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Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by IP Reent Kirill Mikhailovich (hereinafter referred to as the Operator). 1.1. The Operator considers its most important goal and condition for carrying out its activities to respect the rights and freedoms of a person and citizen when processing their personal data, including the protection of rights to privacy, personal and family secrets. 1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://evidencespray.com/contact.
2. Basic Concepts 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 termination of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://evidencespray.com/contact.
2.4. Personal data information system — a combination of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine the ownership of personal data to a specific User or other subject of personal data without the use of additional information.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual who independently or jointly with other persons organizes and/or processes personal data, as well as defines the purposes of processing personal data, the 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 specific or identifiable User of the website https://evidencespray.com/contact.
2.9. Personal data authorized by the subject of personal data for distribution — personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner provided for by the Law on Personal Data (hereinafter — personal data authorized for distribution).
2.10. User — any visitor to the website https://evidencespray.com/contact.
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 actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with personal data of an unlimited circle of persons, including disclosure of personal data in the 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 an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
2.2. Blocking of personal data — temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://evidencespray.com/contact.
2.4. Personal data information system — a combination of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine the ownership of personal data to a specific User or other subject of personal data without the use of additional information.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual who independently or jointly with other persons organizes and/or processes personal data, as well as defines the purposes of processing personal data, the 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 specific or identifiable User of the website https://evidencespray.com/contact.
2.9. Personal data authorized by the subject of personal data for distribution — personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner provided for by the Law on Personal Data (hereinafter — personal data authorized for distribution).
2.10. User — any visitor to the website https://evidencespray.com/contact.
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 actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with personal data of an unlimited circle of persons, including disclosure of personal data in the 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 an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Basic 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 subject of personal data;— in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request with a demand to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:— provide the subject of personal data, at their request, with information regarding the processing of their personal data;— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;— report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 10 days from the date of receipt of such a request;— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;— terminate the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;— fulfill other obligations stipulated by the Law on Personal Data.
3.2. The Operator is obliged to:— provide the subject of personal data, at their request, with information regarding the processing of their personal data;— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;— report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 10 days from the date of receipt of such a request;— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;— terminate the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;— fulfill other obligations stipulated by the Law on Personal Data.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Subjects of personal data have the right to:— receive information regarding the processing of their personal data, with the exception of cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;— require the operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;— put forward a condition of preliminary consent when processing personal data for the purpose of promoting goods, works and services on the market;— to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;— appeal to the authorized body for the protection of the rights of subjects of personal data or in court the illegal actions or inaction of the Operator when processing their personal data;— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:— provide the Operator with reliable data about themselves;— inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:— provide the Operator with reliable data about themselves;— inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Processing Personal Data
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, is ensured. The operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of processing personal data require, if the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
5.2. Processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, is ensured. The operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of processing personal data require, if the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Processing Personal Data
Purpose of processing:
Informing the User by sending emails.
Personal data:
Last name, first name, patronymic, email address.
Legal grounds:
Statutory (constituent) documents of the Operator, agreements concluded between the operator and the subject of personal data. Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 N 149-FZ
Types of personal data processing:
Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data.
Sending information emails to the email address.
Informing the User by sending emails.
Personal data:
Last name, first name, patronymic, email address.
Legal grounds:
Statutory (constituent) documents of the Operator, agreements concluded between the operator and the subject of personal data. Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 N 149-FZ
Types of personal data processing:
Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data.
Sending information emails to the email address.
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or a law, to fulfill the 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, execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or a 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.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. Processing of personal data is carried out, access to which is provided to an unlimited circle of persons by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data is carried out that are subject to publication or mandatory disclosure in accordance with federal law.
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or a law, to fulfill the 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, execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or a 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.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. Processing of personal data is carried out, access to which is provided to an unlimited circle of persons by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data is carried out that are subject to publication or mandatory disclosure in accordance with federal law.
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 for the full implementation of the requirements of the current legislation in the field of personal data protection. 8.1. The Operator ensures the safety of personal data and takes all possible measures that exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given the Operator consent to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of detecting inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the email address of the Operator hello@evidencespray.com with the note "Updating personal data".
8.4. The period of processing personal data is determined by achieving the purposes for which the personal data were collected, unless another period is provided for by the agreement or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address hello@evidencespray.com with the note "Withdrawal of consent to the processing of personal data".
8.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for the provision of access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data. 8.8. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than the purposes of processing personal data require, if the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the identification of illegal processing of personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given the Operator consent to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of detecting inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the email address of the Operator hello@evidencespray.com with the note "Updating personal data".
8.4. The period of processing personal data is determined by achieving the purposes for which the personal data were collected, unless another period is provided for by the agreement or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address hello@evidencespray.com with the note "Withdrawal of consent to the processing of personal data".
8.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for the provision of access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data. 8.8. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than the purposes of processing personal data require, if the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the identification of illegal processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the information received via information and telecommunications networks or without it.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the information received via information and telecommunications networks or without it.
10. Cross-border Transfer of Personal Data
10.1. The Operator, prior to the commencement of activities for the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out a cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. The Operator, before submitting the above notification, is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom cross-border transfer of personal data is planned.
10.2. The Operator, before submitting the above notification, is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarification on issues of interest regarding the processing of their personal data by contacting the Operator via email hello@evidencespray.com.
12.2. This document will reflect any changes to the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://evidencespray.com/privacy.
12.2. This document will reflect any changes to the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://evidencespray.com/privacy.
