Personal data processing policy
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1. General points
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-ФЗ «On Personal Data» (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by G2R Limited (hereinafter referred to as the Operator)
- 1.1 The Operator's most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
- 1.2 This Operator's personal data processing policy (the "Policy") applies to all information that the Operator may receive about visitors to https://g2r.biz.
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2. Basic concepts used in the
- 2.1 Automated processing of personal data - processing of personal data by means of 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 means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://g2r.biz network address.
- 2.4 Personal data information system is an aggregate of personal data contained in databases, and information technologies and technical means, ensuring processing of personal data.
- 2.5. depersonalization of personal data - actions, as a result of which it is impossible to determine, without using additional information, the attribution of personal data to a particular User or other subject of personal data.
- 2.6 Processing of personal data means any action (operation) or a set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data.
- 2.7 Operator - a state body, municipal authority, legal entity or individual, independently or together with other persons, arranging and (or) carrying out processing of personal data, as well as determining the purpose of personal data processing, 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 particular or defined User of the website https://g2r.biz.
- 2.9. Personal data, allowed by the subject of personal data for distribution - personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, allowed the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, allowed for distribution).
- 2.10. User - any visitor to the https://g2r.biz website.
- 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. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data to an unlimited circle of persons, including disclosure of personal data 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 state authority, foreign natural person or foreign legal entity.
- 2.14. Destruction of personal data - any action, as a result of which personal data is destroyed irretrievably with impossibility to further restore the content of personal data in the information system of personal data and (or) material media of personal data are destroyed.
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3. The basic rights and obligations of the operator
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3.1 The operator has the right:
- to obtain from the subject of personal data reliable information and/or documents containing personal data;
- in case the personal data subject withdraws their consent to the processing of personal data, the operator has the right to continue the processing of personal data without the consent of the personal data subject on the grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure fulfilment of obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
- 3.2 The operator shall:
- provide the personal data subject, at his or her request, with information relating to the processing of his or her personal data;
- organise the processing of personal data in accordance with the procedure established by the applicable laws of the Russian Federation;
- to respond to requests and enquiries of personal data subjects and their legal representatives, in accordance with the requirements of the Law on personal data;
- notify the authority responsible 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 request;
- publish or otherwise ensure unrestricted access to this Policy on personal data processing;
- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful acts in relation to personal data;
- cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;
- perform other duties provided by the Personal Data Law.
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3.1 The operator has the right:
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4. Basic rights and obligations of personal data subjects
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4.1 Personal data subjects have the right:
- to receive information relating to the processing of their personal data, with the exception of cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Act;
- demand that the operator clarify, block or destroy personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and to take statutory measures to protect their rights;
- to impose the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw their consent to the processing of personal data;
- to appeal against unlawful actions or omissions of the Operator in processing his personal data to the authorised body for protection of the rights of subjects of personal data or in court;
- to exercise other rights provided by the legislation of the Russian Federation.
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4.2 Personal data subjects shall:
- provide the Operator with accurate data about themselves;
- inform the Operator of the clarification (updating, modification) of their personal data.
- 4.3 Persons who provided the Operator with false information about themselves or information about another personal data subject without their consent shall be liable in accordance with Russian law.
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4.1 Personal data subjects have the right:
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5. The operator may process the following personal data of the user
- 5.1 Surname, first name and patronymic.
- 5.2 Email address.
- 5.3 Telephone numbers.
- 5.4 Information about the organisation.
- 5.5 The website also collects and processes impersonal visitor data (including cookies) using Internet statistical services (Yandex Metrika and Google Analytics, etc.).
- 5.6 The above-mentioned data are hereinafter referred to in this Policy under the general term Personal Data.
- 5.7 The Operator shall not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs or intimate life.
- 5.8 Processing of personal data, authorized for dissemination, from among the special categories of personal data specified in Article 10.1 of the Personal Data Law shall be permitted if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are complied with.
- 5.9 The User's consent to the processing of personal data authorized for dissemination shall be formalized separately from other consents to the processing of their personal data. The conditions stipulated, in particular, in Article 10.1 of the Personal Data Law shall be complied with. The requirements for the content of such consent shall be established by the competent authority for the protection of the rights of personal data subjects.
- 5.9.1 The consent for the processing of personal data permitted for distribution shall be given by the User directly to the Operator.
- 5.9.2 The Operator is obliged, within three working days of the receipt of the User's consent, to publish information about the processing conditions, prohibitions and conditions for the processing of personal data permitted for distribution to an unlimited number of persons.
- 5.9.3 Transfer (distribution, provision, access) of personal data, authorised by the personal data subject for distribution, must be terminated at any time at the request of the personal data subject. This request shall include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is sent.
- 5.9.4 Consent to the processing of personal data authorised for dissemination shall cease upon receipt by the Operator of the request referred to in clause 5.9.3 of this Policy regarding the processing of personal data.
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6. Principles of personal data processing
- 6.1 Processing of personal data shall be lawful and fair.
- 6.2 Processing of personal data shall be limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.
- 6.3 Databases containing personal data that are processed for purposes that are incompatible with each other shall not be merged.
- 6.4 Only personal data that meets the purposes for which it is being processed shall be processed.
- 6.5 The content and scope of personal data processed shall comply with the stated processing purposes. No excessive processing of personal data in relation to the stated processing purposes shall be permitted.
- 6.6 When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance in relation to the purpose of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to remove or clarify incomplete or inaccurate data.
- 6.7 Personal data shall be stored in a form that allows identification of the personal data subject for no longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalised upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.
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7. Purposes of personal data processing
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7.1 The purpose of processing the User's personal data:
- informing the User by sending emails.
- 7.2 The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User can always refuse receiving information messages by sending an email to the Operator at rushan@g2r.biz with the note "Unsubscribe from notifications about new products and services and special offers.
- 7.3 The anonymised User data collected via Internet statistics services are used to collect information about Users' activities on the website, to improve the quality of the website and its content.
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7.1 The purpose of processing the User's personal data:
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8. Legal basis for processing personal data
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8.1 The legal basis for the processing of personal data by the Operator shall be:
- Federal Law "On Information, Information Technologies and the Protection of Information" of 27.07.2006 N 149-FZ;
- Federal Laws and other regulations in the sphere of personal data protection;
- users' consent to the processing of their personal data, to the processing of personal data permitted for distribution.
- 8.2. The Operator processes the User's personal data only if the User fills them in and/or sends them by himself through the special forms located on the website https://g2r.biz or sent to the Operator by e-mail. By filling in the relevant forms and/or sending his personal data to the Operator, the User expresses his consent to this Policy.
- 8.3 The Operator processes anonymised data about the User if this is permitted in the User's browser settings (cookie saving and the use of JavaScript technology are enabled).
- 8.4 The personal data subject shall independently decide on the provision of his or her personal data and shall give consent freely, of his or her own free will and in his or her own interest.
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8.1 The legal basis for the processing of personal data by the Operator shall be:
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9. Conditions for the processing of personal data
- 9.1 Processing of personal data shall be subject to the consent of the personal data subject to the processing of his/her personal data.
- 9.2 Processing of personal data is necessary in order to achieve the objectives set out in an international treaty of the Russian Federation or by law, to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
- 9.3 Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
- 9.4 Processing of personal data is necessary for execution of the agreement, to which the personal data subject is a party or beneficiary or guarantor, as well as for conclusion of the agreement on the initiative of the personal data subject or the agreement, under which the personal data subject will be a beneficiary or guarantor.
- 9.5 The processing of personal data is necessary for the exercise of the rights and lawful interests of the operator or third parties or for the achievement of socially important objectives, provided that the rights and freedoms of the personal data subject are not violated thereby.
- 9.6 Processing of personal data, to which access has been granted by or at the request of the data subject (hereinafter "publicly available personal data").
- 9.7 Processing of personal data subject to publication or compulsory disclosure in accordance with federal law.
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10. Procedure for the collection, storage, transfer and other processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organisational and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.
- 10.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorised persons.
- 10.2 The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of the current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party to fulfil obligations under a civil law contract.
- 10.3 If inaccuracies in the personal data are identified, the User may update the personal data themselves by sending a notification to the Operator's email address rushan@g2r.biz, marked "Update of personal data".
- 10.4 The time period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different time period is stipulated by contract or applicable law. The user may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via e-mail to the Operator's e-mail address rushan@g2r.biz, marked "Withdrawal of consent to the processing of personal data".
- 10.5 All information that is collected by third party services, including payment systems, means of communication and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to acquaint themselves with the said documents in a timely manner. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
- 10.6 The prohibitions established by the personal data subject on the transfer (other than granting access) as well as on the processing or processing conditions (other than gaining access) of personal data permitted for distribution shall not apply in cases of processing of personal data in state, public and other public interests as defined by Russian legislation.
- 10.7. The Operator shall ensure the confidentiality of personal data when processing personal data.
- 10.8. The operator shall store personal data in a form which allows the personal data subject to be identified, for no longer than is required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor under which the personal data subject is a beneficiary.
- 10.9 A condition for the termination of personal data processing may be the achievement of the personal data processing objectives, expiry of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as the detection of unlawful personal data processing.
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11. List of actions performed by the operator with the personal data received
- 11.1 The Operator shall collect, record, systematise, aggregate, store, clarify (update, modify), extract, use, transmit (distribute, provide, access), anonymise, block, delete and destroy personal data.
- 11.2 The Operator shall carry out automated processing of personal data with or without the receipt and/or transmission of received information via information and telecommunications networks.
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12. Cross-border transfer of personal data
- 12.1 Before transborder transfer of personal data, the operator shall ensure that the foreign state to whose territory the transfer of personal data is to take place provides reliable protection of the rights of personal data subjects.
- 12.2 The cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out if the personal data subject consents in writing to the cross-border transfer of his/her personal data and/or to the performance of an agreement to which the personal data subject is a party.
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13. Confidentiality of personal data
The operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
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14. Final provisions
- 14.1 The User may obtain any clarification on questions of interest regarding the processing of their personal data by contacting the Operator by email at rushan@g2r.biz.
- 14.2 This document will reflect any changes to the Operator's personal data processing policy. The Policy shall be valid indefinitely until replaced by a new version.
- 14.3 The current version of the Policy is freely available on the Internet at https://g2r.biz/privacy.