Policy of personal data processing 1. General provisions
This personal data processing policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006. No.152-FZ "On Personal Data" (hereinafter — the "Law on Personal Data") and determines the procedure of personal data processing and measures to ensure security of personal data, taken by EQUIUM LLC (hereinafter — the "Operator").
1.1. Operator sets as its most important goal and condition of its activity the observance of human and citizen's rights and freedoms in the processing of their personal data, including the protection of rights to privacy, personal and family secrets.
1.2. Operator's personal data processing policy (hereinafter — the "Policy") applies to all information that Operator may receive about visitors to the https://equium.global/
website. 2. Basic concepts used in this Policy
2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary suspension of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://equium.global/
2.4. Personal data information system is an aggregate of personal data contained in databases, and information technologies and technical means, ensuring processing of personal data.
2.5. De-identification of personal data — actions, as a result of which it is impossible to determine, without using additional information, the attribution of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data —any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal authority, legal entity or individual, independently, or together with other persons, arranging and (or) carrying out processing of personal data, as well as determining the purpose of personal data processing, 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 particular or defined User of the website https://equium.global/
2.9. Personal data, allowed by the subject of personal data for distribution — personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, allowed by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter — the "Personal data allowed for distribution").
2.10. User — any visitor to https://equium.global/
2.11. Provision of personal data — actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Distribution of personal data — any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarise an unlimited number of persons with personal data, including 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. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign natural person, or foreign legal entity.
2.14. Destruction of personal data — any action, as a result of which personal data is destroyed irretrievably with impossibility to further restore the content of personal data in the information system of personal data and (or) material media of personal data are destroyed. 3. Basic rights and obligations of Operator
3.1. Operator has the right to:
- obtain from the subject of personal data reliable information and/or documents containing personal data;
- in case the personal data subject withdraws their consent to the processing of personal data, Operator has the right to continue the processing of personal data without the consent of the personal data subject on the grounds specified in Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided by Personal Data Law and the regulations adopted in accordance therewith, unless otherwise provided by Personal Data Law or other federal laws. 3.2. Operator is obligated to:
- provide the personal data subject, at his or her request, with information relating to the processing of his or her personal data;
- organise the processing of personal data in the manner prescribed by applicable laws of the Russian Federation;
- respond to requests and enquiries of personal data subjects and their legal representatives in accordance with the requirements of Personal Data Law;
- report to the authority responsible for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receipt of such request;
- publish or otherwise ensure unrestricted access to this Policy on personal data processing;
- take legal, organisational, and technical measures to protect personal data from unauthorised or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful acts in relation to personal data;
- cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by Personal Data Law;
- perform other duties provided by Personal Data Law. 4. Basic rights and obligations of subjects of personal data
4.1. Personal data subjects have the right:
- to receive information relating to the processing of their personal data, except in the cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are set out in Personal Data Law;
- to require Operator to clarify its personal data, to block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and to take statutory measures to protect his rights;
- to condition prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- to withdraw the consent to the processing of personal data;
- to appeal to the authorised body for the protection of the rights of subjects of personal data or in court against unlawful acts or omissions of Operator in the processing of his personal data;
- to exercise other rights provided by the legislation of the Russian Federation;
4.2. Personal data subjects are obligated to:
- provide Operator with accurate data about themselves;
- inform Operator of the clarification (updating, modification) of their personal data;
4.3. Persons who provided Operator with inaccurate information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Russian Federation. 5. Operator may process the following personal data of User
5.1. Last name, first name, middle name.
5.2. Email address.
5.3. Phone numbers.
5.4. The site also collects and processes visitors' anonymized data (including cookies) using Internet statistics services (Yandex Metrics, Google Analytics, etc.).
5.5. The above-mentioned data is hereinafter referred to in this Policy as "Personal Data".
5.6. Operator shall not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data, allowed for dissemination, from among the special categories of personal data specified in Part 1 of Article 10 of Personal Data Law, is allowed, if the prohibitions and conditions stipulated in Article 10.1 of Personal Data Law are observed.
5.8. The User's consent to the processing of personal data authorised for dissemination shall be formalised separately from other consents to the processing of their personal data. The conditions stipulated, in particular, by Article 10.1 of Personal Data Law shall be complied with. The requirements for the content of such consent shall be established by the competent authority for the protection of the rights of personal data subjects.
5.8.1. The consent for the processing of personal data permitted for distribution shall be given by the User directly to Operator.
5.8.2. Operator is obliged, within three working days from the receipt of the above consent of the User, to publish information about the conditions of processing, prohibitions, and conditions for the processing of personal data permitted for distribution to an unlimited number of persons.
5.8.3. The transfer (dissemination, provision, access) of personal data, authorised by the personal data subject for dissemination, must be stopped at any time at the request of the personal data subject. This request must include the surname, first name, patronymic (if any), contact information (telephone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by Operator to whom it is sent.
5.8.4. Consent to the processing of personal data authorised for dissemination shall cease upon receipt by Operator of the request referred to in clause 5.8.3 of this Policy for the processing of personal data.
6. Principles of personal data processing
6.1. Processing of personal data shall be lawful and fair.
6.2. Processing of personal data shall be limited to achieving specific, predetermined, and legitimate objectives. No processing of personal data which is incompatible with the purposes for which the personal data is collected shall be permitted.
6.3. Databases containing personal data that are processed for purposes that are incompatible with each other shall not be merged.
6.4. Only personal data that meets the purposes for which it is being processed shall be processed.
6.5. The content and scope of personal data processed shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.
6.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance in relation to the purpose of personal data processing shall be ensured. Operator shall take necessary measures and/or ensure that incomplete or inaccurate data is removed or clarified.
6.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law, an agreement to which the personal data subject is a party, a beneficiary, or a guarantor. Processed personal data shall be destroyed or depersonalised upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.
7. Purposes of personal data processing
7.1 Purpose of processing User's personal data:
- informing User by sending emails and/or text messages;
- conclusion, performance and termination of civil law contracts;
- giving the User access to services, information and/or materials contained on the website https://equium.global/
7.2. Operator has the right to send to User notifications about new products and services, special offers and different events. User has a right to refuse receiving information messages by sending an email to Operator at firstname.lastname@example.org with the note "Refuse notifications about new products and services and special offers."
7.3. The anonymized User data collected via Internet statistics services is used to collect information about Users' activities on the website, to improve the quality of the website and its content. 8. Legal basis for personal data processing
8.1. The legal basis for the processing of personal data by Operator is covered by:
- Operator's charter documents;
- contracts entered into between Operator and the subject of personal data;
- federal laws, other laws and regulations in the sphere of personal data protection;
- the consent of Users for the processing of their personal data, for the processing of personal data allowed for dissemination.
8.2. Operator processes User's personal data only if it is filled in and/or sent by User himself via special forms located on the website https://equium.global/
or sent to Operator by email. By completing the relevant forms and/or sending his personal data to Operator, User expresses his consent to this Policy.
8.4. The subject of personal data shall independently decide on the provision of their personal data and give consent freely, willingly and in their own interest. 9. Terms of personal data processing
9.1. Processing of personal data shall be subject to the consent of the personal data subject to the processing of their personal data.
9.2. Processing of personal data is necessary for achievement of the objectives envisaged by an international treaty of the Russian Federation or by law, for implementation of the functions, powers, and duties imposed on Operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which is the personal data subject, as well as for conclusion of an agreement on the initiative of the personal data subject or an agreement, under which the personal data subject will be a beneficiary or guarantor.
9.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of Operator or third parties, or for the achievement of socially important objectives, provided that the rights and freedoms of the personal data subject are not thereby violated.
9.6. Processing of personal data, to which access has been granted by or at the request of the data subject (hereinafter — "Publicly available personal data").
9.7. Processing of personal data subject to publication or compulsory disclosure in accordance with federal law. 10. Procedure for collection, storage, transfer, and other processing of personal data
The security of personal data processed by Operator is ensured by implementing legal, organisational, and technical measures necessary to comply fully with the requirements of current legislation in the area of personal data protection.
10.1. The operator ensures the safety of personal data and takes all possible measures which exclude access to personal data by unauthorised persons.
10.2. The personal data of User will never, under no circumstances be transferred to third parties, except in cases related to the execution of the applicable laws or if the personal data subject has given their consent to Operator for the transfer of data to a third party to fulfil their obligations under a civil law contract.
10.3. If inaccuracies in the personal data are identified, User may update the personal data themselves by sending a notification to the Operator's email address email@example.com, marked "Update of personal data."
10.4. The time period for processing personal data is determined by the achievement of the purposes for which the personal data was collected unless a different time period is stipulated by contract or applicable law.
User may withdraw his consent to the processing of personal data at any time by sending Operator a notification via email to the Operator's email address firstname.lastname@example.org with the note "Withdrawal of consent to the processing of personal data."
10.6. The prohibitions established by the personal data subject on the transfer (other than granting access) as well as on the processing or processing conditions (other than gaining access) of personal data permitted for distribution shall not apply in cases of processing of personal data in state, public, and other public interests as defined by Russian legislation.
10.7. Operator shall ensure the confidentiality of personal data when processing personal data.
10.8. Operator shall store personal data in a form that allows the personal data subject to be identified, for no longer than is 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/under which the personal data subject is a party, a beneficiary, or a guarantor.
10.9. A condition for termination of personal data processing may be the achievement of the personal data processing objectives, expiry of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as detection of unlawful processing of personal data. 11. List of actions conducted by Operator with received personal data
11.1. Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalises, blocks, deletes, and destroys personal data.
11.2. Operator shall carry out automated processing of personal data with or without the receipt and/or transmission of received information via information and telecommunications networks.
12. Cross-border transfer of personal data
12.1. Operator is obliged to make sure that the foreign country, on the territory of which the personal data transfer is supposed to be carried out, provides reliable protection of the personal data subjects' rights before the start of the trans-border transfer of personal data.
12.2. The transborder transfer of personal data to foreign countries, which do not comply with the above requirements, may take place only if the personal data subject consents in writing to the transborder transfer of his/her personal data and/or to the performance of the contract, to which the personal data subject is a party.
13. Confidentiality of personal data
Operator and other persons who obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without consent of the personal data subject, unless otherwise provided by the federal law.
14. Final provisions
14.1. User may obtain any clarification on questions of interest regarding the processing of their personal data by contacting the Operator by email at email@example.com.
14.2 This document will reflect any changes to the personal data processing policy of Operator. Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of Policy is freely available on the Internet at https://equium.global/en/policy