Policy on the Processing of Personal Data — ГПК «Дерфер» ...

Policy on the Processing of Personal Data

1. General Provisions This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006 (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by GPC Doerfer (hereinafter referred to as the “Operator”).

1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of privacy, personal, and family secrets, as one of its most important objectives and conditions for carrying out its activities.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the website https://gpcdoerfer.com/.

2. Key Terms Used in the Policy 2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of personal data processing (except in cases where processing is necessary for the clarification of personal data).

2.3. Website – a set of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://gpcdoerfer.com/.

2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data – actions resulting in the impossibility of determining the identity of personal data without additional information.

2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.

2.7. Operator – a state body, municipal body, legal or natural person that independently or jointly with others organizes and/or performs the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.

2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://gpcdoerfer.com/.

2.9. Personal data permitted by the data subject for distribution – personal data to which the data subject has granted access to an unlimited number of persons by giving consent in the manner prescribed by the Personal Data Law (hereinafter referred to as “personal data permitted for distribution”).

2.10. User – any visitor to the website https://gpcdoerfer.com/.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarization with personal data by an unlimited number of persons, including publication in mass media, placement in information and telecommunication 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 government authority, a foreign natural or legal person.

2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or the destruction of tangible personal data carriers.

3. Basic Rights and Obligations of the Operator 3.1. The Operator has the right to: — obtain accurate information and/or documents containing personal data from the data subject; — continue processing personal data without the consent of the data subject if there are legal grounds specified in the Personal Data Law; — independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it.

3.2. The Operator is obliged to: — provide the data subject, upon request, with information regarding the processing of their personal data; — organize the processing of personal data in accordance with the current legislation of the Russian Federation; — respond to inquiries and requests from data subjects and their legal representatives; — notify the authorized body for the protection of the rights of data subjects upon request within 10 days from the date of receipt of such a request; — publish or otherwise provide unrestricted access to this Policy on the processing of personal data; — take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as other unlawful actions; — stop the transmission (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the Personal Data Law; — fulfill other obligations stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Data Subjects 4.1. Data subjects have the right to: — receive information regarding the processing of their personal data, except in cases provided by federal law; — demand the correction, blocking, or destruction of their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose; — set conditions for prior consent when processing personal data for marketing purposes; — withdraw consent to the processing of personal data and request the termination of processing; — appeal to the authorized body for the protection of the rights of data subjects or to a court regarding unlawful actions or inaction of the Operator in processing their personal data; — exercise other rights provided by Russian law.

4.2. Data subjects are obliged to: — provide the Operator with accurate data about themselves; — inform the Operator about the updating (modification) of their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another data subject without their consent bear responsibility in accordance with Russian law.

5. Principles of Personal Data Processing 5.1. Personal data processing is carried out on a lawful and fair basis.

5.2. Processing is limited to specific, pre-defined, and legitimate purposes. Processing incompatible with the purposes of personal data collection is not allowed.

5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.

5.4. Only personal data that meets the purposes of processing is subject to processing.

5.5. The content and scope of processed personal data must correspond to the stated processing purposes. Excessive processing of personal data is not allowed.

5.6. The accuracy, sufficiency, and relevance of personal data must be ensured for processing purposes.

5.7. Personal data is stored in a form that allows the identification of the data subject no longer than required for processing purposes unless a longer period is required by law.