1. GENERAL PROVISIONS
1.1. Who created and approved the Policy
Individual Entrepreneur Korobkova Tatyana Valerievna, TIN 930301715743
1.2. We comply with the requirements of the Law
Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", Federal Law of 30.12.2020 No. 519-FZ "On Amendments to the Federal Law "On Personal Data".
1.3. The Personal Data Processing Policy (hereinafter - the Policy) defines
1.3.1. the procedure for processing personal data and measures to ensure the security of personal data taken by the Operator;
1.3.2. the rules for processing personal data by the Operator, provided by persons who use the Operator's Site or other resources of the Operator;
1.3.3. the purposes, legal grounds, procedure and scope of processed personal data;
1.3.4. the procedure for interaction with personal data subjects when receiving appeals from them.
1.4. Whose data does the Operator process
physical persons who leave applications, requests on the Site, other resources of the Operator, are in civil law relations with the Operator
1.5. Categories of personal data processed by the Operator
1.5.1. Name;
1.5.2. Phone number;
1.5.3. Email address;
1.5.4. Link to social networks;
1.5.5. Telegram username (nickname).
1.6. Processing of data using Internet statistics services
The Operator collects and processes depersonalized data about visitors (including cookie files) using Internet statistics services (Yandex Metrica and others).
1.7. Resources where we process personal data
Website and Telegram mini-applications: https://unitee.space/, including subdomains and their pages.
1.8. If there are questions not regulated by the Policy
questions not regulated by this Personal Data Processing Policy are resolved in accordance with the current legislation of the Russian Federation in the field of personal data.
2. TERMS AND DEFINITIONS
2.1. Operator
an individual entrepreneur (clause 1.1 of the Policy) who processes personal data; determines the purposes of personal data processing, the composition of personal data subject to processing; actions (operations) performed with personal data.
2.2. User/Personal Data Subject
any visitor of the Operator's resources, clause 1.7 of the Policy.
2.3. Site
a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet, the network address of the Site is indicated in clause 1.7 of the Policy
2.4. Personal Data
information relating to a directly or indirectly identified or identifiable natural person (personal data subject).
2.5. Processing of Personal Data
any action or set of actions performed using or without using automation tools with personal data, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.6. Automated processing of personal data
processing of personal data using computer means.
2.7. Blocking of personal data
temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.8. Depersonalization of personal data
actions as a result of which it becomes impossible without the use of additional information to determine the attribution of personal data to a specific personal data subject.
2.9. Provision of personal data
actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.10. Distribution of personal data
actions aimed at disclosing personal data to an indefinite circle of persons.
2.11. Destruction of personal data
any actions as a result of which personal data is irrevocably destroyed with the impossibility of further restoration of the content of personal data.
3. PURPOSES OF PERSONAL DATA PROCESSING
3.1. Compliance with the law
ensuring the protection of the rights and freedoms of man and citizen during the processing of his personal data, including the protection of the right to privacy, personal and family secrets.
3.2. Operator's goals
3.2.1. clarifying order details;
3.2.2. conclusion, execution, termination of civil law contracts;
3.2.3. providing access to services, information, materials of the Operator;
3.2.4. providing and collecting feedback;
3.2.5. notifying about new products and services of the Operator;
3.2.6. improving the quality of services and the Site that the Operator uses to provide services
4. PRINCIPLES OF PERSONAL DATA PROCESSING
4.1. Principles of personal data processing
in accordance with the Law Federal Law No. 152-FZ of 27.07.2006 «On Personal Data» and the Policy
4.1.1. legality of the purposes and methods of personal data processing, good faith and fairness in the Operator's activities;
4.1.2. reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of processing personal data that are excessive in relation to the purposes stated when collecting personal data.
4.1.3. processing only those personal data that correspond to the purposes of their processing;
4.1.4. ensuring the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of personal data processing. The Operator takes the necessary measures or ensures that they are taken to delete or clarify incomplete or inaccurate data;
4.1.5. storage of personal data in a form that allows the personal data subject to be identified, no longer than required by the purposes of personal data processing.
5. RECEIPT, PROCESSING, STORAGE OF PERSONAL DATA
5.1. Procedure for obtaining personal data by the Operator
when registering and ordering services on the Operator's resources, the personal data subject provides the data necessary to identify the personal data subject and to provide him with services. The list of personal data is indicated in paragraph 1.5 of the Policy.
5.2. Data that the Operator does not receive or process
about race, political views, religious and philosophical beliefs, health status, intimate life, unless otherwise provided by law.
5.3. Consent to the processing of personal data
The Operator is entitled to process the personal data of individuals only with their consent to the use of personal data. The personal data subject expresses consent to the processing of personal data by marking (consent) on the Operator's resources.
5.4. When consent to the processing of personal data is not required
5.4.1. personal data are publicly available;
5.4.2. processing of personal data is carried out on the basis of a federal law that establishes its purpose, conditions for obtaining personal data and the circle of subjects whose personal data are subject to processing, as well as the specified powers of the Operator;
5.4.3. at the request of authorized state bodies - in cases provided for by federal law;
5.4.4. processing of personal data is carried out for the purpose of fulfilling a contract concluded with the Operator;
5.4.5. processing of personal data is carried out for statistical or other scientific purposes, subject to mandatory anonymization of personal data;
5.4.6. processing of personal data is necessary to protect the life, health or other vital interests of the Customer, if obtaining his consent is not possible.
5.5. Storage of personal data
5.5.1. storage, compilation, accounting and use of documents containing personal data is organized in the form of a separate archive of the Operator.
5.5.2. storage of personal data must be carried out in a form that allows the personal data subject to be identified, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract to which the personal data subject is a party.
5.6. Termination of personal data processing
5.6.1. personal data are subject to destruction or anonymization upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law;
5.6.2. the condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent period or the withdrawal of consent by the personal data subject to the processing of his personal data, as well as the detection of unlawful processing of personal data.
5.7. Updating personal data
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 with the subject line «Personal data update».
5.8. Term of personal data processing and withdrawal of consent to the processing of personal data
Processing of the User's personal data is carried out for 3 (three) years from the date of consent to the processing of personal data or until the expiration of the specified period in case of withdrawal of consent by the personal data subject to the processing of his personal data, by sending a notification to the Operator by e-mail to the Operator's e-mail address with the subject line «Withdrawal of consent to the processing of personal data».
5.9. Methods of personal data processing
5.9.1. Processing of personal data may be carried out by mixed processing with transmission over the Operator's internal network with transmission over the Internet and by automated processing without transmission over the Operator's internal network with transmission over the Internet.
5.9.2. The Operator does not carry out cross-border transfer of personal data.
5.9.3. Encryption (cryptographic) tools: not used.
6. MEASURES TO ENSURE THE SECURITY OF PERSONAL DATA
6.1. Security measures
in accordance with the Law Federal Law No. 152-FZ of 27.07.2006 «On Personal Data» and the Policy
6.1.1. internal control of personal data processing compliance with Federal Law No. 152;
6.1.2. a document defining the Policy on the processing of personal data is published and posted on the Operator's resources, containing information about the implemented requirements for the protection of personal data;
6.1.3. organizational and technical measures are applied to ensure the security of personal data during their processing in information systems, necessary to fulfill the requirements for the protection of personal data, including:
- appointment of officials responsible for the organization of processing and protection of personal data;
- limitation of the composition of persons admitted to the processing of personal data;
- familiarization of subjects with the requirements of federal legislation and Operator's regulatory documents on the processing and protection of personal data;
- organization of accounting, storage and handling of media containing information with personal data;
- determination of threats to the security of personal data during their processing, formation of threat models based on them;
- development of a personal data protection system based on a threat model;
- checking the readiness and effectiveness of the use of information protection tools;
- limitation of user access to information resources and software and hardware processing facilities;
- registration and accounting of user actions in personal data information systems;
- use of antivirus tools and personal data protection system recovery tools;
- use of firewalls, intrusion detection systems, security analysis tools, and information cryptographic protection tools, where necessary.
6.1.4. rules for access to personal data processed in the information system are established, as well as ensuring the registration and accounting of all actions performed with personal data in the Operator's information system;
6.1.5. control is carried out over the measures taken to ensure the security of personal data and the level of protection of the Operator's information systems;
6.1.6. the possibility of uncontrolled entry or presence of unauthorized persons in the premises where personal data is processed is excluded;
6.1.7. the safety of personal data carriers and information protection tools is ensured. In case of processing personal data on material carriers, separate storage of personal data (material carriers) whose processing is carried out for different purposes is ensured;
6.1.8. use of antivirus software; use of electronic digital signature (EDS); passwords on computers where personal data is processed; backup.
7. TRANSFER OF PERSONAL DATA
7.1. Prohibition of personal data transfer
it is forbidden to transfer personal data to a third party without the written consent of the personal data subject, except in cases where this is necessary to prevent a threat to the life, health of the Customer, as well as in other cases provided for by law.
7.2. Warning about the purpose of personal data processing
The Operator warns persons receiving personal data that this data may be used only for the purposes for which it was provided, and requires these persons to confirm that this rule has been observed.
7.3. Who is allowed access to personal data
specially authorized persons, while such persons must have the right to receive only the personal data necessary to perform specific functions.
7.4. Transfer of personal data to representatives
in the manner prescribed by the Federal Law of 27.07.2006 No. 152-FZ «On Personal Data».
8. LEGAL BASIS FOR PERSONAL DATA PROCESSING
8.1. Legal basis
a set of legal acts, in execution of which and in accordance with which the Operator processes personal data on the basis of: applicable legislation, contracts between the operator and the personal data subject, consent to the processing of personal data (in cases not directly provided for by the legislation of the Russian Federation, but corresponding to the Operator's powers).
8.2. When the Operator can process personal data
only if they are filled in and/or sent by the User/Personal Data Subject independently through special forms located on the Operator's resources. By filling in the relevant forms and/or sending their personal data to the Operator, the personal data subject expresses their consent to this Policy.
8.3. Processing of depersonalized data
The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (saving «cookie» files and using JavaScript technology are enabled).
9. FINAL PROVISIONS
9.1. Where the personal data subject can turn
the personal data subject can get any clarifications on issues of interest regarding the processing of their personal data from the Operator using email [email protected].
9.2. Changes to the Policy
The Operator reserves the right to make changes to this Policy at its own discretion, including in cases where this is caused by changes in legislation or the terms of use of the services used by the Operator. Notifications of changes to the Personal Data Processing Policy may be displayed on the Operator's resources (for example, in the Personal Account, through a pop-up window or banner) before such changes come into force, or may be sent by email.
9.3. Familiarization with the Policy
The personal data subject is obliged to familiarize themselves with the text of the Personal Data Processing Policy each time they use the Operator's resources.
9.4. Entry into force of the Policy
The new version of the Personal Data Processing Policy comes into force from the moment of its placement in the relevant section of the Site or other resource of the Operator. In case of disagreement with the terms of the Policy, the personal data subject must immediately stop using the Operator's resources.
