Personal Data Processing and Protection Policy of Individual Entrepreneur V. A. Levi
This Personal Data Processing and Protection Policy (the "Policy") applies to all information that Individual Entrepreneur Valeria Anatolyevna Levi (PSRNSP 319784700369074, ITN 490903263739) (the "Personal Data Operator" or "Operator") can receive about the user (the "User") and/or about a third party, on behalf of and in whose interests the User acts while using the website
https://leviburo.ru/ (the "Website"), its services, programs and products.
This Policy was created on the basis of and in accordance with Art. 24 of the Constitution of the Russian Federation, Federal Law 152-FZ, dated 27.07.2006, "On Personal Data" (the "Law on Personal Data"), other regulations of the Russian Federation.
The Policy applies to all personal data of subjects that can be obtained by the Operator in the course of its activities.
For users from the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of protection for personal data. Therefore, the Operator has taken appropriate measures to ensure that such transfers are carried out in accordance with the applicable EU data protection regulations.
The Policy applies to relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy. .
Pursuant to the requirements of Part 2 of Art. 18.1 of the Law on Personal Data, this Policy is published in the public domain on the information and telecommunications network Internet on the Operator's website.
The terms and definitions used in this Policy are interpreted in accordance with their definition in the Law on Personal Data.
The purpose of the Policy is to inform the persons (subjects) who provide their personal data with the necessary information, which makes it possible to assess what personal data and for what purposes are processed by the Operator, what methods of ensuring their security are implemented.
The policy ensures the protection of the rights and freedoms of subjects when their personal data is processing using automation tools or without using such means, and also establishes the responsibility of persons who have access to personal data for failure to comply with the requirements governing the processing and protection of personal data.
Users of the Website, using the services of the Operator, agreeing with the disclaimers installed on the Website by pressing the "Agree" button and/or ticking on the consent to the Policy, informing the Operator their personal data including through the mediation of third parties acknowledge their consent to the processing of personal data in accordance with this Policy and the terms of processing of the User's personal data.
The consent to the processing of personal data can be revoked by the User by sending a message to the email address indicated on the Website. In the event of withdrawal of the consent to the processing of personal data by the User, the Operator has the right to continue processing personal data without the consent of the User if there the grounds specified by the current legislation.
Please read this Policy before using the website https://leviburo.ru/ 1. GENERAL 1.1. Within the framework of this Policy, the personal information of the User means:
· Personal information that the User provides about himself independently in the process of using feedback forms and other Services of the Website, including personal data of the User (last name, first name, place of work, position, contact phone number, e-mail address, etc.) as well as personal data arriving at the address of the Operator's corporate mail by the persons who have agreed to the processing of personal data by starting to use the Site, sending information through the selected forms on the pages of the Website or sending an e-mail to the Operator's corporate mail. The information required for the provision of the Services is marked in a special way. Other information is provided by the User at his discretion.
· Data that is automatically transmitted to the services of the Website during their use (viewing, reading texts, downloading information) with the software installed on the User's device, including the IP address, cookie data, information about the User's browser (or other program with which access to the services is carried out), the technical characteristics of the equipment and software used by the User, the date and time of the visit to the Website, the addresses of the requested pages, and other similar information.
· Other information about the User, the processing of which is necessary in order to use the Website.
1.2. This Privacy Policy applies only to the Website
https://leviburo.ru/. The Website
https://leviburo.ru/ does not control and is not responsible for third-party websites to which the User can click the links available on the Site
https://leviburo.ru/.
2. THE PRINCIPLES AND PURPOSES OF PROCESSING PERSONAL INFORMATION OF USERS
2.1. The processing of personal data by the Operator is based on the following principles:
· legality and fairness;
· limitation of the achievement of specific, predetermined and legal;
· prevention the processing of personal data incompatible with the purposes of collecting personal data;
· prevention of the unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
· the content and the scope of processed personal data must comply with the stated processing objectives;
· Personal data is stored in a form that allows you to identify the subject of personal data, no longer than the purpose of processing personal data requires, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor;
· other principles contained in Russia's current legislation on personal data.
2.2. The Website collects and stores only personal information necessary for the provision of services or the execution of agreements and contracts with the User, except for cases when the legislation provides for the mandatory storage of personal information for a period specified by law.
2.3. The Operator processes personal data to carry out activities, realize his legitimate interests and requirements.
2.4. The Purposes of processing personal data:
· User identification when completing and sending feedback forms on the Website.
· Providing the access to the resources of the Website to the User.
· Obtaining feedback from the User, including sending notifications, requests regarding the use of the Website, the provision of services, processing requests and applications from the User; determining the location of the User to ensure security and prevent fraud.
· Confirmation of the accuracy and completeness of personal data provided by the User.
· Providing effective customer and technical support to the User in case of problems related to the use of the Website; user notification by e-mail.
· Conducting statistical and other studies based on anonymized data.
· Transmission of reference and marketing information to the Website Users by sending messages to the email address specified by the Website User.
· Notification of the User on the updating of the Website's information materials, transmission of notifications, special offers, newsletters and other information and requests related to the provision of services with the User's consent.
2.5. The Website collects model information from the session log, including the IP address, type and language of the browser, as well as time and address of the websites from which links were followed. In order to ensure efficient management of the Website and to help set up the user interface, the Operator can use cookies (small text files stored in the browser) or web beacons (electronic images) in conjunction with tracking pixels, which allow the Website to count the number of visitors to a particular page and provide access to certain cookies.
2.6. The collected model information is used only for statistical purposes. The Operator does not use personal data for personal identification of any of the Users.
2.7. By using the Website and agreeing to the disclaimer installed on the Website by pressing the "Agree" button, the User agrees that the Operator can download cookies to the User's device in accordance with the conditions described above.
2.8. The User can manage cookies by accessing the browser settings. If cookies are deleted, all data about the User's preferences, including the preference not to use cookies, will be deleted. If cookies are blocked, changes might affect the user interface and some components of the Website might become unavailable.
3. GOOGLE ANALYTICS AND YANDEX METRICA 3.1. The Operator uses the tools "Google Analytics" and "Yandex.Metrica" to collect information about the use of the Website, such as the frequency of visits to the Website by the Users, the pages visited and the websites on which the Users were before moving to this Website. Google Analytics and Yandex.Metrica collects only the IP addresses assigned to the User on the day of visiting the Website, but not the name or other identification information.
3.2. Google Analytics and Yandex.Metrica posts a permanent cookie in the User's web browser to identify the User as unique when he visits the Website. This cookie cannot be used by anyone except Google, Inc and Yandex, respectively.
3.3. The Operator uses the information obtained through Google Analytics and Yandex.Metrica only to improve the services on the Website. The operator does not combine information obtained through Google Analytics and Yandex.Metrica with personal information.
3.4. The ability of Google and Yandex to use and share with third parties the information collected by Google Analytics and Yandex.Metrica about the User's visits to the Website is limited by the Google and Yandex Privacy Policy. The User can prevent Google Analytics and Yandex.Metrica from recognizing it on repeat visits to the Website by disabling the Google Analytics and Yandex.Metrica cookies in their browser or the User can use the Google Analytics Blocker
https://tools.google.com/dlpage/gaoptout/.
4. PROCEDURE AND TERMS OF PROCESSING OF PERSONAL INFORMATION OF USERS AND ITS TRANSMISSION TO THIRD PARTIES 4.1. The User's personal information is kept confidential, except in cases where the User voluntarily provides information about himself for public access to an unlimited number of persons. In this case, the User agrees that some of his personal information becomes publicly available. However, the User's silence or inaction regarding the information disclosed to an unlimited number of persons does not constitute the User's consent to the processing of his personal data by the Operator. The User's consent to the Operator for processing of personal data permitted by the User for distribution must be recorded separately from the other consent of the User for processing his personal data in accordance with the Law on Personal Data.
4.2. The operator is not entitled to transmit the User's personal information to third parties, except for the following persons:
· authorized state agencies within their powers;
· persons to whom the Operator is obliged to transfer it in order to comply with the legislation of the Russian Federation;
· persons to whom the Operator transmits personal data in order to perform the contract with the User;
· persons to whom the Operator entrusts the processing of personal data;
· legal successors of the Operator;
· other persons with the User's consent.
4.3. The processing of personal data of the User is carried out without time limit in any legal way, including in information systems of personal data, with or without the use of automation toola, but no longer than the purpose of processing personal data requires. The processing of personal data of Users is carried out in accordance with the Law on Personal Data.
4.4. The Operator applies appropriate technological and operational security standards to protect information provided by the Visitors of the Website from unauthorized access, disclosure, distortion, blocking or destruction.
Measures applied by the Operator include:
· appointment of a person responsible for organizing the processing of personal data;
· Application of legal, technical and organizational measures to ensure the security of personal data;
· assessment of harm that might be caused to the User in case of violation of legal requirements, the ratio of harm and security measures taken by the Operator;
· Establishment rules for access to personal data processed in the information system of personal data as well as ensuring the registration and recording of all actons perfomed with personal data in the information system of personal data;
· familiarization of the Operator's employees who directly process personal data with the provisions of the Russian Federation's legislation on personal data;
· control over the measures taken to ensure the security of personal data.
4.5. The operator guarantees organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions of third parties. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.
4.6. In collecting personal data, including through the information and telecommunication network Internet, the Operator provides recording, systematization, accumulation, storage, clarification (update, change), extraction of the User's personal data using databases located on the territory of the Russian Federation, except for cases specified in the Law on Personal Data.
5. OBLIGATIONS OF THE PARTIES 5.1. The User is obliged:
5.1.1. Provide reliable personal information needed to use the Website.
5.1.2. Update and supplement provided personal data information if this information changes.
5.2. The user has the right to:
5.2.1. receive information regarding the processing of his personal data, exept in cases provided for by federal laws. The information is provided to the User by the Operator in an accessible form, and it should not contain personal data relating to other Users, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data.
5.2.2. require the Operator to clarify, block or destroy personal data if personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing as well as take measures prescribed by law to protect their rights..
5.2.3. require prior consent when processing personal data for advertising in the market of goods, works and services.
5.3. The operator is obliged:
5.3.1. use the information received only within the stated purposes..
5.3.2. ensure the storage of confidential information in secret, do not disclose without the prior written permission of the User, and also do not sell, exchange, publish or disclose in other possible ways the transferred personal data of the User, with the exception of those provided for in this Policy.
5.3.3. take precautions to protect the confidentiality of the User's personal data in accordance with the procedure usually used to protect this kind of information in the existing business turnover.
5.3.4. block personal data related to the User concered from the moment of the request of the User, his legal representative, or an authorized agency for the protection of the rights of personal data subjects during the period of verification in case of revealing inaccurate personal data or illegal actions.
5.3.5. respond to the requests of the User and his legal representatives in accordance with the requirements of the Law on Personal Data.
5.3.6. report the necessary information to the authorized agency for the protection of the rights of personal data subjects (The Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)) at the request of that authority. The information must be provided within 30 days from the date of receipt of the request.
5.4. The operator has the right to:
5.4.1. independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Law on Personal Data and the regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
5.4.2. entrust the processing of personal data to another person with the consent of the User, unless otherwise provided by federal law, on the basis of a contract concluded with that person. A person who processes personal data on behalf of the Operator is obliged to comply with the principles and rules for processing personal data under the Law on Personal Data.
5.4.3. if the User withdraws consent to the personal data processing, the Operator has the right to continue processing personal data without the User's consent if there are grounds specified in the Law on Personal Data.
5.5. In case of loss or disclosure of personal data, the Operator will not be responsible if this confidential information:
· Becomes public before its loss or disclosure.
· Is received from a third party before the Operator receives it.
· Is disclosed with the User's consent.
5.6. The User is fully responsible for complying with the requirements of the Russian Federation's legislation, including the laws on advertising, on the protection of copyright and neighbouring rights, on the protection of trademarks and service marks, but not limited to those listed, including full responsibility for content and form of materials.
5.7. The User recognizes that responsibility for any information (data files, texts, etc.) that might be accessed as part of the Website is the responsibility of the Provider.
5.8. The User agrees that the information provided to him as part of the Website
https://leviburo.ru/ might be an intellectual property object, the rights to which are protected and belong to other Users, partners or advertisers who post such information on the Website.
5.9. The User does not have the right to make changes, lease, loan, sell, distribute or create derivative works based on the Website's content (in whole or in part), unless such actions has been expressly authorized in writing by the owners of the Website's content in accordance with the terms of a separate agreement.
5.10. Regarding text materials (articles, publications that are freely available to the public on the Site), their distribution is allowed as long as a link to the Website is given.
5.11. The Operator is not responsible to the User for any loss or damage suffered by the User as a result of the removal, interruption, or impossibility to save any content of the Website and other communication data contained on or transmitted through the Website.
5.12. The operator is not responsible for any direct or indirect damages arising out the use or inability to use the website or individual services, unauthorized access to the User's communication.; statements or conduct of any third party on the Website.
5.13. The Operator is not responsible for any information posted by the User on the Website, including but not limited to information protected by copyright without the express consent of the copyright owner.
6. IMPLEMENTATION OF PERSONAL DATA PROTECTION 6.1. The Operator's activity on the personal data processing in information systems is based on the principles of protecting the confidentiality of the information received.
6.2. The security of personal data during their processing in the Operator's information systems is ensured by an information protection system, consisting of organizational measures with the use of restricting physical access to premises and the use of software and hardware protection measures.
6.3. The exchange of personal data during their processing in information systems is carried out through communication channels protected by technical means of information protection.
6.4. During the personal data processing in the information systems of the Organization, the following actions are provided:
· adoption measures to prevent unauthorized access to personal data and its transmission to persons who do not have the right to access such information;
· timely detection of unauthorized access to personal data;
· prevention of impact on technical means of automated processing of personal data, as a result of which their functioning might be disrupted;
· possibility of immediate recovery of personal data modified and destroyed by unauthorized access;
· constant monitoring of the level of protection of personal data.
6.5. In order to ensure the compliance of the level of personal data protection with the requirements of the Law on Personal Data and Federal Law 149-FZ, dated 27.07.2006, "On Information, Information Technologies and Information Protection", the Operator does not disclose information on the specific means and methods used to ensure the information security of personal data.
7. PROCESSING TIME OF PERSONAL DATA 7.1. The time limits for processing personal data are based on the purposes of processing in the information systems of the Operator in accordance with the period of validity of the contract, the agreement with the User, the limitation period as well as other legal requirements and regulations of the Operator.
8. ADDITIONAL TERMS
8.1. The operator has the right to make changes to this Policy without the User's consent.
8.2. The new version of the Policy enters into force as soon as it is posted on the Website unless otherwise provided by the new Policy.
8.3. The current version of the Policy is posted on the page at
https://leviburo.ru/ .
9. Updating, correction, deletion and destruction of personal data, responses to subjects' requests for access to personal data
9.1. Confirmation of the fact of personal data processing by the Operator, legal grounds and purposes of personal data processing as well as other information specified in Part 7 of Art. 14 of the Law on Personal Data are provided by the Operator to the User or his representatives upon contact or receipt of a request from the User or his representatives.
9.1.1. The information provided does not include personal data relating to other subjects of personal data unless there are legal grounds for disclosing such personal data.
9.1.2. The request must contain:
· The number of the main identity document of the User or his representative, the date of issue of the document, and the issuing authority;
· information confirming the participation of the User in relations with the Operator (contract number, date of conclusion of the contract, conventional verbal designation, etc.), or information otherwise confirming the fact of processing of personal data by the Operator;
· the signature of the User or his representative.
The request might be sent in the form of an electronic document and signed by an electronic signature in accordance with the Russian Federation's legislation.
9.1.3. If the User's request does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data or the subject does not have the right of access to the requested information, a reasoned refusal will be sent to the User.
The User's right to access his personal data might be limited in accordance with Part 8 of Art. 14 of the Law on Personal Data, including if the User's access to his personal data violates the rights and legitimate interests of third parties.
9.2. In case of revealing inaccurate personal data, the Operator, upon request of the User, his representative, or the Roskomnadzor, will block personal data related to this User from the moment of such request or receipt of the request for the verification period, if the blocking of personal data does not violate the rights and the legitimate interests of the User or third parties. In case of confirmation of the fact of the inaccuracy of personal data, the Operator, on the basis of information provided by the User, his representative, and Roskomnadzor, or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes blocking of personal data.
9.3. In case of unlawful processing of personal data, the Operator, upon request of the User, his representative, or the Roskomnadzor, blocks the unlawfully processed personal data relating to this User from the moment of such a request or receipt of the request.
9.4. In case of achievement of the goals of data processing or the User's withdrawal of consent to its processing, personal data will be deleted unless:
· otherwise is provided by the contract to which the User is a party, beneficiary, or guarantor;
· The operator has the right to process without the User's consent on the grounds provided by the Law on Personal Data or other federal laws;
· otherwise is provided by another agreement between the Operator and the User.
10. FEEDBACK. QUESTIONS AND SUGGESTIONS. 10.1. All suggestions, questions and notifications regarding this Policy should be reported to the e-mail address:
info@leviburo.ru or by phone +7 (812) 910-88-97.