PERSONAL DATA PROCESSING POLICY
- GENERAL PROVISIONS
1.1. This Policy is implemented by Arctic Marine Limited Liability Company (hereinafter referred to as the "Operator") in relation to the processing and protection of personal data of individuals (subjects of personal data) on the basis of Article 24 of the Constitution
of the Russian Federation and Federal Law No. 152-FZ "On Personal Data".
1.2. This Policy applies to all personal data that may be obtained by the Operator in the course of its activities, including the personal data of the Operator's clients. The Operator processes personal data in accordance
with the following regulatory legal acts:
- Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”
- (hereinafter referred to as the Federal Law “On Personal Data”);
- Resolution of the Government of the Russian Federation of September 15, 2008 No. 687
- “On approval of the Regulation on the specifics of personal data processing carried out without the use of automation tools”;
- other regulatory legal acts of the Russian Federation and regulatory documents of executive bodies of state power.
1.3. The purpose of the Policy is to provide individuals providing their personal data with the necessary information to enable them to assess what personal data
and for what purposes are processed by the Operator, what methods are implemented to ensure their security, as well as to establish the basic principles and approaches to the processing and security of personal data by the Operator.
1.4. The Policy ensures the protection of the rights and freedoms of subjects when processing their personal data with or without the use of automation tools, and also establishes the liability of persons with access to personal data for failure to comply with the requirements governing the processing and protection of personal data.
1.5. By using the Operator's services and features, including those located
on the Operator's website
arctic-marine.ru (hereinafter referred to as the Website), and by providing the Operator with their personal data, including through third parties, Users agree
to the processing of their personal data in accordance with this Policy. If
the User disagrees with this Policy in general, or with any provision of this Policy, they must refrain from using the Services.
1.6. The Operator receives and begins processing the Subject's personal data upon receipt of their consent. Consent to the processing of personal data may be given by the Subject of Personal Data in a form that confirms the receipt of consent, unless otherwise provided by federal law:
- in writing and/or
- By the personal data subject performing implicit actions (checking the box under the appropriate personal data entry form)
- when using services on the Operator's website, using feedback forms, and accepting offers containing provisions on the processing of personal data
- in accordance with applicable law. If the personal data subject does not consent to the processing of their personal data, such processing
- will not occur.
1.7. Consent to the processing of personal data may be revoked by the personal data subject. If the personal data subject revokes consent to the processing of personal data, the operator has the right to continue processing the personal data without the consent of the personal data subject, provided there are grounds specified by current legislation.
1.8. This Policy may be amended by the Operator. The Operator reserves the right to amend this Policy at any time, at its sole discretion,
subject to prior notice to the User. When changes are made,
the latest version will indicate the date of the last update. The new version of the Policy takes effect from the moment it is posted on the web server, unless otherwise provided in the new version of the Policy.
1.9. This Policy applies only to information about the User obtained through the use of the Operator's Services. The Operator does not control and is not responsible
for the processing of information about the User by third-party websites to which the User may access links available on the Operator's official web server.
1.10. CONCEPTS USED IN THIS POLICY:
- personal data – any information relating to a directly or indirectly identified or identifiable natural person (subject of personal data)
- personal data operator (operator) – a state body, municipal body, legal entity or individual that, independently or jointly with other persons, organizes and (or) carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data;
- Personal data processing – any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation tools. Personal data processing includes
- , but is not limited to: collection; recording; systematization; accumulation; storage; clarification (updating, modification); retrieval; use; transfer (distribution, provision, access); depersonalization; blocking; deletion; destruction.
- automated processing of personal data – processing of personal data
- using computer technology;
- dissemination of personal data – actions aimed at disclosing personal data to an indefinite number of persons;
- provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;
- destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed;
- personal data information system – a set of personal data contained in databases and the information technologies and technical means that ensure their processing;
- personal data subject—an individual, directly or indirectly identified
- or identifiable on the basis of personal data relating to him/her.
- CONCEPT AND COMPOSITION OF PERSONAL DATA
2.1. For the purposes of this Policy, personal data means any information relating directly or indirectly to a specific individual (subject of personal data).
2.2. Depending on the personal data subject, the Operator may process personal data of the following categories of subjects in order to carry out its activities and fulfill its obligations:
- Client data—information required by the Operator to fulfill its obligations under contractual relations with the Client and to comply with the requirements of the legislation of the Russian Federation. This also includes data provided by potential clients, representatives of clients authorized to represent clients; managers and chief accountants of legal entities that are clients of the Operator, persons who have entered into
- civil law contracts with the Operator for the provision of the Operator's services; employees of the Operator's partners and other legal entities having contractual relations
- with the Operator, with whom the Operator's employees interact as part of their activities;
- the Client’s personal data provided upon registration on the Website, as well as when using the services and communication forms posted on the Website;
- personal data of other individuals who have expressed consent to the processing of their personal data by the Operator or individuals whose processing of personal data is necessary for the Operator to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation
- and fulfillment of the powers and duties imposed by the legislation of the Russian Federation;
- personal data of individuals that they have made publicly available,
- and their processing does not violate their rights and complies with the requirements established by the Law on Personal Data.
2.3. The Operator hereby informs the Subjects of personal data that
within the framework of the personal data provided on the Website, the Operator
may process the following personal data, subject to the consent of the Subject of personal data to the processing of personal data, expressed by checking the appropriate box under the personal data collection form or clicking the appropriate button: first name, last name, telephone number; email address (E-mail).
- GROUNDS AND PURPOSES OF PERSONAL DATA PROCESSING
3.1. The Operator processes personal data to carry out its activities, including providing services to Clients. The Operator has the right to:
- carry out the functions assigned to the Operator by the legislation of the Russian Federation in accordance with the Federal Law "On Personal Data" and other laws
- and regulatory legal acts of the Russian Federation, as well as the Charter and regulatory acts of the Operator;
- The Operator collects and stores the Client's personal data necessary for the provision of services, the execution of agreements and contracts, and the fulfillment of obligations to the Client.
3.2. The operator processes personal data only if at least one
of the following conditions is met:
- the processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
- the processing of personal data is necessary to achieve the goals provided by law, for the implementation and fulfillment of the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation;
- the processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor;
- the processing of personal data is necessary for the exercise of the rights and legitimate interests of the Company or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
- personal data is processed, access
- to which by an unlimited number of persons is provided by the subject of personal data or at his request;
- or mandatory disclosure in accordance with federal law is processed .
3.3. Operators and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of the personal data, unless otherwise provided by federal law.
3.4. The operator may process personal data of personal data subjects
for the following purposes:
- to identify the subject of personal data;
- to communicate with the subject of personal data if necessary, including sending proposals, notifications, information and requests, both related and
- not related to the provision of services, as well as processing the Client’s applications, requests and applications;
- improving the quality of services provided by the Operator.
3.5. The Operator does not process special categories of Personal Data related to race , nationality , political views, religious or philosophical beliefs, or intimate life.
- PERSONAL DATA PROCESSING PERIODS
4.1. The terms for processing personal data are determined based on the purposes of processing
in the Operator's information systems, in accordance with the term of the contract or agreement with the personal data subject.
4.2. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing in accordance with the terms of
the agreement concluded between the Operator and the personal data subject, the expiration of the consent or the revocation of the consent of the personal data subject to the processing of his or her personal data, as well as the detection of unlawful processing of personal data.
- CIRCLE OF PERSONS AUTHORIZED TO PROCESS PERSONAL DATA
5.1. To achieve the objectives of Article 3 of this Policy, only those employees of the Operator assigned to do so
in accordance with their job responsibilities are permitted to process personal data. Access to other employees may only be granted in cases stipulated by law. The Operator requires its employees to maintain the confidentiality and ensure the security of personal data when processing it.
5.2. The operator has the right to transfer personal data to third parties in the following cases:
- The subject of personal data has clearly expressed his consent to such actions;
- The transfer is provided for by Russian or other applicable legislation
- within the framework of the procedure established by law.
In this case, the acquirer assumes all obligations to comply with the terms of this Policy in relation to the data received by him.
5.3. At the motivated request of the authorized body and in accordance with current legislation, the personal data of the subject may be transferred without his consent:
- in connection with the administration of justice in judicial bodies;
- to the police, the Federal Security Service, the prosecutor's office, and the Investigative Committee;
- to other bodies authorized by current legislation and applicable legal norms and the Operator in cases established in regulatory legal acts that are mandatory for the operator to execute.
- PROCEDURE AND METHODS OF PROCESSING PERSONAL DATA
6.1. In the process of providing services and carrying out internal business activities, the Operator uses automated and non-automated processing of personal data.
6.2. The Operator has the right to entrust the Processing of Personal Data to another person with the consent of the Personal Data Subject, unless otherwise provided by the legislation of the Russian Federation, on the basis of an agreement concluded with this person, a mandatory condition of which is the compliance by this person with the principles and rules for the Processing of Personal Data provided for by the Federal Law "On Personal Data".
6.3. Personal data shall not be disclosed to third parties or otherwise distributed without the consent of the Personal Data Subject, unless otherwise provided by the legislation of the Russian Federation.
6.4. Representatives of government authorities (including regulatory, supervisory, law enforcement and other bodies) have access to Personal Data processed by the Operator in the amount and manner established by the legislation of the Russian Federation.
6.5. Within the framework of personal data processing, the following rights are defined for the Personal Data Subject and the Operator.
6.5.1. The personal data subject has the right to:
- receive information regarding the processing of his personal data in the manner, form and timeframes established by the Legislation on Personal Data;
- demand clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, is not necessary for the stated purpose of processing or is used for purposes not previously stated when the Subject of personal data provided consent to the processing of personal data;
- take measures provided by law to protect their rights;
- withdraw your consent to the processing of personal data.
6.5.2. The operator has the right:
- process the personal data of the Personal Data Subject in accordance
- with the stated purpose;
- require the personal data subject to provide reliable personal data necessary for the performance of the agreement, provision of the service, identification of the personal data subject, as well as in other cases stipulated by the legislation on personal data; restrict the access of the personal data subject to his personal data in the event that the processing of personal data is carried out in accordance with the legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism, the access of the personal data subject to his personal data violates the rights
- and legitimate interests of third parties, as well as in other cases stipulated by the legislation of the Russian Federation;
- process publicly available personal data of individuals;
- process personal data subject to publication or mandatory disclosure in accordance with the legislation of the Russian Federation;
- entrust the processing of personal data to another person with the consent of the Personal Data Subject.
6.6. In the event that the fact of inaccuracy of personal data or illegality of its processing is confirmed, the personal data is subject to updating by the operator, and processing must be terminated.
6.7. Upon achieving the purposes of personal data processing, as well as in the event of the personal data subject's withdrawal of consent to their processing, personal data are subject to destruction if:
- unless otherwise provided by an agreement
- to which the subject of personal data is a party, beneficiary or guarantor;
- The operator does not have the right to process personal data without the consent of the subject on the grounds provided for by the Federal Law "On Personal Data"
- or other federal laws;
- unless otherwise provided by another agreement between the Operator and the personal data subject.
6.8. The operator is obliged to inform the subject of personal data or his representative of information about the processing of personal data of such subject carried out by him upon the latter’s request.
6.9. The operator also has other rights and bears other obligations established by the Federal Law “On Personal Data”.
7. Any suggestions or questions regarding this Privacy Policy should be sent to
info@arctic-marine.ru