Personal Data Processing Policy
1. General Provisions and Key Terms
This personal data processing policy has been drawn up 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 WEBMARKETING Limited Liability Company (OGRN: 1237800096533, TIN: 7842217430), registered at: 191014, Saint Petersburg, Nekrasova St., 29 lit. A, prem. 1-n office 2-2 (hereinafter referred to as the Operator).
The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets, as its most important goal and condition for conducting its activities.
This Operator's policy 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://webmarketing.ru/ (hereinafter referred to as the Website).
This Privacy Policy applies only to the Website https://webmarketing.ru/. The Website https://webmarketing.ru/ does not control and is not responsible for third-party websites that the User may access via links available on the Website https://webmarketing.ru/.
The Operator processes the User's personal data only if it is filled in and/or submitted by the User independently through special forms located on the website https://webmarketing.ru/. By filling in the relevant forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.
The Operator processes anonymized data about the User if this is permitted in the User's browser settings (cookie storage and JavaScript technology are enabled).
2. Key Terms and Definitions Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means a temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://webmarketing.ru/.
2.4. Personal data information system means a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data means actions as a result of which it is impossible to determine, without the use of additional information, the association of personal data with a specific User or other personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automated means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator means a government 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 means any information relating directly or indirectly to a specific or identifiable User of this website.
2.9. Personal data authorized by the data subject for distribution means personal data to which access by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure provided by the Personal Data Law (hereinafter referred to as personal data authorized for distribution).
2.10. User means any visitor to this website.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at acquainting an unlimited number of persons with personal data, including the publication of personal data in the mass 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 means the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data means any actions as a result of which personal data are irreversibly destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3. Operator's Rights and Obligations
3.1. The Operator has the right to:
3.1.1. Receive reliable information and/or documents containing personal data from the personal data subject;
3.1.2. In the event that 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 if there are grounds specified in the Personal Data Law;
3.1.3. Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided 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:
3.2.1. Provide the personal data subject, upon their request, with information concerning the processing of their personal data;
3.2.2. Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
3.2.3. Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
3.2.4. Report the required information to the authorized body for the protection of the rights of personal data subjects upon request of said body within 30 days from the date of receipt of such request;
3.2.5. Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
3.2.6. Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
3.2.7. Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
3.2.8. Fulfill other obligations provided by the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
4.1.1. Receive information concerning the processing of their personal data, except in cases provided by federal laws. The information is 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, except in cases where there are lawful grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
4.1.2. Require the operator to clarify their personal data, block or destroy it 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 by law to protect their rights;
4.1.3. Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
4.1.4. Withdraw consent to the processing of personal data;
4.1.5. 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 in the processing of their personal data;
4.1.6. Exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
4.2.1. Provide the Operator with accurate data about themselves;
4.2.2. Inform the Operator of any clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Personal Data Processed by the Operator
5.1. Last name, first name, patronymic
5.2. Email address
5.3. Phone numbers
5.4. Company or project name
5.5. Job title
5.6. Website address (URL)
5.7. Content of messages submitted through feedback forms
5.8. Files attached through feedback forms
5.9. The website also collects and processes anonymized data about visitors using the Yandex Metrica internet statistics service.
5.10. The above-mentioned data are hereinafter collectively referred to as Personal Data throughout the text of this Policy.
5.11. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.12. The processing of personal data authorized for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions provided by Article 10.1 of the Personal Data Law are observed.
5.13. The User's consent to the processing of personal data authorized for distribution is issued separately from other consents to the processing of their personal data. In doing so, the conditions provided, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.13.1. Consent to the processing of personal data authorized for distribution is provided by the User directly to the Operator.
5.13.2. The Operator is obliged, no later than three business days from the date of receipt of the said User's consent, to publish information about the processing conditions, the existence of prohibitions and conditions on the processing by an unlimited number of persons of personal data authorized for distribution.
5.13.3. The transfer (distribution, provision, access) of personal data authorized by the personal data subject for distribution must be ceased at any time at the request of the personal data subject. Such a request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is to be ceased. The personal data specified in such a request may only be processed by the Operator to whom it is addressed.
5.13.4. Consent to the processing of personal data authorized for distribution ceases to be effective from the moment the Operator receives the request specified in clause 5.13.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
6.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
6.4. Only personal data that meets the purposes of their processing shall be subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. The processed personal data shall not be excessive in relation to the stated purposes of their processing.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required by 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. Processed personal data are destroyed or anonymized upon achievement of the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data:
7.1.1. Informing the User by sending emails;
7.1.2. Conclusion, execution, and termination of civil law contracts;
7.1.3. Providing the User with access to services, information, and/or materials contained on the website.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may at any time opt out of receiving informational messages by sending an email to the Operator at [email protected].
7.3. Anonymized User data collected through the Yandex Metrica internet statistics service is used to gather information about User actions on the website, improve the quality of the website, and its content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for the Operator's processing of personal data are:
8.1.1. Federal Law No. 149-FZ dated July 27, 2006 "On Information, Information Technologies and Protection of Information";
8.1.2. The Operator's charter documents;
8.1.3. Contracts concluded between the operator and the personal data subject;
8.1.4. Federal laws and other regulatory legal acts in the field of personal data protection;
8.1.5. Users' consents to the processing of their personal data, to the processing of personal data authorized for distribution.
8.2. The Operator processes the User's personal data only if it is filled in and/or submitted by the User independently through special forms located on the website or sent to the Operator via email. By filling in the relevant forms and/or submitting their personal data to the Operator, the User expresses their 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 storage and JavaScript technology are enabled).
8.4. The personal data subject independently decides on the provision of their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions for Personal Data Processing
9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the goals provided by an international treaty of the Russian Federation or by law, to carry out the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The 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 the conclusion of 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.
9.5. The processing of personal data is necessary for the exercise 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.
9.6. Processing is carried out of personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
10. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of current legislation, or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
10.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address with the subject line "Personal Data Update".
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided by a 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 via email with the subject line "Withdrawal of Consent to Personal Data Processing".
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to familiarize themselves with said documents in a timely manner. The Operator is not responsible for the actions of third parties, including service providers mentioned in this clause.
10.6. Prohibitions on transfer (other than providing access), as well as on processing or conditions of processing (other than obtaining access) of personal data authorized for distribution established by the personal data subject, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data during the processing of personal data.
10.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by 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.
10.9. The conditions for the termination of personal data processing may include the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Obtained Personal Data
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of information received via information and telecommunications networks or without such.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may only be carried out if there is written consent of the personal data subject to the cross-border transfer of their personal data and/or the execution of a contract to which the personal data subject is a party.
13. Confidentiality of Personal Data
13.1. The Operator and other persons who have gained 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.
14. Final Provisions
14.1. The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator via email at [email protected].
14.2. The current version of the Policy is freely available on the Internet at https://webmarketing.ru/privacy-policy.
14.3. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.