal Data processing to a third party with consent of a Data Subject, unless otherwise provided by the legislation of the Russian Federation. In this case Personal Data processing may be assigned to a third party under a contract with this party, provided this party shall observe the principles and rules of Personal Data Processing, provided by the Federal Law “On Personal Data”.

6.3. Personal Data shall not be disclosed to a third party or otherwise disseminated without the Data Subject’s consent, unless otherwise provided by laws and regulations of the Russian Federation or a contract.

6.4. The Processor is entitled to

process Personal Data of a Data Subject in accordance with the stated purpose;

require from a Data Subject to provide accurate Personal Data necessary for the provision of services, identification of a Data Subject, as well as in other cases according to laws and regulations of the Russian Federation concerning personal data;

restrict access of a Data Subject to their Personal Data should Personal Data processing be carried out in accordance with anti-money laundering and counter-terrorism financing legislation or should Data Subject’s access to such data violate the rights and legitimate interests of third party, as well as in other cases according to laws and regulations of the Russian Federation;

process publicly available Personal Data of individuals;

process Personal Data subject to publication or mandatory disclosure in accordance with the laws and regulations of the Russian Federation;

assign Personal Data processing to a third party with consent of a Data Subject.

6.5. Should inaccuracy of Personal Data be confirmed, the Processor shall update such Data. Should illegality of Personal Data be confirmed, the Processor shall stop its processing.

6.6. A Data Subject is entitled to

obtain information from the Processor concerning the processing of their Personal Data, unless such right is restricted in accordance with applicable law;

demand the Processor should clarify, block or destroy their Personal Data if it is incomplete, outdated, inaccurate, illegally obtained or unnecessary for the stated purpose of processing, as well demand the Processor should take statutory measures to protect their rights;

appeal against actions or omissions of the Processor to the authorized body for protection of the Data Subjects’ rights or in court if the Data Subject believes that the Processor processes their Personal Data in violation of the applicable laws of the Russian Federation;

 protect their rights and legitimate interests, including suing for compensation for damages and (or) compensation for moral harm caused by unlawful actions of the Processor.

  1. IMPLEMENTATION OF PERSONAL DATA PROTECTION

7.1. The Processor’s activity in processing Personal Data in Personal Data Systems is inseparably connected with received data privacy protection conducted by the Processor. The Processor shall ensure privacy of Personal Data, as well as other information obtained by the Processor unless it is contrary to the current legislation of the Russian Federation.

7.2. The Processor shall ensure security of processed Personal Data as part of an integrated system of organizational, technical and legal measures to protect information constituting a trade secret, taking into account the requirements of personal data legislation and regulations adopted in accordance with it.

7.3. Exchange of Personal Data during its processing in Personal Data Systems shall be carried out via communication channels protected by technical means of information protection

7.4. When processing Personal Data in Personal Data Systems the Processor shall provide:

Activities aimed at prevention of unauthorized access to the Personal Data and (or) their transfer to unauthorized persons;

Timely detection of unauthorized access to Personal Data;

Prevention of impact of automated processing of Personal Data on technical means resulting in disruption of their functioning;

The possibility of immediate recovery of Personal Data, modified and destroyed as a result of unauthorized access to it;

Instant control of the level of Personal Data protection;

Limiting the scope of the persons having access to Personal Data;

Information to Data Subjects concerning requirements of federal legislation and the Processor’s regulatory documents on processing and protection of the Personal Data.

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