Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (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 undertaken by LLC “AGENCY ARM” (hereinafter referred to as the “Operator”).
1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy and personal and family secrets, to be its most important objective and condition 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://armmoscow.ru.
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 the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://armmoscow.ru.
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, without using additional information, the identity of the personal data to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the categories of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://armmoscow.ru.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access by an unlimited number of persons has been provided by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User — any visitor to the website https://armmoscow.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.
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 individual or foreign legal entity.
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 physical media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— in the event that the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions involving personal data;
— terminate the transfer (dissemination, provision, access) of personal data, terminate processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or omissions of the Operator in processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification (update, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data shall not be permitted.
5.3. It shall not be permitted to combine databases containing personal data whose processing is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes shall not be permitted.
5.6. When processing personal data, their accuracy and sufficiency, and, where necessary, their relevance to the purposes of processing personal data, shall be ensured. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing personal data, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or when the need to achieve such purposes is no longer applicable, unless otherwise provided by federal law.
7. Conditions for Processing Personal Data
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a court decision, or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data to which an unlimited number of persons have been granted access by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”) are processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.
8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data
The 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 applicable legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except where such transfer is required by applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address ok@ag-arm.ru with the subject line “Personal Data Update”.
8.4. The period of processing personal data is determined by achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification by email to the Operator’s email address ok@ag-arm.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject should review these documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for granting access) of personal data permitted for dissemination, shall not apply where personal data are processed in the state, public or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing personal data, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Processing of personal data may be terminated upon achievement of the purposes of processing personal data, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to terminate processing, as well as upon detection of unlawful processing of personal data.
8.10. The Operator uses cookies to ensure the proper functioning of the website. By continuing to use the website, the User agrees to the processing of cookies.
9. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the information obtained via information and telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (such notification shall be submitted separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator shall obtain relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data shall not disclose such personal data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarification regarding matters related to the processing of their personal data by contacting the Operator via email at ok@ag-arm.ru.
12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://armmoscow.ru/en/policy.