Personal Data Processing Policy



Personal Data Processing Policy

1. General provisions

This Personal Data Processing Policy is compiled in accordance with the requirements of Federal Law No. 152-ФЗ as of July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data taken by ORIENT TRANSLATING LLC (hereinafter referred to as the "Operator").

1.1. The operator makes it a condition for the implementation of its activities to respect the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about website visitors https://www.orientranslating.ru/

2. Basic concepts used in the Policy

2.1. Automated processing of personal data is the processing of personal data using computer technology.

2.2. Blocking of personal data is a temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. A website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at a network address https://www.orientranslating.ru /

2.4. A 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. A depersonalization of personal data means 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 subject of personal data.

2.6. Personal data processing is 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. An Operator is a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data are any information related directly or indirectly to a specific or identifiable User of the website https://www.orientranslating.ru /

2.9. Personal data authorized by a subject of personal data for distribution – personal data to which an unlimited number of persons have access given by a subject of personal data by giving consent to the processing of personal data authorized by a subject of personal data for distribution in accordance with the procedure provided for by the Personal Data Law (hereinafter – "personal data authorized for distribution").

2.10. A User is any visitor to the website https://www.orientranslating.ru/

2.11. A provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

2.12. A distribution of personal data means any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited circle of persons, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.

2.13. A cross–border transfer of personal data is a transfer of personal data to a territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. A destruction of personal data means any actions as a result of which personal data are permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:

– receive reliable information and/or documents containing personal data from a subject of personal data;

– if a subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of a subject of personal data 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 a 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 from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

– to inform the authorized body for the protection of the rights of personal data subjects at this body`s request of the necessary information within 30 days from the date of receipt of such a request;

– publish this Personal Data Processing Policy or otherwise provide unrestricted access to it;

– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions with respect to personal data;

– stop the transfer (distribution, provision) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

– perform other duties stipulated 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 concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law ;

– require the Operator to clarify personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;

– to put forward the 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;

– 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 when processing personal data;

– to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

– provide the Operator with reliable data about themselves;

– inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of a User

5.1. Surname, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. The site also collects and processes depersonalized data about visitors (including cookies) using Internet statistics services (Yandex.Metrica, Google Analytics and others).

5.5. The above data, hereinafter referred to in the text of the Policy, are combined by the general concept of "Personal Data".

5.6. Processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life, is not carried out by the Operator.

5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.

5.8. A User's consent to the processing of personal data allowed for distribution is issued separately from other consents to the processing of his personal data. At the same time, the conditions stipulated, 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.

5.8.1. A User gives consent to the processing of personal data allowed for distribution directly to the Operator.

5.8.2. The Operator is obliged, no later than three working days from the date of receipt of a User's consent, to publish information on the processing conditions, on the existence of prohibitions and conditions for processing by an unlimited number of persons of personal data allowed for distribution.

5.8.3. The transfer (distribution, provision) 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 requirement must include the surname, 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 processing of which is subject to termination. The personal data specified in this request can be processed only by the Operator to whom it is sent.

5.8.4. The consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.8.3 of this Personal Data Processing Policy.

5.8.3 of this Personal Data Processing Policy.

6. Principles of personal data processing

6.1. The processing of personal data is carried out on a legal and fair basis.

6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

6.4. Only personal data that meet the purposes of such processing are subject to processing.

6.5. The content and volume of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

6.6. The processing of personal data ensures the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

6.7. The storage of personal data is carried out in a form that allows to determine a subject of personal data, no longer than the purposes of personal data processing require, if the storage period of personal data is not established by federal law, an contract to which a subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. Purposes of processing a User's personal data:

– informing a User by sending emails;

– clarification of order details.

7.2. The Operator also has the right to send notifications to a User about new products and services, special offers and various events. A User can always refuse to receive informational messages by sending an email to the Operator info@orientranslating.ru marked "Refusal of notifications about new products and services and special offers".

7.3. Depersonalized User data collected using Internet statistics services are used to collect information about User actions on the site, improve the quality of the site and optimize its content.

8. Legal grounds for processing personal data

8.1. The legal grounds for processing personal data by the Operator are:

– statutory (constituent) documents of the Operator;

– federal laws and other regulatory legal acts in the field of personal data protection;

– consent of Users to the processing of their personal data and personal data allowed for distribution.

8.2. The Operator processes a User's personal data only if they are filled in and/or sent by a User independently through special forms located on the website https://www.orientranslating.ru / or sent to the Operator via e-mail. By filling out the appropriate forms and/or sending their personal data to the Operator, a User agrees with this Policy.

8.3. The Operator processes depersonalized data about a User if this is allowed in a User's browser settings (cookie saving and the use of javascript technology are enabled).

8.4. A subject of personal data independently decides on the provision of his personal data and gives consent freely, of his own free will and in his own interests.

9. Terms of 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 his personal data.

9.2. The processing of personal data is necessary to achieve the goals stipulated by an international agreement of the Russian Federation or a law, to carry out the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.

9.3. 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.

9.4. The processing of personal data is necessary for an execution of a contract to which a subject of personal data is a party or beneficiary or guarantor, as well as for a conclusion of a contract on an initiative of a subject of personal data or a contract under which a subject of personal data will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that rights and freedoms of a personal data subject are not violated.

9.6. The processing of personal data is carried out, access of an unlimited number of persons to which is provided by a subject of personal data, or at his request (hereinafter referred to as "publicly available personal data").

9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

10. Procedure for the 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.

10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to the personal data of unauthorized persons.

10.2. A User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation, or if a subject of personal data has given the Operator consent to transfer data to a third party to fulfill obligations under a civil contract.

10.3. In case of identification of inaccuracies in personal data, a User can update them independently by sending a notification to the Operator to the Operator's email address welcome@tolq.spb.ru marked "Updating of personal data".

10.4. The term of processing of personal data is determined by the achievement of the purposes for which personal data was collected, unless another term is provided for by a contract or current legislation. A User can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator to the Operator's email address info@orientranslating.ru marked "Withdrawal of consent to the processing of personal data".

10.5. All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreements and Privacy Policies. A subject of personal data and/or a User is obliged to familiarize himself with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

10.6. The prohibitions established by a subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, community and other public interests defined by the legislation of the Russian Federation.

10.7. The Operator ensures the confidentiality of personal data when processing personal data.

10.8. The Operator stores personal data in a form that allows to determine a subject of personal data, no longer than the purposes of personal data processing require, if the period of personal data storage is not established by federal law, an contract to which a subject of personal data is a party, beneficiary or guarantor.

10.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, an expiration of a consent of a personal data subject or a withdrawal of a consent by a personal data subject, as well as the identification of unlawful processing of personal data.

11. List of actions performed by the Operator with the received personal data

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides), depersonalizes, blocks, deletes and destroys personal data.

11.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting received information via information and telecommunication networks.

12. A cross-border transfer of personal data

12.1. Prior to the start of a cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state to the territory of which the transfer of personal data is supposed to be carried out provides reliable protection of the rights of personal data subjects.

12.2. A cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if a personal data subject has written consent to a cross-border transfer of his personal data and/or an execution of a contract to which a personal data subject is a party.

13. Confidentiality of personal data

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 a subject of personal data, unless otherwise provided by federal law.

14. Final provisions

14.1. A User can get any clarifications on issues of interest concerning processing of his personal data by contacting the Operator at the email address info@orientranslating.ru

14.2. This document will reflect any changes to the Personal Data Processing Policy by the Operator. The Policy is valid indefinitely until it is replaced by a new version.

14.3. The current version of the Policy is published on the Internet in free access at the address. Personal Data Processing Policy