1. General provisions
This personal data processing policy has been drawn up in accordance with
with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On personal
data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing
personal data and measures to ensure the security of personal
data undertaken by Andrey Konstantinovich Pystin (hereinafter referred to as
Operator).
1.1. The operator sets as its most important goal and condition for the implementation of its
activities observance of the rights and freedoms of man and citizen in the processing
his personal data, including the protection of the rights to inviolability
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 get information about website visitors https://hqdbaltic.com/.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data - processing
personal data using computer technology.
2.2. Blocking of personal data - suspension of processing
personal data (unless the processing is necessary for
clarification of personal data).
2.3. Website - a set of graphic and informational materials, and
as well as computer programs and databases that ensure their availability on the network
Internet at the network address https://hqdbaltic.com/.
2.4. Information system of personal data - set
contained in databases of personal data, and providing them
processing of information technologies and technical means.
2.5. Depersonalization of personal data - actions, as a result of which
cannot be determined without additional information
belonging of personal data to a specific User or other
the subject of personal data.
2.6. Processing of personal data - any action (operation) or
a set of actions (operations) performed using funds
automation or without the use of such means with personal data,
including collection, recording, systematization, accumulation, storage, clarification
(update, change), extract, use, transfer
(distribution, provision, access), depersonalization, blocking,
deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or
natural person, alone or jointly with other persons
organizing and (or) carrying out the processing of 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 - any information relating directly or
indirectly to a specific or identifiable Web User
website https://hqdbaltic.com/.
2.9. Personal data authorized by the subject of personal data for
distribution, - personal data, access of an unlimited number of persons to
which is provided by the subject of personal data by giving consent to
processing of personal data authorized by the subject of personal data
for distribution in the manner prescribed by the Law on Personal
data (hereinafter referred to as personal data permitted for distribution).
2.10. User - any visitor of the website https://hqdbaltic.com/.
2.11. Provision of personal data - actions aimed at
disclosure of personal data to a certain person or a certain circle
persons.
2.12. Dissemination of personal data - any action aimed at
to the disclosure of personal data to an indefinite circle of persons (transfer
personal data) or to get acquainted with personal data
an unlimited number of persons, including the disclosure of personal data in
mass media, placement in information and
telecommunications networks or providing access to personal
given in some other way.
2.13. Cross-border transfer of personal data - transfer of personal
data to the territory of a foreign state to the authority of a foreign
state, foreign individual or foreign legal entity.
2.14. Destruction of personal data - any action that results in
personal data is destroyed irrevocably with the impossibility
further restoration of the content of personal data in
personal data information system and (or) destroyed
material carriers of personal data.
3. Basic rights and obligations of the Operator
3.1. The operator has the right:
– receive reliable information from the subject of personal data and/or
documents containing personal data;
– in case of withdrawal by the subject of personal data of consent to processing
personal data The operator has the right to continue processing personal
data without the consent of the 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 under
Law on Personal Data and adopted in accordance with it
normative legal acts, unless otherwise provided by the Law on
personal data or other federal laws.
3.2. The operator is obliged:
– provide the subject of personal data at his request with information,
concerning the processing of his personal data;
– organize the processing of personal data in the manner prescribed by
the current legislation of the Russian Federation;
– respond to requests and requests from personal data subjects and their
legal representatives in accordance with the requirements of the Law on Personal
data;
– notify the authorized body for the protection of the rights of subjects of personal
data at the request of this authority the necessary information within 30 days from
the date of receipt of such request;
publish or otherwise provide unrestricted access to
this Policy regarding the processing of personal data;
– take legal, organizational and technical measures to protect
personal data from unauthorized or accidental access to them,
destruction, modification, blocking, copying, provision,
dissemination of personal data, as well as from other illegal
actions in relation to personal data;
– stop the transfer (distribution, provision, access) of personal
data, stop processing and destroy personal data in the manner and
cases provided for by the Law on Personal Data;
– perform other duties stipulated by the Law on Personal
data.
4. Basic rights and obligations of subjects of personal
data
4.1. Subjects of personal data have the right to:
– receive information regarding the processing of his personal data, for
except as otherwise provided by federal law. Intelligence
provided to the subject of personal data by the Operator in an accessible
form, and they should not contain personal data relating to
other subjects of personal data, unless there are
legitimate grounds for disclosing such personal data. Scroll
information and the procedure for obtaining it is established by the Law on Personal
data;
– require the operator to clarify his personal data, block them
or destruction if the personal data is incomplete,
outdated, inaccurate, illegally obtained or not
necessary for the stated purpose of processing, as well as to take
legal measures to protect their rights;
– put forward the condition of prior consent when processing personal
data in order to promote goods, works and services on the market;
– to withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of subjects of personal
data or legally wrongful acts or omissions
the Operator when processing his 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 yourself;
– inform the Operator about the clarification (updating, changing) of their
personal data.
4.3. Persons who provided the Operator with false information about themselves, or information
about another subject of personal data without the consent of the latter, are
responsibility in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal
user data
5.1. Full Name.
5.2. Email address.
5.3. Phone numbers.
5.4. The site also collects and processes anonymous data about
visitors (including cookies) using Internet statistics services
(Yandex Metrika and Google Analytics and others).
5.5. The above data further in the text of the Policy are united by a common
concept of personal data.
5.6. Processing of special categories of personal data relating to
race, nationality, political opinions, religious or
philosophical beliefs, intimate life, the Operator is not carried out.
5.7. Processing of personal data authorized for dissemination, from
the number of special categories of personal data specified in Part 1 of Art. ten
of the Law on Personal Data, is allowed if the prohibitions and
conditions under Art. 10.1 of the Personal Data Law.
5.8. Consent of the User to the processing of personal data permitted
for distribution, is issued separately from other consents to the processing of it
personal data. In doing so, the conditions stipulated in
in particular, art. 10.1 of the Personal Data Law. Content Requirements
of such consent are established by the authorized body for the protection of rights
subjects of personal data.
5.8.1 Consent to the processing of personal data authorized for
distribution, the User provides the Operator directly.
5.8.2 The operator is obliged, no later than three working days from the date of receipt
the specified consent of the User to publish information about the conditions
processing, about the presence of prohibitions and conditions for processing in an unlimited circle
persons of personal data permitted for distribution.
5.8.3 Transfer (distribution, provision, access) of personal
data authorized by the subject of personal data for dissemination,
must be terminated at any time at the request of the subject of personal
data. This requirement must include the last name, first name, patronymic (if
available), contact information (phone number, email address
or postal address) of the subject of personal data, as well as a list
personal data, the processing of which is subject to termination. Specified in
According to this requirement, personal data can only be processed
The operator to whom it is directed.
5.8.4 Consent to the processing of personal data authorized for
distribution, ceases to be valid from the moment the Operator receives
the requirement specified in clause 5.8.3 of this Policy regarding the processing
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 achieving specific,
predetermined and legitimate purposes. Processing not allowed
personal data that is incompatible with the purposes of collecting personal data.
6.3. It is not allowed to combine databases containing personal data,
the processing of which is carried out for purposes that are incompatible with each other.
6.4. Only personal data that meet the purposes are subject to processing
their processing.
6.5. The content and scope of the processed personal data correspond to
stated purposes of processing. Redundancy of processed
personal data in relation to the stated purposes of their processing.
6.6. When processing personal data, the accuracy of personal
data, their sufficiency, and, if necessary, their relevance in relation to
to the purposes of processing personal data. The operator accepts the necessary
measures and / or ensures their adoption to remove or clarify incomplete or
inaccurate data.
6.7. The storage of personal data is carried out in a form that allows
determine the subject of personal data, no longer than the purposes require
processing of personal data, if the period of storage of personal data is not
established by federal law, an agreement to which, a party,
the beneficiary or guarantor for which the subject is
personal data. The processed personal data is destroyed
or depersonalized upon achievement of the purposes of processing or in case of loss
the need to achieve these goals, unless otherwise provided
federal law.
7. Purposes of personal data processing
7.1. The purpose of processing the User's personal data:
– informing the User by sending e-mails.
7.2. The Operator also has the right to send notifications to the User about new
products and services, special offers and various events.
The user can always refuse to receive information
messages by sending an email to the Operator
e-mail info@hqdbaltic.com marked "Refusal of notifications about new
products and services and special offers.
7.3. Non-personal data of Users collected using the services
Internet statistics are used to collect information about the actions of Users
on the site, improving the quality of the site and its content.
8. Legal grounds for the processing of personal data
8.1. Legal grounds for the processing of personal data by the Operator
are:
– statutory (constituent) documents of the Operator;
– federal laws, other regulatory legal acts in the field of protection
personal data;
– consent of Users to the processing of their personal data, to the processing
personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if
their completion and / or sending by the User independently through special
forms located on the website https://hqdbaltic.com/ or sent to
Operator via email. Filling out the relevant forms
and / or by sending their personal data to the Operator, the User expresses
your agreement to this Policy.
8.3. The Operator processes anonymized data about the User in the event that
if it is allowed in the User's browser settings (enabled saving
cookies and the use of JavaScript technology).
8.4. The subject of personal data independently decides on
providing his personal data and gives consent freely, of his own free will
and in your interest.
9. Conditions for the processing of personal data
9.1. The processing of personal data is carried out with the consent of the subject
personal data for the processing of his personal data.
9.2. The processing of personal data is necessary to achieve the goals,
provided for by an international treaty of the Russian Federation or
law, for the implementation of the legislation of the Russian Federation
Federation on the operator's functions, powers and responsibilities.
9.3. The processing of personal data is necessary for the implementation
justice, execution of a judicial act, act of another body or official
persons subject to execution in accordance with the legislation of the Russian
Federation of Enforcement Proceedings.
9.4. The processing of personal data is necessary for the performance of the contract,
the party of which or the beneficiary or guarantor for which
is the subject of personal data, as well as to conclude an agreement on
initiative of the subject of personal data or an agreement under which the subject
personal data will be the beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of rights and
legitimate interests of the operator or third parties, or to achieve
publicly significant purposes, provided that this does not violate the rights and
freedom of the subject of personal data.
9.6. The processing of personal data is carried out, access to unlimited
the circle of persons to whom it is provided by the subject of personal data or by his
request (hereinafter referred to as publicly available personal data).
9.7. The processing of personal data subject to
publication or mandatory disclosure under federal
by law.
10. Procedure for collection, storage, transfer and other types of processing
personal data
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 the current
legislation in the field of personal data protection.
10.1. The operator ensures the safety of personal data and accepts all
possible measures to exclude access to personal data
unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be
will be transferred to third parties, except in cases related to
compliance with the current legislation or in the event that the subject
personal data, consent was given to the Operator to transfer data to a third
person to fulfill obligations under a civil law contract.
10.3. In case of detection of inaccuracies in personal data, the User
can update them independently by sending to the Operator
notification to the Operator's email address info@hqdbaltic.com with
marked "Updating personal data".
10.4. The term for processing personal data is determined by the achievement of the goals,
for which personal data was collected, unless a different period
stipulated by the contract or applicable law.
The user can revoke his consent to processing at any time
personal data by sending a notification to the Operator via
email to the Operator's email address info@hqdbaltic.com with
marked "Withdrawal of consent to the processing of personal data".
10.5. All information collected by third party services, including
payment systems, means of communication and other service providers,
stored and processed by the specified persons (Operators) in accordance with
their User Agreement and Privacy Policy. Subject
personal data and / or the User is obliged to independently in a timely manner
review the said documents. The operator is not responsible for
actions of third parties, including the suppliers specified in this clause
services.
10.6. Prohibitions on transfer established by the subject of personal data
(other than granting access), as well as the processing or processing conditions
(other than obtaining access) personal data authorized for
distribution, do not apply in cases of processing of personal data in
state, public and other public interests determined
the legislation of the Russian Federation.
10.7. When processing personal data, the operator ensures
confidentiality of personal data.
10.8. The operator stores personal data in the form,
allowing to determine the subject of personal data, no longer than this
require the purpose of processing personal data, if the period of storage of personal
data is not established by federal law, an agreement, a party to which,
the beneficiary or guarantor for which the subject is
personal data.
10.9. The condition for terminating the processing of personal data may be
achievement of the purposes of personal data processing, expiration
consent of the subject of personal data or withdrawal of consent by the subject
personal data, as well as the detection of unlawful processing
personal data.
11. List of actions performed by the Operator with
received personal data
11.1. The operator collects, records, systematizes, accumulates,
storage, refinement (update, change), retrieval, use,
transfer (distribution, provision, access), depersonalization,
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 the received information via
information and telecommunication networks or without it.
12. Cross-border transfer of personal data
12.1. The operator prior to the start of the cross-border transfer of personal
data is obliged to make sure that a foreign state, on the territory
which it is intended to transfer personal data,
reliable protection of the rights of personal data subjects is ensured.
12.2. Cross-border transfer of personal data in the territory of foreign
states that do not meet the above requirements, may be carried out
only if there is consent in writing from the subject of personal
data on the cross-border transfer of his personal data and / or execution
contract to which the subject of personal data is a party.
13. Privacy 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 distribute personal data without
consent of the subject of personal data, unless otherwise provided
federal law.
14. Final provisions
14.1. The user can get any clarifications on
questions regarding the processing of his personal data, by contacting
Operator via e-mail info@hqdbaltic.com.
14.2. This document will reflect any changes to the processing policy
personal data by the Operator. The policy is valid indefinitely until it is replaced
new version.
14.3. The current version of the Policy is freely available online
Internet at https://hqdbaltic.com/en-terms.