1. General Regulations.This Personal Data Processing Policy is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "About Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure of personal data processing and measures to ensure personal data security taken by PRIDE-MARKETING LLC (hereinafter referred to as the Operator).
1.1 The Operator's most important purpose and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of rights to privacy, personal and family secrets.
1.2 This Operator's personal data processing policy (the "Policy") applies to all information that the Operator may receive about visitors to https://pride.marketing.
2. Basic Concepts Used in this Policy2.1. Automated processing of personal data means processing of personal data with the help of computer technology.
2.2. Blocking of personal data - temporary suspension of processing of personal data (unless the processing is necessary to clarify the personal data).
2.3. Website - a collection of graphic and information materials, as well as computer programs and databases, making them available on the Internet at the network address https://pride.marketing.
2.4. Personal data information system - a set of personal data contained in databases of personal data and information technologies and technical means ensuring its processing.
2.5. Depersonalization of personal data - actions that make it impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another subject of personal data.
2.6. Processing of personal data means any action (operation) or a set of actions (operations) performed with or without the use of means of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal entity or natural person, independently or together with other persons, arranging and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to an identified or identifiable User of the https://pride.marketing website.
2.9. Personal data permitted by the personal data subject for dissemination - personal data, access to which is granted to an unlimited number of persons by the personal data subject by giving consent to processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for dissemination).
2.10. A user is any visitor to the https://pride.marketing website.
2.11. Provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to make personal data available to an unlimited number of persons, including disclosure of personal data in the media, placement 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 a foreign state authority, foreign natural person or foreign legal entity.
2.14. Destruction of personal data - any action resulting in the destruction of personal data irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) destruction of tangible media of personal data.
3. Basic rights and obligations of the operator3.1. The Operator have the right to:- Receive accurate information and/or documents containing personal data from the data subject;- If the personal data subject withdraws consent to the processing of personal data, the operator has the right to continue processing personal data without the consent of the personal data subject on the grounds set out in the Personal Data Act.- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations under the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The operator must:- provide the data subject, at his or her request, with information relating to the processing of his or her personal data;- organize the processing of personal data in accordance with the procedure established by the applicable laws of the Russian Federation;- respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;- to provide the competent authority for the protection of personal data subjects with the necessary information upon request of that authority within 30 days of receiving such a request;- publish or otherwise provide unrestricted access to this Policy on the processing of personal data;- Take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, sharing, distribution of personal data, and other unlawful acts in relation to personal data;- stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for in the Personal Data Act;- fulfill other obligations stipulated in the Personal Data Act.
4. Basic rights and obligations of subjects of personal data4.1. Personal data subjects have the right to- Receive information relating to the processing of his or her personal data, except in cases provided for by federal laws. Information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, unless there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it, is established by the Personal Data Act;- Demand that the operator clarify, block or destroy personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and to take statutory measures to protect their rights;- to condition prior consent when processing personal data for the purpose of marketing goods, works and services;- to withdraw your consent to the processing of personal data;- To appeal to the competent authority for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in processing his personal data;- to exercise other rights provided for by Russian law.
4.2. Personal data subjects shall- provide the Operator with accurate information about yourself;- inform the operator of any changes (updates, amendments) to your personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another personal data subject without their consent shall be liable in accordance with Russian law.
5. The operator may process the following personal data of the User5.1. Surname, first name, patronymic.
5.2. E-mail address.
5.3. Telephone numbers.
5.4. The website also collects and processes depersonalized visitor data (including cookies) using internet statistics services (Yandex Metrics and Google Analytics and others).
5.5. The above-mentioned data are hereinafter referred to in this Policy under the generic term Personal Data.
5.6. The Operator shall not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data, authorized for dissemination, from among the special categories of personal data specified in Article 10.1 of the Personal Data Law shall be permitted if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are complied with.
5.8. The User's consent to the processing of personal data authorized for distribution shall be executed separately from other consents to the processing of its personal data. The conditions stipulated, in particular, by Article 10.1 of the Personal Data Act shall be complied with. The requirements for the content of such consent shall be established by the authority responsible for the protection of personal data subjects' rights.
5.8.1. The User consents to the processing of personal data authorized for distribution directly to the Operator.
5.8.2. The Operator shall, within three working days of receipt of the above consent of the User, publish information about the processing conditions, prohibitions and conditions on the processing of personal data permitted for distribution to an unlimited number of persons.
5.8.3. Transfer (distribution, provision, access) of personal data, authorized by the personal data subject for distribution, must be terminated at any time at the request of the personal data subject. This request shall include the surname, first name, patronymic (if you have), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the operator to whom the request is sent.
5.8.4. Consent to the processing of personal data authorized for distribution shall terminate upon receipt by the Operator of the request referred to in section 5.8.3 of this Policy for the processing of personal data.
6. Principles of personal data processing6.1. Personal data shall be processed in a lawful and fair manner.
6.2. Processing of personal data shall be limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.
6.3. Databases containing personal data whose processing is incompatible with each other shall not be merged.
6.4. Only personal data that is suitable for processing shall be processed.
6.5. The content and scope of personal data processed shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.
6.6. When processing personal data, the accuracy of personal data, its sufficiency and, where necessary, its relevance in relation to the purposes of personal data processing shall be ensured. The operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than the purpose of personal data processing requires, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalized upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided by federal law.
7. Purposes of personal data processing7.1. Purpose of processing of the User's personal data:- informing the User by sending e-mails;- the conclusion, performance and termination of civil law contracts;- providing the User with access to the services, information and/or materials contained on https://pride.marketing.
7.2. The Operator is also entitled to send to the User notifications about new products and services, special offers and various events. The User can always opt out of receiving information messages by sending an email to the Operator at welcome@pridemarketing.ru marked as "Opt-out of notifications of new products and services and special offers".
7.3. The depersonalized User data collected via Internet statistical services is used to collect information about Users' activities on the website and to improve the quality of the website and its content.
8. Legal basis for processing personal data8.1. The legal basis for the processing of personal data by the Operator are:- Federal Law "On Information, Information Technology and Information Protection" of 27.07.2006 N 149-FZ;;- Federal laws and other regulations governing personal data protection;- The user's consent to the processing of their personal data, and to the processing of personal data that is authorized for distribution.
8.2. The Operator processes the User's personal data only if the User fills them in and/or sends them by himself through the special forms located on the website https://pride.marketing or sent to the Operator by e-mail. By filling in the relevant forms and/or sending his personal data to the Operator, the User expresses his consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (cookie saving and the use of JavaScript technology are enabled).
8.4. The personal data subject shall independently decide on the provision of his or her personal data and give consent freely, of his or her own free will and in his or her own interest.
9. Terms of personal data processing9.1. The processing of personal data shall be subject to the consent of the data subject to the processing of his or her personal data.
9.2. Processing of personal data is necessary in order to achieve the purposes set out in an international treaty of the Russian Federation or by law, to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for administration of justice, enforcement of a judicial act, act of another authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary in order to fulfill an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as to conclude an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and lawful interests of the operator or third parties or to achieve socially important objectives, on condition that the rights and freedoms of the data subject are not infringed thereby.
9.6. Personal data shall be processed to which access is granted to an unlimited number of persons by the subject of personal data or at his or her request (hereinafter referred to as "publicly accessible personal data").
9.7. Personal data subject to publication or compulsory disclosure under federal law shall be processed.
10. Procedure for collecting, storing, transferring and other processing of personal dataThe security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to comply fully with the requirements of current legislation in the field of personal data protection.
10.1. The operator shall ensure the security of personal data and shall take all possible measures to exclude access to personal data by unauthorized persons.
10.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.
10.3. If inaccuracies in the personal data are identified, the User may update the personal data themselves by sending a notification to the Operator's email address welcome@pridemarketing.ru, marked as "Update of personal data".
10.4. The time period for processing personal data shall be determined by achieving the purposes for which the personal data was collected, unless a different time period is stipulated by the agreement or applicable law.The user may withdraw their consent to the processing of personal data at any time by sending to the Operator a notification via email to the Operator's email address welcome@pridemarketing.ru, marked as "Withdrawal of consent to the processing of personal data".
10.5. All information that is collected by third party services, including payment systems, means of communication and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to acquaint themselves with the said documents timely. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
10.6. The prohibitions established by the personal data subject on the transfer (other than granting access) and processing or conditions of processing (other than obtaining access) of personal data authorized for distribution shall not apply in cases of processing of personal data for state, public and other public interests as defined by Russian law.
10.7. The operator shall ensure the confidentiality of personal data when processing personal data.
10.8. The operator shall store personal data in a form that allows the identification of the personal data subject for no longer than the purposes of personal data processing require, unless the storage period of personal data is prescribed by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor under which the personal data subject is a beneficiary.
10.9. A condition for the termination of personal data processing may be the achievement of the personal data processing objectives, expiry of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as the identification of unlawful personal data processing.
11. List of actions taken by the operator with the personal data received11.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), anonymize, block, delete and destroy personal data.
11.2. The Operator shall carry out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunication networks.
12. Cross-border transfer of personal data12.1. Before the cross-border transfer of personal data, the operator must ensure that the foreign country to whose territory the transfer of personal data is to take place provides adequate protection of the rights of personal data subjects.
12.2. The cross-border transfer of personal data to foreign countries that do not meet the aforementioned requirements may only take place if the personal data subject consents in writing to the cross-border transfer of his/her personal data and/or performance of the agreement to which the personal data subject is a party.
13. Confidentiality of personal data. The operator and other persons who have access to personal data shall not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final provisions14.1. The User may obtain any clarification on questions of interest regarding the processing of their personal data by contacting the Operator by e-mail at welcome@pridemarketing.ru.
14.2. This document will reflect any changes to the personal data processing policy by Operator. The Policy shall be valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at
https://pride.marketing/politika