Personal Data Processing Policy
For unrestricted access; information published in accordance with Part 2 of Article 18.1 of the Federal Law of July 27, 2006, N 152-FZ "On Personal Data"This Personal Data Processing Policy applies to all information that the website brand-resource.com, located at the domain name https://brand-resource.com, may receive about the User during the use of the website.
The User's use of the website implies consent to this Personal Data Processing Policy and the conditions for processing the User's personal data. In case of disagreement with the terms of the Personal Data Processing Policy, the User must cease using the website.
This Policy applies only to the website https://brand-resource.com/. The Company does not control and is not responsible for third-party websites that the User may access via links available on the website.
The Company does not verify the accuracy of personal data provided by the User of the website.
1. General ProvisionsThis personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter - the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by IE "Ivanchenko A. P." (hereinafter - the Company).
1.1. The Company considers as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.
1.2. The Policy applies to all personal data of subjects processed by the Company with or without the use of automation tools and applies to all information that the Company may receive about visitors to the website https://brand-resource.com/.
2. Basic Concepts Used in the Policy2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - temporary cessation of personal data processing (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://brand-resource.com/.
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 resulting in the impossibility of determining, without the use of additional information, the ownership 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 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. Company - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining 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://brand-resource.com/.
2.9. Personal data permitted by the subject of personal data for distribution - personal data, access to which by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data permitted for distribution).
2.10. User - any visitor to the website https://brand-resource.com/.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing with personal data of an unlimited circle of persons, including the disclosure of personal data in the mass media, placement 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the permanent destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and (or) destruction of the material carriers of personal data.
3. Principles and Conditions of Personal Data Processing3.1. Processing of personal data in the Company is carried out on the basis of the following principles:
- legality and fair basis;
- limiting the processing of personal data to the achievement of specific, predetermined, and legitimate purposes;
- preventing the processing of personal data incompatible with the purposes of collecting personal data;
- preventing the merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
- processing only those personal data that meet the purposes of their processing;
- correspondence of the content and volume of processed personal data to the stated purposes of processing;
- preventing the processing of excessive personal data in relation to the stated purposes of their processing;
- ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing personal data;
- destruction or depersonalization of personal data upon achievement of processing goals or in case of loss of need to achieve these goals, if it is impossible for the Company to eliminate violations of personal data, unless otherwise provided by federal law.
3.2. The Company processes personal data only under at least one of the following conditions:
- processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
- processing of personal data is necessary to achieve the purposes provided for by law, for the implementation and performance of the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator;
- processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or 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;
- 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;
- processing is carried out of personal data, access to which has been provided by an unlimited circle of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data);
- processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
3.3. The Company has the right to transfer the personal data of the subject to third parties, provided that there is a valid Confidentiality Agreement between the Company and the third party.
3.4. For information support in the Company, publicly available sources of personal data of employees may be created, including directories and address books. With the consent of an employee, publicly available sources of personal data may include his surname, name, patronymic, date and place of birth, position, contact phone numbers, email address. Information about an employee should be excluded from publicly available sources of personal data at any time at the request of the employee or by a court decision or other authorized state bodies.
3.5. The Company has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law. A person processing personal data on behalf of the Company is obliged to comply with the principles and rules for the processing of personal data provided for by FZ-152.
3.6. The Company's processing of special categories of personal data relating to racial, national affiliation, political views, religious or philosophical beliefs, health status, intimate life is allowed in cases if:
- the subject of personal data has given written consent to the processing of his personal data;
- personal data has been made publicly available by the subject of personal data;
- processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on pensions for state pension provision, on labor pensions;
- processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;
- processing of personal data is carried out in accordance with the legislation of the Russian Federation on countering terrorism, countering corruption, on enforcement proceedings, the criminal enforcement legislation of the Russian Federation;
- processing of personal data is carried out in accordance with the legislation on mandatory types of insurance, with insurance legislation.
The processing of special categories of personal data must be immediately terminated if the reasons due to which it was carried out have been eliminated, unless otherwise established by federal law.
3.7. Processing of personal data on criminal records may be carried out by the Company exclusively in cases and in the manner determined in accordance with federal laws.
3.8. Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity - biometric personal data - can be processed by the Company only with the written consent of the employee.
3.9. Cross-border transfer of personal data to the territories of foreign states can be carried out by the Company only with the consent of the subject of personal data for the cross-border transfer of his personal data. Before starting the cross-border transfer of personal data, the Company is obliged to make sure that the foreign state to whose territory the personal data is transferred provides adequate protection of the rights of subjects of personal data.
4. Basic Rights and Obligations of the Company4.1. The Company has the right:
- to receive reliable information and/or documents containing personal data from the subject of personal data;
- in case of revocation of consent to the processing of personal data by the subject of personal data, the Company 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;
- to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
4.2. The Company is obliged:
- to provide the subject of personal data, at his request, with information regarding the processing of his personal data;
- to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- to 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;
- to 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 30 days from the date of receipt of such a request;
- to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
- to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
- to cease the transfer (distribution, provision, access) of personal data, to terminate processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
- to fulfill other obligations provided for by the Law on Personal Data.
5. Basic Rights and Obligations of Personal Data Subjects5.1. Subjects of personal data have the right:
- to receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Company in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
- to require the Company to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
- to 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;
- to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Company in processing their personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
5.2. Subjects of personal data are obliged:
- to provide the Company with reliable data about themselves;
- to inform the Company about the clarification (updating, modification) of their personal data.
5.3. Persons who have provided the Company with unreliable 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.
6. The Company May Process the Following Personal Data of the User6.1. Last name, first name, patronymic;
6.2. Phone number;
6.3. Email address;
6.4. Also, the website collects and processes anonymized data about visitors (including "cookie" files) using Internet statistics services (Yandex Metrica and Google Analytics and others).
6.5. The above data are hereinafter collectively referred to as Personal Data in the text of the Policy.
6.6. The Company does not process special categories of personal data relating to racial, national affiliation, political views, religious or philosophical beliefs, intimate life.
6.7. Processing of personal data permitted for distribution, from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data, is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Law on Personal Data are observed.
6.8. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of his personal data. At the same time, the conditions provided for, in particular, by Art. 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
6.8.1. The User provides the Company directly with consent to the processing of personal data permitted for distribution.
6.8.2. The Company is obliged, within no later than three working days from the moment of receiving the specified consent of the User, to publish information about the conditions of processing, about the existence of prohibitions and conditions for the processing by an unlimited circle of persons of personal data permitted for distribution.
6.8.3. The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement must include the surname, name, patronymic (if any), contact information (telephone number, email address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is to be terminated. The personal data specified in this requirement may be processed only by the Company to which it is directed.
6.8.4. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Company receives the requirement specified in clause 5.8.3 of this Policy regarding the processing of personal data.
7. Principles of Personal Data Processing7.1. Processing of personal data is carried out on a legal and fair basis.
7.2. Processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
7.3. Merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
7.4. Only personal data that meets the purposes of its processing is subject to processing.
7.5. 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.
7.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. The Company takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
7.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of need to achieve these goals, unless otherwise provided by federal law.
8. Purposes of Personal Data Processing8.1. The purpose of processing the User's personal data:
- informing the User by sending emails;
- conclusion, execution, and termination of civil law contracts;
- providing the User with access to services, information and/or materials contained on the website https://brand-resource.com/;
- clarification of order details.
8.2. The Company also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive information messages by sending the Company a letter to the email address privacy@brand-resource.com with the note "Refusal of notifications about new products and services and special offers".
8.3. Anonymized User data collected using Internet statistics services is used to collect information about User actions on the website, improve the quality of the website and its content.
9. Legal Grounds for Processing Personal Data9.1. The legal grounds for the Company's processing of personal data are:
- the Company's constituent documents;
- contracts concluded between the Company and the subject of personal data;
- federal laws, other regulatory legal acts in the field of personal data protection;
- User consents to the processing of their personal data, to the processing of personal data permitted for distribution.
9.2. The Company processes the User's personal data only if they are filled out and/or sent by the User independently through special forms located on the website https://brand-resource.com/ or sent to the Company via email. By filling out the corresponding forms and/or sending their personal data to the Company, the User expresses their consent to this Policy.
9.3. The Company processes anonymized data about the User if this is allowed in the User's browser settings (saving "cookie" files and using JavaScript technology is enabled).
9.4. The subject of personal data independently makes a decision on the provision of his personal data and gives consent freely, of his own free will and in his own interest.
10. Conditions for Processing Personal Data10.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
10.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, for the implementation of the functions, powers, and duties imposed by the legislation of the Russian Federation on the Company.
10.3. 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.
10.4. Processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or 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.
10.5. 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.
10.6. Processing is carried out of personal data, access to which has been provided by an unlimited circle of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).
10.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
11. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data ProcessingThe security of personal data processed by the Company is ensured through the implementation of legal, organizational, and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.
11.1. The Company ensures the safety of personal data and takes all possible measures that exclude access to personal data by unauthorized persons.
11.2. 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 Company consent to transfer data to a third party for the fulfillment of obligations under a civil law contract.
11.3. In case of detecting inaccuracies in personal data, the User can update them independently by sending a notification to the Company at the Company's email address privacy@brand-resource.com with the note "Updating personal data".
11.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation.
The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Company via email to the Company's email address privacy@brand-resource.com with the note "Withdrawal of consent to the processing of personal data".
11.5. All information that is collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these persons (Companies) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently timely familiarize himself with these documents. The Company is not responsible for the actions of third parties, including the service providers specified in this clause.
11.6. Prohibitions established by the subject of personal data on the transfer (except for providing 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.
11.7. The Company ensures the confidentiality of personal data during the processing of personal data.
11.8. The Company stores personal data in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
11.9. The 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 or the withdrawal of consent by the subject of personal data, as well as the detection of unlawful processing of personal data.
12. List of Actions Performed by the Company with the Received Personal Data12.1. The Company carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
12.2. The Company carries out automated processing of personal data with the receipt and/or transfer of the received information through information and telecommunications networks or without it.
13. Cross-Border Transfer of Personal Data13.1. The Company, before starting the cross-border transfer of personal data, is obliged to make sure that the foreign state to whose territory it is proposed to transfer personal data provides reliable protection of the rights of subjects of personal data.
13.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if there is written consent of the subject of personal data to the cross-border transfer of his personal data and/or execution of an agreement to which the subject of personal data is a party.
14. Confidentiality of Personal DataThe Company 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.
15. Final Provisions15.1. The User can get any clarification on questions of interest regarding the processing of his personal data by contacting the Company via email: info@brand-resource.com.
15.2. The Company has the right to make changes to this Personal Data Processing Policy without the consent of the User.
15.3. The new Privacy Policy comes into force from the moment it is posted on the Website https://brand-resource.com/privacy/, unless otherwise provided by the new version of the Personal Data Processing Policy.
15.4. The current version of the Policy is freely available on the Internet at https://brand-resource.com/privacy/.