The current policy for processing personal data is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC “Artem Sirota’s Legal Bureau” (hereinafter referred to as the Operator).
1.1. The operator’s most important goal and condition for carrying out its activities is to comply with the rights and freedoms of man and citizen when processing his personal data, including protecting the rights to privacy, personal and family secrets.
1.2. 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 http://sirotapartners.ru/.
2.1 Аutomated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data is the temporary termination 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 information materials, as well as computer programs and databases that ensure their availability on the Internet at a network address http://sirotapartners.ru/.
2.4. The personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data is an action as a result of which it is impossible to determine, without using additional information, the identity 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 destruction of personal data.
2.7. The operator is a state body, a municipal body, a legal entity or an individual who independently or jointly with other persons organize and/or process personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions operations performed with personal data.
2.8. Personal data — any information related directly or indirectly to a specific or identifiable user of the website http://sirotapartners.ru/.
2.9. Personal data authorized by the subject of personal data for dissemination personal data access to an unlimited number of persons to whom the subject of personal data is provided by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in accordance with the procedure provided for by the law on personal data hereinafter personal data authorized for dissemination.
2.10. User — any visitor to the website http://sirotapartners.ru/.
2.11. Provision of personal data actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data any actions aimed at disclosure of personal data to an indefinite circle of persons transfer of personal data or familiarization with personal data to an unlimited number of persons, including disclosure of personal data in the media, placement in information and telecommunication networks or provision of 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 is permanently destroyed with the inability to further restore the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3.1. The operator has the right to:
— to receive reliable information and/or documents containing personal data from the subject of personal data;
— if the personal data subject withdraws consent to the processing of personal data and sends a request to terminate the 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 law on personal data;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the law on personal data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the law on personal data or other federal laws
3.2. The operator is obliged to:
— to provide the subject of personal data, at his request, with information concerning the processing of his personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the law on personal data;
— to inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within ten days from the date of receipt of such a request;
— publish or otherwise provide unrestricted access to this personal data processing policy;
— to take legal organizational and technical measures to protect personal data from unlawful or accidental access to them destruction modification blocking copying provision dissemination of personal data as well as from other illegal actions in relation to personal data;
— stop transferring distributing providing access to personal data stop processing and destroy personal data in accordance with the procedure and cases provided for by the law on personal data;
— perform other duties provided for by the law on personal data.
4.1. The subjects of personal data have the right to:
— to obtain information regarding the processing of personal data except for cases stipulated by the Federal laws information is provided subject of personal data by the operator in an accessible form, and it should not contain personal data relating to other subjects of personal data except for cases when there is a legitimate reason for disclosure of such personal data list of information and order of receipt stipulated in the law on personal data;
— to require the operator to clarify his personal data, block or destroy them if the personal data is incomplete outdated inaccurate illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
— to put forward a condition of prior consent when processing personal data in order to promote goods works and services on the market;
— to revoke 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 illegal actions or inaction of the operator during the processing of his personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. The subjects of personal data are obliged to:
— The Subject of Personal Data shall provide the Operator with reliable information about himself/herself.
— The Subject of Personal Data shall notify the Operator about the clarification (updating, changing) of his/her personal data.
4.3. Individuals who have provided the Operator with inaccurate information about themselves, or information about another data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined and lawful purposes. Personal data processing that is incompatible with the purposes for which the personal data were collected is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are 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 declared purposes of processing. The excess of processed personal data in relation to the declared purposes of its processing is not allowed.
5.6. When processing personal data, the accuracy, adequacy and, if necessary, relevance of personal data in relation to the purposes of processing personal data is ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows the identification of the subject of personal data, no longer than is required for the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or anonymized upon achievement of the processing purposes or in the event that the need to achieve these purposes is lost, unless otherwise provided by federal law.
The purpose of processing the User's information by sending electronic personal letters with data.
Legal basis
the statutory constituent documents of the operator
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
7.1. Personal data is processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or a law, to fulfill the functions, powers and obligations of the operator imposed on it by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the 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. The processing of personal data is necessary for the execution 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. The processing of personal data is necessary for the realization of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed, to which access of an unlimited circle of persons is provided by the personal data subject or at his/her request (hereinafter - publicly available personal data).
7.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.
The security of personal data processed by the Operator is ensured through the implementation of legal, organizationaland 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. User's personal data will never be transferred to third parties under any circumstances, except in cases related to the implementation of current legislation or in the event that the personal data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address info@sirotapartners.com with the subject "Update personal data".
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data were collected, unless otherwise provided by the contract or current legislation.
The User may at any time withdraw his consent to the processing of personal data by sending the Operator a notification by email to the Operator's email address info@sirotapartners.com with the subject "Withdrawal of consent to the processing of personal data".
8.5. All information that is 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 and/or with the specified documents. The Operator shall not be responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, established by the personal data subject, shall not apply in cases of processing of personal data in the state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject, no longer than is required for the purposes of processing personal data, unless the storage period for personal data is 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 personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the requirement to terminate the processing of personal data, as well as the identification of illegal processing of personal data.
9.1. The Operator collects, records, systematizes, accumulates, stores, refines (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information over information and telecommunication networks or without such networks.
10.1. Before starting the activities for 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 the cross-border transfer of personal data (such a 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 from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
The Operator and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12.1. The User can get any explanations on the questions of interest concerning the processing of his personal data by contacting the Operator by email info@sirotapartners.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://sirotapartners.ru/.