Privacy Policy (personal data processing)
1.General provisions
This Privacy Policy (Personal Data Processing) (hereinafter - the Policy) is drawn up in accordance with the requirements of the Federal Law of 27.07.2006 No 152-FZ “On Personal Data” (hereinafter - the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure security of personal data taken by the Moscow City Bar Association "Barshchevsky & Partners" (hereinafter - the Operator).
1.1. The Operator's most important goal and condition for its activities is to observe human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data applies to all information that the Operator may receive about visitors to the bbp.ru website.
2.Basic concepts used in the Policy
2.1. Automated personal data processing - personal data processing using computer hardware.
2.2. Blocking of personal data - temporary termination of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as programs for computers and databases, making them available on the Internet at the domain name bbp.ru and the network address https://www.bbp.ru/.
2.4. Information system of personal data - a set of personal data contained in databases of personal data and information technology 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 as to what personal data belongs to a particular user or other subject of personal data.
2.6. Personal Data Processing - any action (operation) or series of actions (operations) with the Personal Data performed with or without automation means including collection, recording, classification, accumulation, storage, clarification (updating, modification), extraction, using, transfer (distribution, provision, granting access), anonymization, blocking, deletion, destruction of the Personal Data.
2.7. Operator - governmental authority, municipal authority, legal entity or individual independently or jointly with other persons arranging and (or) carrying out Personal Data processing, determining the purposes of Personal Data processing, scope of the Personal Data subject to processing, actions (operations) with the Personal Data.
2.8. Personal Data - any information relating directly or indirectly to a specific or identifiable User of the Website.
2.9. Personal data, authorized by the subject of personal data for distribution, - personal data, access to which is provided to the general public by the subject of personal data by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, authorized for distribution).
2.10. User - any visitor to the Website (subject of personal data).
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of people.
2.12. Dissemination of personal data - any action aimed at the disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize with personal data to an unlimited number of persons, including the publication of personal data in the media, placing in information and telecommunications networks or provide access to personal data in any other way.
2.13. Destruction of personal data - any action resulting in the destruction of personal data irretrievably with the inability to further restore the content of personal data in the information system of personal data and (or) the destruction of the material media personal data.
3.Principal Rights and Obligations of the Operator
3.1. The Operator is entitled to:
- receive from the subject of personal data accurate information and/or documents containing personal data;
- if the subject of personal data withdraws consent to the processing of personal data, the Operator may continue the processing of personal data without the consent of the subject of personal data on the grounds specified in the Law on Personal Data;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations under 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.
The Operator shall:
- provide the subject of personal data, at their request, information relating to the processing of their personal data;
- organize the processing of personal data in accordance with the procedure established by applicable law of the Russian Federation;
- respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
- communicate to the authorized body for the protection of the rights of subjects of personal data, at the request of this body the necessary information within 30 days from the date of receipt of such a request;
- publish or otherwise provide unrestricted access to this Policy on the Processing of Personal Data;
- take legal security measures, employ operational discipline and engineering controls to protect personal data against unauthorized or accidental access thereto, destruction, modification, blocking, copying, provision, distribution as well as other illegal actions with respect to personal data;
- stop processing and destroy personal data in the manner and cases provided by the Law on Personal Data;
- perform other duties stipulated by the Law on Personal Data.
4. Principal Rights and Obligations of the Subject of Personal Data
4.1. Personal data subjects shall be entitled to:
- receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- require the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
- impose the condition of prior consent when processing personal data for the purpose of promoting goods, works and services in the market;
- withdraw consent to the processing of personal data at any time, by sending a notice by e-mail to the Operator's e-mail address info1@bbp.ru marked “Withdrawal of consent to personal data processing”;
- appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or omissions of the Operator in the processing of their personal data;
- exercise other rights stipulated by the laws of the Russian Federation.
4.2. The personal data subject shall:
- provide the Operator with reliable data about themselves;
- inform the Operator about clarification (update, change) of their personal data.
4.3. Persons who provided the Operator with false information on themselves, or information on another subject of personal data without the consent of the latter shall be liable in accordance with the laws of the Russian Federation.
5.The Operator can process the following personal data of the User
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The website may also collect and process impersonal data about visitors (including cookies) using Internet statistical services (Yandex Metrics and Google Analytics and others).
5.5. The above-mentioned data further in the text of the Policy are combined under the general term Personal Data.
5.6. Processing of sensitive information related to race, ethnical identity, political opinions, religious or philosophic beliefs, intimacy is prohibited by the Operator.
5.7. Processing of personal data, authorized for distribution, from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is allowed, provided the prohibitions and conditions specified in Article 10.1 of the Law on Personal Data are observed.
5.8. User's consent to the processing of personal data allowed for distribution is executed separately from other consents to the processing of their personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent shall be established by the authorized body for the protection of the rights of subjects of personal data.
5.8.1. Consent to the processing of personal data allowed for distribution, the User shall provide the Operator directly.
5.8.2. The Operator is obliged, within three working days of receiving the above consent from the User, to publish information concerning the conditions of processing, the existence of prohibitions and conditions on the processing of personal data allowed for distribution to an unlimited number of persons.
5.8.3. Transfer (distribution, provision, access) of personal data, authorized by the subject of personal data for distribution, must be terminated at any time on request of the subject of personal data. This requirement must include the surname, first name, patronymic (if any), contact information (phone number, email address or mailing address) of the subject of personal data, 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 it is sent.
5.8.4. Consent to the processing of personal data authorized for dissemination shall terminate upon receipt by the Operator of the request set forth in clause 5.8.3 of this Policy regarding the processing of personal data.