Privacy policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Mikhailov Ivan Sergeyevich (hereinafter — the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of rights to privacy, personal and family secrets, to be its most important goal and condition for carrying out its activities.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://sbg-team.ru/.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computing equipment.

2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the network address https://sbg-team.ru/.

2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that process them.

2.5. Anonymisation of personal data — actions that make it impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other personal data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organising and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, 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://sbg-team.ru/.

2.9. Personal data permitted by the personal data subject for distribution — personal data to which unrestricted access has been granted by the personal data subject by giving consent to the processing of personal data permitted for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor to the website https://sbg-team.ru/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including the publication of personal data in the 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 as a result of which personal data is irreversibly destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or physical personal data media 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 personal data subject;
• in the event that the personal data subject withdraws consent to the processing of personal data, as well as submits a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds provided for by the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of obligations provided for by the Personal Data Law and regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject, upon their request, with information concerning the processing of their personal data;
• organise the processing of personal data in accordance with the current legislation of the Russian Federation;
• respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• notify the authorised body for the protection of the rights of personal data subjects upon request of that body of the necessary information within 10 days from the date of receipt of such request;
• publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
• take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
• stop the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• perform other duties provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and must not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• require the Operator to clarify their personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
• put forward the condition of prior consent when processing personal data for the purpose of marketing goods, works and services;
• withdraw consent to the processing of personal data, as well as to submit a request to cease the processing of personal data;
• appeal to the authorised body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator when processing their personal data;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with reliable data about themselves;
• inform the Operator about clarification (updating, changing) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter’s consent, shall be held liable in accordance with applicable legislation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. Personal data processing 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 permitted.

5.3. It is not permitted 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 meets the purposes for which it is processed is subject to processing.

5.5. The content and volume of personal data processed corresponds to the stated processing purposes. The personal data processed must not be excessive in relation to the stated processing purposes.

5.6. When processing personal data, the accuracy of personal data and its sufficiency, and where necessary its relevance in relation to the purposes of personal data processing is ensured. The Operator takes the necessary measures and/or ensures that incomplete or inaccurate data is removed or clarified.

5.7. Personal data is stored in a form that makes it possible to identify the personal data subject, for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor. The processed personal data is destroyed or anonymised upon achievement of the processing purposes or in the event that it is no longer necessary to achieve those purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Personal Data Processing

7.1. Personal data is processed with the consent of the personal data subject.

7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to exercise and fulfil the functions, powers and duties imposed by the legislation of the Russian Federation on the Operator.

7.3. Processing of personal data is necessary for the administration of justice, the 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 performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that the rights and freedoms of the personal data subject are not thereby violated.

7.6. Processing is carried out in respect of personal data to which unrestricted access has been granted by the personal data subject or at their request (hereinafter — publicly available personal data).

7.7. Processing is carried out in respect of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring 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 to fully comply with the requirements of applicable data protection legislation.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorised persons.

8.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable legislation or in the case where the personal data subject has given consent to the Operator to transfer data to a third party to fulfil obligations under a civil law contract.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@sbg-team.ru marked “Updating of personal data”.

8.4. The personal data processing period is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by the contract or applicable legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator by email at info@sbg-team.ru marked “Withdrawal of consent to the processing of personal data”.

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions established by the personal data subject on the transfer (other than the granting of access), as well as on the processing or conditions of processing (other than the granting of access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests as defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing it.

8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject, for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.

8.9. Grounds for ceasing the processing of personal data may include: achievement of the purposes of processing, expiry of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to cease processing, as well as identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data

9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), anonymises, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.

10. Cross-Border Transfer of Personal Data

10.1. Prior to carrying out cross-border transfer of personal data, the Operator is obliged to notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is submitted separately from the notification of the intention to process personal data).

10.2. The Operator, before submitting the above notification, is obliged to obtain relevant information from the authorities of the foreign state, 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 other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator by email at info@sbg-team.ru.

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://sbg-team.ru/en/privacy-policy/.