Policy on Personal Data Processing
1. General Provisions
This Policy on Personal Data Processing has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by LLC “RSK Stroy” (OGRN 1177746199377, INN 7722391638), registered at the address: 109028, Moscow, within the territory of the municipal district of Tagansky, Zemlyanoy Val Street, building 50A, structure 3.
1.1. This Policy of the Operator 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://rsk.ltd (hereinafter referred to as the Website), which has been voluntarily provided by the Website visitors.
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 suspension of the 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 under the network address https://rsk.ltd.
2.4. Personal data information system — a collection 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 is impossible to determine, without the use of additional information, the affiliation of personal data to a specific User or other data subject.
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 (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — LLC “RSK Stroy” (OGRN 1177746199377, INN 7722391638), 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, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable Website User.
2.9. Personal data permitted by the data subject for dissemination — personal data to which an unrestricted circle of persons has been granted access by the User by giving consent to the processing of personal data permitted by the data subject for dissemination in the manner provided for by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User — any natural person who is a Website visitor and a data subject.
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 familiarizing an unrestricted circle of persons with personal data, including publication of personal data in the mass media, placement in information and telecommunications networks, or provision of access to personal data by any other means.
2.13. Destruction of personal data — any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoration of 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 from the User reliable information and/or documents containing personal data;
— in the event of the User’s withdrawal of consent to the processing of personal data, as well as the submission of a request to terminate the processing of personal data, the Operator may continue processing personal data without the User’s consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and normative 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 User, upon request, with information regarding the processing of his personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries from Users and their legal representatives in accordance with the requirements of the Personal Data Law;
— inform the authorized body for the protection of the rights of data subjects of the necessary information within 10 days from the date of receipt of such a request from this body;
— publish or otherwise ensure unrestricted access to this Policy on Personal Data Processing;
— 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 with respect to personal data;
— cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.
4. Main Rights and Obligations of Users
4.1. Users 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 User by the Operator in an accessible form, and it must 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;
— demand from the Operator clarification of his personal data, blocking or destruction thereof if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
— set the 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 direct a request to terminate the processing of personal data;
— appeal to the authorized body for the protection of the rights of data subjects or to the court the unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Users are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator of any clarification (update, modification) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves or information about another data subject without the latter’s consent shall bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data whose processing is carried out for purposes incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the data subject, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, contract, a party to which, beneficiary, or guarantor under which is the User. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of necessity in achieving these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
- provision of services/works to the User;
- sending notifications to the User regarding the provided services/works;
- preparation and sending of responses to User requests;
- sending to the User’s address information, including advertising, about the Operator’s events/goods/services/works.
Personal data:
- surname, first name, patronymic;
- email address;
- phone numbers;
- other data provided by the User.
Legal bases:
- Personal Data Law;
- Federal Law “On Information, Information Technologies and Information Protection” dated July 27, 2006, No. 149-FZ.
Types of personal data processing:
- sending informational emails to the email address specified by the User;
- calls to the phone number specified by the User.
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the User’s consent to the processing of his personal data, in accordance with the provisions of the Personal Data Law. The User who has accepted this Policy assures and guarantees to the Operator, within the meaning of Article 431.2 of the Civil Code of the Russian Federation, that he has familiarized himself with all provisions of this Policy, understands the meaning and significance of the terminology, as well as the conditions for processing his personal data by the Operator.
7.2. Processing of personal data is necessary to achieve the purposes provided for by this Policy.
7.3. Processing of personal data is necessary for the execution of a contract, a party to which, beneficiary, or guarantor under which is the User, as well as for concluding a contract on the User’s initiative or a contract under which the User will be a beneficiary or guarantor.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the 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 exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will never be transferred to third parties under any circumstances, except in cases related to the execution of current legislation or if the User has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the email address info@rskst.ru with the note “Update of Personal Data”.
8.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract concluded between the Operator and the User or by current legislation.
The User may withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via email at the Operator’s email address info@rsk.ltd with the note “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement, Privacy Policy, and other documents. The User undertakes to familiarize himself with these documents independently. The Operator does not bear and under no circumstances can bear responsibility for the actions/inactions of third parties, including those specified in this clause.
8.6. Prohibitions established by the User on the transfer (except for provision of 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 carries out storage of personal data in a form that allows identification of the data subject, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, contract, a party to which, beneficiary, or guarantor under which is the User.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the User’s consent, withdrawal of consent by the User or a request to terminate personal data processing, as well as detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Obtained Personal Data
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 obtained information over information and telecommunications networks or without such.
10. Confidentiality of Personal Data
The Operator that has gained access to personal data is obliged not to disclose to third parties and not to disseminate personal data without the appropriate consent of the User, unless otherwise provided by regulatory legal acts.
11. Final Provisions
11.1. The User may obtain any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email at: info@rsk.ltd. The period for consideration by the Operator of the User’s request shall not exceed 30 (thirty) days from the date of its receipt by the Operator.
11.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version. The adoption by the Operator of a new version of this Policy is carried out by publishing it on the Website; the date of entry into force of the new version of the Policy is the date of its placement on the Website.
11.3. The current version of the Policy is freely available on the Internet at: https://rsk.ltd/privacy-policy. (link to the policy page)
11.4. The User undertakes to independently monitor updates to this Policy on the Operator’s Website.