1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Moy Produkt LLC (hereinafter — the Operator) to ensure the security of personal data.
1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data — including the protection of the rights to privacy and to personal and family confidentiality — to be the most important objective and condition of its activities.
1.2. This Operator policy on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://myproduct.ru/.
2. Key terms used in the Policy
2.1. Automated processing of personal data — the processing of personal data using computer technology.
2.2. Blocking of personal data — the temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://myproduct.ru/.
2.4. Personal data information system — a set of personal data contained in databases together with the information technologies and technical means that ensure its processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://myproduct.ru/.
2.9. Personal data authorized for dissemination by the personal data subject — personal data to which access has been granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data authorized for dissemination by the personal data subject in the manner provided for by the Personal Data Law (hereinafter — personal data authorized for dissemination).
2.10. User — any visitor to the website https://myproduct.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publishing personal data in the mass media, posting it on information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign state authority, or to a foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irrevocably destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and/or as a result of which the physical media containing the personal data are destroyed.
3. Principal rights and obligations of the Operator
3.1. The Operator has the right to:
- receive from the personal data subject accurate information and/or documents containing personal data;
- where the personal data subject withdraws consent to the processing of personal data, or sends a request demanding that the processing of personal data cease, continue processing the personal data without the consent of the personal data subject if the grounds set out in the Personal Data Law are present;
- independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the 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 the personal data subject, at their request, with information concerning the processing of their personal data;
- organize the processing of personal data in the manner established by the applicable legislation 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;
- report the necessary information to the authorized body for the protection of the rights of personal data subjects, at that body's request, within 10 days of receiving such a request;
- publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
- take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision and dissemination, as well as against other unlawful actions in respect of personal data;
- cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
- fulfil other obligations provided for by the Personal Data Law.
4. Principal 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 must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- require the operator to clarify, block or destroy their personal data where the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take the measures provided for by law to protect their rights;
- require prior consent as a condition for the processing of personal data for the purpose of promoting goods, works and services on the market;
- withdraw consent to the processing of personal data, and to send a demand that the processing of personal data cease;
- appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate information about themselves;
- 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 that subject's consent, bear liability in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. 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 its collection is not permitted.
5.3. It is not permitted to merge databases containing personal data that is processed for mutually incompatible purposes.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessiveness of the personal data processed in relation to the stated purposes of its processing is not permitted.
5.6. When processing personal data, the accuracy and sufficiency of the personal data is ensured, as is its currency where necessary in relation to the purposes of the personal data processing. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of the personal data processing, unless the storage period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. The personal data processed is destroyed or depersonalized once the purposes of processing have been achieved or where the need to achieve those purposes is lost, unless otherwise provided by federal law.
6. Purposes of personal data processing
- Last name, first name, patronymic
- Email address
- Phone numbers
- The Operator's charter (constituent) documents
- Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
- Sending informational emails to the email address
7. Conditions for processing personal data
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice and the enforcement of a judicial act or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. 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.
7.5. 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 purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out on personal data to which access has been granted to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out on personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the collection, storage, transfer and other types of personal data processing
The security of the personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for full compliance with the requirements of applicable personal data protection legislation.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation, or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are found in personal data, the User may update them independently by sending the Operator a notification to the Operator's email address info@myproduct.ru marked "Updating personal data".
8.4. 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 for by contract or applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by email to the Operator's email address info@myproduct.ru marked "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the said documents. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than obtaining access) of personal data authorized for dissemination, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of the personal data processing, unless the storage period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of the personal data processing, the expiry of the personal data subject's consent, the withdrawal of consent by the personal data subject, a demand to cease the processing of personal data, or the discovery of unlawful processing of personal data.
9. List of actions performed by the Operator with the personal data received
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.
10. Cross-border transfer of personal data
10.1. Before commencing activities involving 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 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 the relevant information from the authorities of the foreign state and the foreign individuals and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties and not to disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator by email at info@myproduct.ru.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet
