Privacy Policy Regarding Personal Data Processing- General Provisions
This personal data processing policy is developed in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "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 Ekaterina Viktorovna Antonova (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is the protection of the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrets.
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://smartadsteam.com.
2. Key Terms Used in the Policy
2.1. Automated personal data processing – the processing of personal data using computing 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 set of graphical and informational materials, as well as software and databases that provide access to them via the internet address
https://smartadsteam.com.
2.4. Information system of personal data – a set of personal data contained in databases and ensuring their processing using information technologies and technical means.
2.5. Anonymization of personal data – actions that make it impossible to identify personal data without using additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with personal data using automated or non-automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a government body, municipal body, legal or natural person who independently or together with others organizes and/or performs the processing of personal data and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information related directly or indirectly to a specific or determined User of the website
https://smartadsteam.com.
2.9. Personal data authorized by the data subject for distribution – personal data to which an unlimited number of individuals is granted access by the data subject by giving consent to the processing of personal data authorized by the data subject for distribution in the manner specified in the Personal Data Law (hereinafter – personal data authorized for distribution).
2.10. User – any visitor to the website
https://smartadsteam.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transferring personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the media, placement on information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – the transfer of personal data to a foreign state, a foreign government agency, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, with no possibility of further recovery of the content of personal data in the information system of personal data and/or the destruction of physical carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive from the data subject accurate information and/or documents containing personal data.
— In case of the data subject withdrawing consent for processing personal data, or submitting a request to stop processing personal data, the Operator may continue processing personal data without consent if there are grounds as specified in the Personal Data Law.
— Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and other normative legal acts adopted in accordance with it, unless otherwise specified by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— Provide the data subject, upon their request, with information regarding the processing of their personal data.
— Organize the processing of personal data in accordance with the applicable legislation of the Russian Federation.
— Respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.
— Inform the authorized body for the protection of personal data subjects' rights, upon request, with necessary information within 10 days of receiving such a request.
— Publish or otherwise ensure unrestricted access to this Privacy Policy regarding the processing of personal data.
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions concerning personal data.
— Cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in accordance with the Personal Data Law.
— Fulfill other obligations provided by the Personal Data Law.
4. Main Rights and Obligations of the Data Subjects
4.1. Data subjects have the right to:
— Receive information regarding the processing of their personal data, except in cases specified by federal laws. The information provided to the data subject by the Operator must be in an accessible form and must not contain personal data related to other data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are defined by the Personal Data Law.
— Require the Operator to clarify, block, or destroy personal data if they are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, and also take legal measures to protect their rights.
— Make the condition of prior consent when processing personal data for marketing purposes.
— Withdraw consent to the processing of personal data, as well as submit a request to stop processing personal data.
— Appeal to the authorized body for the protection of the rights of data subjects or in court for unlawful actions or omissions by the Operator when processing personal data.
— Exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obligated to:
— Provide the Operator with accurate information about themselves.
— Notify the Operator about any clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or about another data subject without their consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.
5.3. Combining databases containing personal data that are processed for incompatible purposes is not permitted.
5.4. Only personal data necessary to achieve the goals of their processing will be processed.
5.5. The content and scope of personal data being processed correspond to the declared purposes of processing. The processing of personal data exceeding the scope required for the declared purposes is not permitted.
5.6. When processing personal data, accuracy, sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption for deleting or clarifying incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identifying the data subject for no longer than necessary for achieving the purposes of personal data processing, unless the retention period is established by federal law, contract, or other legal obligations. Personal data are destroyed or anonymized once the purposes of processing are achieved or if there is no further need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: exclusively for establishing communication with users and offering personalized cooperation terms.
Personal data:
Last name, first name, patronymic
Email address
Phone numbers
Legal grounds: Federal Law "On Information, Information Technologies and Information Protection" of July 27, 2006, No. 149-FZ.
Types of personal data processing: informing about services, offers, and other issues related to the company's activities.
7. Conditions for Processing Personal Data
7.1. Personal data processing is carried out with the consent of the data subject for processing their personal data.
7.2. Personal data processing is necessary to achieve the goals stipulated by international agreements of the Russian Federation or law, to fulfill the functions, powers, and obligations imposed by the legislation of the Russian Federation on the operator.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court decision, or other actions required by Russian Federation law.
7.4. Personal data processing is necessary for the execution of a contract, in which the data subject is a party or beneficiary, or for the conclusion of a contract upon the data subject's initiative.
7.5. Personal data processing is necessary for the exercise of rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data are processed that have been made publicly available by the data subject or at their request.
7.7. Personal data processing is carried out when it is necessary for publication or mandatory disclosure in accordance with federal law.
8. Order of Collection, Storage, Transfer, and Other Types of Personal Data Processing
Personal data security, processed by the Operator, is ensured by implementing legal, organizational, and technical measures necessary for full compliance with the requirements of applicable legislation on the protection of personal data.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except as related to the fulfillment of applicable legislation or if the data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by notifying the Operator at the email address
info@smartadsteam.com with the subject line "Personal Data Update".
8.4. The period for processing personal data is determined by the achievement of the goals for which the personal data were collected, unless another period is provided by the contract or applicable law.
The User can withdraw consent to process personal data at any time by sending the Operator a notice via email at
info@smartadsteam.com with the subject line "Withdrawal of consent to process personal data".
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by those entities (Operators) according to their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including those specified in this paragraph.
8.6. Restrictions imposed by the data subject on the transfer (except for providing access) and processing of personal data authorized for distribution do not apply when processing personal data for public or state interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identifying the data subject for no longer than necessary for achieving the purposes of processing, unless the retention period is established by federal law, the contract, or the data subject is a party, beneficiary, or guarantor under that contract.
8.9. Personal data processing can be terminated upon the achievement of processing goals, expiration of the data subject's consent, withdrawal of consent, or when an unlawful processing of personal data is detected.
9. Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the reception and/or transfer of the obtained information through information and telecommunications networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. The Operator must notify the authorized body for the protection of personal data subjects' rights before engaging in cross-border personal data transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain the necessary information from foreign government authorities, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and any individuals who have access to personal data are obliged not to disclose or distribute personal data to third parties without the data subject's consent, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarifications regarding the processing of their personal data by contacting the Operator at the email address
info@smartadsteam.com.
12.2. This document will reflect any changes in the personal data processing policy by the Operator. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at
https://smartadsteam.com/policy.
