What is this document about?
This policy of processing personal data (hereinafter - the Policy and Personal Data accordingly) was developed in accordance with the Federal Law "On Personal Data" (hereinafter - the Law) and establishes the principles of personal data processing established in SPETSMASH Trading House LLC and is an approved local act of SPETSMASH Trading House LLC.
Where does the Policy apply?
This Policy is used directly in the economic activity of SPETSMASH LLC, on web-sites owned and/or operated by SPETSMASH LLC, and in other cases when SPETSMASH LLC is going to process Personal Data of third parties.
What terms are used in the Policy?
The terms established by the Federal Law "On Personal Data" as well as other, including commonly used terms that may be applicable to the Policy are used in the Policy
What are the general principles of Personal Data processing?
- Processing of Personal Data is limited to achieving specific, predetermined and legitimate purposes. We do not allow processing of Personal Data that is incompatible with the purposes for which such Personal Data is collected.
- We do not allow aggregation of databases containing Personal Data processed for purposes incompatible with each other.
- We only process Personal Data that are relevant to the purposes for which they are processed.
- The content and scope of the processed Personal Data corresponds to the stated processing purposes. The processed Personal Data is not excessive in relation to the stated purposes of its processing.
- When processing Personal Data, we ensure the accuracy of Personal Data, their adequacy, and, if necessary, relevance in relation to the purposes of personal data processing. We take appropriate measures to delete or clarify incomplete or inaccurate Personal Data.
- We shall store Personal Data in a form that allows us to identify the subject of Personal Data no longer than required by the purposes of Personal Data processing, unless the period of storage of Personal Data is established by federal law, an agreement to which the subject of Personal Data is a party, a beneficiary or a guarantor.
- We destroy or depersonalize Personal Data upon attainment of the processing objectives or when it is no longer necessary to attain those objectives, unless otherwise provided by law.
What are the grounds for processing Personal Data?
We process Personal Data only if:
The existence of the consent of the personal data subject;
And also in cases when processing of Personal Data is necessary for:
- To achieve the purposes provided by an international treaty of the Russian Federation or law, for implementation and execution of functions, powers and duties imposed on LLC TH SPETSMASH by the legislation of the Russian Federation;
- To perform the contract, which party (beneficiary or guarantor on which) is the subject of Personal Data, as well as to conclude the contract on the initiative of the subject of Personal Data or the contract under which the subject of Personal Data will be a beneficiary or guarantor;
- Exercising rights and legitimate interests of SPETSMASH Trading House LLC or third parties provided that in doing so the rights and freedoms of the subject of Personal Data are not violated.
What is the list and purpose of processing of Personal Data?
A specific list of Personal Data, purposes and conditions of their processing are set forth in the consent to the processing of Personal Data, and they cannot contradict this Policy and the Law. Each consent to the processing of Personal Data posted on behalf of SPETSMASH Trading House LLC is an integral part of this Policy.
How is Personal Data processed?
When processing Personal Data we can perform the following actions with Personal Data, both separately and in aggregate, both with the use of automation and without it: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.
SPETSMASH LLC does not process Personal Data solely by automated means, as well as special categories of Personal Data and biometric Personal Data.
Sometimes we may consent to cross-border transfer of Personal Data. Such transfer of Personal Data is carried out exclusively in the countries, providing adequate protection of the rights of subjects of personal data and (or) to the organizations, specified in the relevant consent to processing of Personal Data.
What are the retention periods and destruction requirements for Personal Data?
The retention period of Personal Data depends on the composition of the processed data and is specified in the relevant consent to the processing of Personal Data.
Processed Personal Data shall in any case be destroyed when:
- the achievement of their processing purposes or when they are no longer needed;
- Receipt of a corresponding request from the personal data subject in the manner prescribed by the Law;
- Receipt of a legal request from the competent authority;
- the expiration of the stipulated retention period of the personal data.
What measures are taken when processing and protecting Personal Data?
We appoint employees responsible for the organization of Personal Data processing; We determine, publish and update the Personal Data Processing Policy and, if necessary, issue and implement local acts to ensure safe processing of Personal Data or eliminate the negative consequences of such processing.
If necessary, apply legal, organizational and technical measures to ensure the security of Personal Data, as well as implement other measures aimed at ensuring the processing of Personal Data in accordance with the Law and the Policy.
What rights do the subjects of personal data have?
SPETSMASH Trading House LLC guarantees observance of personal data subjects' rights specified by the Law and Policy. The subject of personal data can receive exhaustive information, concerning processing and safety of his personal data, sending official inquiry to SPETSMASH Trading House LLC according to the Law.