1. General provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by LLC ZVK "BERVEL" (hereinafter — the Operator).1.1. The Operator’s most important goal and condition of its activities is observance of the rights and freedoms of individuals and citizens when processing their personal data, including protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://bervel.ru.
2. Key terms 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 the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, that make them available on the Internet at the network address https://bervel.ru.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without additional information, whether personal data belong to a specific User or another personal data subject.
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 (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of processing personal data, 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://bervel.ru.
2.9. Personal data permitted by the personal data subject for dissemination — personal data access to which by an unrestricted circle of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://bervel.ru.
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 at making personal data known to an unrestricted circle of persons, including publication of personal data in the mass media, posting 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 an 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 destroyed irreversibly with no possibility of further restoration of the content of personal data in the personal data information system and/or the tangible media of personal data are destroyed.
3. Main 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;
— if the personal data subject withdraws consent to the processing of personal data, as well as if a request is sent to terminate the processing of personal data, the Operator is entitled to continue processing personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations provided for by the Personal Data Law and the 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 relating to the processing of their personal data;
— to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— to respond to requests and inquiries of personal 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 personal data subjects, upon that body’s request, the necessary information within 10 days from the date of receipt of such request;
— to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— to 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;
— to cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— to perform other obligations provided for by the Personal Data Law.
4. Main rights and obligations of personal data subjects
4.1. Personal data subjects have the right:— to receive information relating to 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 must not contain personal data relating to other personal data subjects, except 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 require the operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— to set a condition of prior consent when personal data are processed for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in processing their personal data;
— to 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;
— to inform the Operator of clarification (updating, modification) of their personal data.
4.3. Persons who have transferred to the Operator unreliable information about themselves, or information about another personal data subject without the latter’s consent, bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data are processed 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 that is incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data that are processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Excessiveness of the personal data processed relative 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, their relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, by a contract to which the personal data subject is a party, beneficiary, or surety. Processed personal data are destroyed or depersonalized upon achievement of the processing purposes or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of personal data processing
| Purpose of processing | informing the User by sending emails |
|---|---|
| Personal data |
|
| Legal grounds |
|
| Types of personal data processing |
|
7. Conditions for processing personal data
7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the performance of the functions, powers, and obligations imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, or under which the personal data subject is a beneficiary or surety, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or surety.
7.5. 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 purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out of personal data access to which by an unrestricted circle of persons has been granted by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out of personal data that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for collection, storage, transfer, and other types of processing of personal data
The security of personal data processed by the Operator is ensured by implementing the legal, organizational, and technical measures necessary to fully meet the requirements of current legislation in the field of personal data protection.8.1. The Operator ensures the safekeeping of personal data and takes all possible measures excluding 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 compliance with current legislation or if the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator’s email address zvk@bervel.ru with the subject “Updating personal data”.
8.4. The period of processing personal data is determined by achievement of the purposes for which the personal data were collected, unless another period 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 the Operator a notice via email to the Operator’s email address zvk@bervel.ru with the subject “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 the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the said 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 transfer (except for granting access), as well as on 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 determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, by a contract to which the personal data subject is a party, beneficiary, or surety.
8.9. Conditions for terminating the processing of personal data may include achievement of the purposes of processing personal data, expiry of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to terminate the processing of personal data, as well as identification of unlawful processing of personal data.
9. List of actions performed by the Operator with the personal data obtained
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the information obtained over information and telecommunications networks or without such.
10. Cross-border transfer of personal data
10.1. Before commencing activities involving 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 cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, and 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 obtained 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 may obtain any clarifications on matters of interest relating to the processing of their personal data by contacting the Operator by email at zvk@bervel.ru.12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://bervel.ru/privacy/.
