Personal Data Processing Policy
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 taken to ensure the security of personal data by US-MEDIA LLC (hereinafter — the Operator).
1.1. The Operator’s most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the right 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://reputaciya.us-media.ru/.
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 cessation of processing of personal data (except in cases 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 ensure their availability on the Internet at the network address https://reputaciya.us-media.ru/.
2.4. Personal data information system — a set of personal data contained in databases and 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 ownership of personal data to a specific User or other 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 (distribution, 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, as well as 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://reputaciya.us-media.ru/.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which unlimited access has been granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://reputaciya.us-media.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication 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 a government 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 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. Basic 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;
- in the event of withdrawal by the personal data subject of consent to the processing of personal data, as well as upon submission of a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject 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 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 request, with information regarding the processing of their 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 personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized body for the protection of the rights of personal data subjects, upon request of this body, with the necessary information within 10 days from the date of receipt of such request;
- publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
- cease the transfer (distribution, 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. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- receive information regarding 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 it must not contain personal data relating to other personal 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;
- 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 take measures provided by law to protect their rights;
- set a 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 submit a request to cease processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data;
- 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;
- inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the consent of the latter, 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 that is incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of 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, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes the 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 makes it possible to identify the personal data subject, no longer than required by the purposes of processing personal data, if the storage period for personal data is not established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of processing | providing the ability to use the Operator’s services and products, increasing visitors’ awareness of the Operator’s products and services, sending system notifications necessary for the performance of a contract, providing technical support, processing requests to the Operator, providing targeted advertising information and optimizing advertising campaigns, and for other marketing and advertising purposes. |
|---|---|
| Personal data | email address, phone numbers, name |
| Legal grounds |
|
| Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data. Sending informational emails to the email address. |
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out 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 exercise of the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official subject to execution 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, beneficiary, or guarantor, 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 guarantor.
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 goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data to which unlimited access has been granted by the personal data subject or at their request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of 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, 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 consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the email address info@us-media.ru with the note “Personal data update”.
8.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator by email at info@us-media.ru with the note “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to independently familiarize themselves with the specified 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 providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined 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, no longer than required by the purposes of processing personal data, if the storage period for personal data is not established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The condition for termination of processing of personal data may be the achievement of the purposes of processing personal data, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or a request to cease processing of personal data, as well as identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to 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 relevant information from the government authorities of a foreign state, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute 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 issues of interest regarding the processing of their personal data by contacting the Operator by email at info@us-media.ru.
12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://reputaciya.us-media.ru/politic/.