PRIVACY POLICY
1. TERMS AND DEFINITIONS
1.1. In this Privacy Policy the following terms shall have the following meanings:
1.1.1. Website Administration means the employees authorized to manage the website, acting on its behalf, who arrange for the personal data processing and (or) process personal data, and determine the objectives of personal data processing, scope of personal data to be processed and actions (operations) to be performed with personal data.
1.1.2. Confidentiality of Personal Data means a mandatory requirement for the Website Administration to prevent their intentional dissemination without the consent of personal data owner or other legitimate grounds.
1.1.3. Personal Data Processing means any action (operation) or a set of actions (operations) performed with personal data with or without the use of computer equipment, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, disclosure, access), depersonalization, blocking, deletion, and destruction of personal data.
1.1.4. Personal Data Operator means a legal entity that arranges for the personal data processing and (or) processes personal data, and determines the objectives and scope of personal data processing. Under this Privacy Policy, the operator is Resource Group LLC.
1.1.5. Personal Data means any information related, directly or indirectly, to a specific or identifiable individual (personal data owner).
1.1.6. Website User (hereinafter referred to as the User) means a person having access to the website via the Internet and using this website for their own purposes.
1.1.7. Website means an Internet resource located at: www.resourcegroup.ru
1.1.8. Personal Data Owner means an individual who is directly or indirectly identified or identifiable using personal data.
1.1.9. Cookies means a small piece of data sent by a web server and stored on the User’s computer, which the web client or web browser sends to the web server each time in an HTTP request when trying to open a page of the respective website.
1.1.10. IP address means is a unique network address of a host in a computer network built using the IP protocol.
2. GENERAL
2.1. This Personal Data Policy (hereinafter referred to as the Privacy Policy) of Resource Group LLC (hereinafter referred to as the Operator), taxpayer identification number (TIN): 7703353740, located at: 127287, Moscow, 38A, 2nd Khutorskaya Str., bldg.14 room 69, was executed in accordance with paragraph 2 of Article 18.1 of the Federal Law On Personal Data No.
2.2. The Website Administration shall ensure the protection of personal data being processed from unauthorized access and disclosure, misuse or loss as required by Federal Law No.
2.3. The Website Administration may amend this Privacy Policy. When making changes, the last revision date shall be indicated in the Policy header. The new version of the Policy shall come into force upon publication on the website, unless otherwise provided by the new version of the Policy.
2.4. This Privacy Policy shall apply to any information about the User that the Website may receive, as well as any programs and products posted on it.
2.5. The current version of the Privacy Policy is a public document developed by the Website Administration and is available to any Internet User by clicking on a hypertext link “Privacy Policy”.
2.6. By using the feedback form, leaving a request, or using other available resources of the Website, the User agrees with this Privacy Policy and the conditions of the User’s personal data processing.
2.7. If the User does not agree with the terms and conditions of this Privacy Policy, the User shall stop using the Website.
2.8. This Privacy Policy shall apply only to this Website. The Website Administration does not control and shall not be liable for third-party websites which the User can visit by clicking the links available on this Website.
2.9. The Website Administration shall not verify the accuracy of the personal data provided by the Website User.
3. SCOPE OF THE PRIVACY POLICY
3.1. This Privacy Policy establishes the Website Administration obligations for the wilful non-disclosure of personal data provided to the Website Administration by the User.
3.2. The personal data are processed by the Website Administration in order to:
· identify the User to place an order and (or) conclude a Contract, execute an application;
· provide consultation to the User following the application left on the Website by filling out the feedback form;
· communicate with the User after completion of the feedback form on the Website, including notifications, requests and other information;
· provide services to the User and improve the quality of the Website and Services;
· assess the Service level, monitor the traffic and rating of various service options;
· implement marketing activities;
· confirm the accuracy and completeness of the personal data provided by the User.
3.3. The Personal Data authorized for processing under this Privacy Policy are provided by the User by filling out special forms on the Website and include the following information:
· the User’s last name, first name, patronymic;
· the User’s contact phone number;
· e-mail address.
3.4. The Website Administration shall also make efforts to protect Personal Data that are automatically transmitted when browsing through the Website pages:
· IP address;
· information given by cookies;
· browser information (or other program accessing the website);
· access time;
· addresses of visited pages;
· referrer (address of the previous page), etc.
Disabling cookies may result in the inability to access the Website.
The Website collects statistics of the IP addresses of its visitors. This information is used to identify and solve technical problems, to control the correctness of operations.
3.5. Any other personal information not mentioned above is not subject to intentional disclosure, except as provided in paragraphs 5.2 and 5.3 hereof.
4. TERMS AND CONDITIONS OF PERSONAL DATA PROCESSING
4.1. The User’s personal data shall be transmitted by the User to the Website Administration with the User’s consent.
4.2. The transfer of personal data by the User to the Website Administration through the Feedback Form shall be regarded as the User’s consent to the transfer of his personal data.
4.3. The Website Administration processes information about the User, including his personal data, such as: first name, last name, patronymic, e-mail, phone, and any additional information about the User provided by him voluntarily: company, city, position, etc. in order to fulfill obligations to the Website User.
4.4. The personal data are processed in compliance with the following principles:
· legality of the personal data processing objectives and methods and good faith;
· compliance of the personal data processing objectives with the objectives defined in advance and declared during the collection of personal data;
· compliance of the scope and nature of the processed personal data with the personal data processing methods and objectives;
· inadmissibility of combining databases containing personal data created for incompatible purposes.
4.5. The Website Administration shall process the User’s personal data with his consent in order to provide information, advice, feedback, conclude a Contract, execute applications, and provide services offered on the Website.
4.6. The User’s personal data shall be stored on electronic media, and if necessary can be stored on paper, and used strictly for the purpose specified in this Privacy Policy.
4.7. The User’s personal data shall be stored on the Website electronic media for an indefinite period.
4.8. The User’s personal data shall be destroyed if desired by the User himself subject to his request, or at the initiative of the Website Administrator without explaining the reasons by deleting the information posted by the User by the Website Administration.
5. METHODS AND TERMS OF PERSONAL DATA PROCESSING
5.1. The User’s personal data shall be processed for an indefinite period of time, in any legal way, including in personal data systems using automation tools or without such tools.
5.2. The User agrees that the Website Administration may transfer personal data to third parties, in particular, courier services, postal organizations, telecommunication operators, commercial organizations solely for the purposes of fulfilling the User requests left on the Website.
5.3. The User’s personal data may be transferred to the authorized state authorities only on the grounds and in the manner set forth by the applicable law.
6. ENSURING THE PROTECTION OF PERSONAL DATA DURING PROCESSING
6.1. The Website Administration shall take measures necessary and sufficient to ensure the fulfillment of obligations provided for by Federal Law No.
6.2. Resource Group LLC shall determine at its own discretion the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by Federal Law No. 152 dated July 27, 2006 “On Personal Data”, Government Decree No. 1119 dated November 01, 2012 “On Approval of the Requirements for the Protection of Personal Data during Their Processing in the Personal Data Systems”, FSTEC (Federal Service for Technical and Export Control) Order No. 21 dated February 18, 2013 “On Approval of the Scope and Content of Organizational and Technical Measures to Ensure the Personal Data Security during Their Processing in Personal Data Systems”, and other regulatory legal acts, unless otherwise provided by federal laws. Such measures shall include:
· appointment of a person responsible for the arrangement of personal data processing at Resource Group LLC;
· publication of documents by Resource Group LLC defining the company’s policy regarding the personal data processing, local regulatory acts on the personal data processing, and local regulatory acts establishing the procedures to prevent and detect violations of the laws of the Russian Federation, eliminate the consequences of such violations;
· application of legal, organizational and technical measures to ensure the personal data security;
· internal control and (or) audit of compliance of the personal data processing with the Federal Law “On Personal Data” and regulatory legal acts adopted in accordance with it, personal data protection requirements, Operator’s personal data processing policy, Operator’s local regulatory acts;
· determination and assessment of harm that may be caused to personal data owners in case of violation of the Federal Law “On Personal Data”, the ratio of the specified harm to the measures taken by the Operator to ensure the fulfillment of obligations provided for by the Federal Law “On Personal Data”;
· familiarization of the Operator’s employees directly engaged in the personal data processing with the provisions of privacy laws of the Russian Federation, including the personal data protection requirements, documents defining the Operator’s personal data processing policy, local regulatory acts on the personal data processing, and (or) training of these employees.
6.3. Processing the personal data, Resource Group LLC shall adopt the necessary legal, organizational and technical measures or ensure their adoption to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, disclosure, dissemination of personal data, as well as from other illegal actions in relation to personal data.
7. OBLIGATIONS OF THE PARTIES
7.1. The User undertakes to:
· Provide the correct and truthful information about the personal data necessary for the Website use.
· Update or supplement the provided information about the personal data in case of change in this information.
· Take measures to protect the access to their confidential data stored on the Website.
7.2. The Website Administration undertakes to:
· Use the received information solely for the purposes defined in this Privacy Policy.
· Not to disclose the User’s personal data, except for clauses 5.2 and 5.3 hereof.
· Block personal data related to the relevant User upon application or request of the User or his legal representative or the authorized body in charge with the protection of the rights of personal data owners for the period of verification, in case of identification of false personal data or illegal actions.
8. THE RIGHT OF THE PERSONAL DATA OWNER TO ACCESS HIS PERSONAL DATA
8.1. The User may request the Website Administration to clarify his 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, and to take legally provided measures to protect their rights.
8.2. The information is provided to the User who is the personal data owner or his representative by the Website Administration when upon application or request from the personal data owner or his representative. The request shall contain the number of the main identity document of the personal data owner or his representative, information about the issue date of the specified document and the issuing authority, information confirming the participation of the personal data owner in relations with the Operator (contract number, contract execution date, conditional verbal designation and (or) other information), or information otherwise confirming the personal data processing by the Operator, signature of the personal data owner or his representative. The request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the laws of the Russian Federation.
8.3. The Operator may refuse to fulfill a repeated request to the Website User, who is the personal data owner. Such a refusal shall be substantiated. The provision of the proof of substantiated refusal to fulfill a repeated request is the Operator’s responsibility.
8.4. The Website User, who is the personal data owner, has the right to receive information regarding the processing of his personal data, including information containing:
· the confirmation of personal data processing by the Operator;
· legal grounds and purposes of personal data processing;
· personal data processing objectives and methods used by the Operator;
· the Operator’s name and location, information about persons (except for the Operator’s employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the operator or federal law;
· processed personal data related to the relevant personal data owner, their source, unless another submission procedure for such data is provided for by federal law;
· terms of personal data processing, including the terms of their storage;
· the procedure for the exercise of the rights provided for by the Federal Law “On Personal Data” by the personal data owner;
· information about the performed or expected cross-border data transmission;
· name or first name, last name, patronymic and address of a person processing personal data on behalf of the Operator, if the processing has been or will be entrusted to such a person.
8.5. If the Website User, who is the personal data owner, believes that the Website Administration or the Operator processes his personal data in violation of the requirements of the Federal Law “On Personal Data” or otherwise violates his rights and freedoms, the personal data owner has the right to appeal the Operator’s actions or omissions to the body authorized to protect the rights of personal data owner, or in court.
8.6. The Website User, who is the personal data owner, has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court.
9. LIABILITY OF THE PARTIES
9.1. The Website Administration shall be liable for the intentional disclosure of the User’s Personal Data in accordance with applicable law, except as provided for in paragraphs 5.2, 5.3 hereof.
9.2. In case of Personal Data loss or disclosure, the Website Administration shall not be liable if this confidential information:
· Became known to the public before its loss or disclosure.
· Had been received from a third party before it was received by the Website Administration.
· Was obtained by third parties through unauthorized access to the website files.
· Was disclosed with the User’s consent.
9.3. The User shall be liable for the legality, correctness and truthfulness of the Personal Data provided in accordance with the applicable law.
10. DISPUTE RESOLUTION
10.1. Before filing a court action on disputes arising from the relations between the Website User and the Website Administration, it is mandatory to submit a claim (a written proposal for a voluntary dispute settlement).
10.2. The claim recipient shall notify the claimer in writing about the claim consideration results within 30 calendar days from the date of claim receipt.
10.3. If the consensus is not reached, the dispute will be referred to a judicial authority in accordance with the applicable law.
10.4. The current laws of the Russian Federation shall apply to this Privacy Policy and the relations between the User and the Website Administration.