De Novo Group - Policy on personal data processing

Policy on personal data processing

1. General provisions

This policy of personal data processing is drawn up in accordance with the requirements of the Federal Law No. 152-FZ "On Personal Data" of July 27, 2006 (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of the personal data undertaken by De Novo Group LLC (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition of activity the observance of human and citizen's rights and freedoms when processing his or her personal data, including the protection of the rights to privacy and personal and family secrecy.
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 may obtain about the visitors of the website https://denovogroup.ru/.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data is processing of personal data by means of computers.
2.2. Blocking of personal data is temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).
2.3. Website is a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://denovogroup.ru/
2.4. A personal data information system is a set of personal data contained in databases, information technology, and technical means ensuring their processing.
2.5. Personal data depersonalization are actions, as a result of which it is impossible to determine without using additional information the belonging of personal data to a particular User or other personal data subject.
2.6. Processing of personal data is any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator is a state authority, municipal authority, legal or natural person, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the https://denovogroup.ru/
2.9. Personal data authorized by the personal data subject for dissemination is personal data, access to which is provided by the personal data subject to an unlimited number of persons by giving consent to the processing of personal data authorized by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter—personal data authorized for dissemination).
2.10. User is any visitor to the https://denovogroup.ru/ website
2.11. Provision of personal data is actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data is any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number 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 is a transfer of personal data to the territory of a foreign country to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data is any actions as a result of which personal data is irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. Main rights and obligations of the Operator

3.1. The Operator has the right to receive from the personal data subject reliable information and/or documents containing personal data; in case the personal data subject withdraws consent to personal data processing, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law; 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 regulatory legal acts adopted in accordance with it, 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 his or her request, with information regarding the processing of his or her personal data; organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation; respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 30 days from the date of receipt of such a request; publish or otherwise provide unrestricted access to this Policy on personal data processing; take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, and dissemination of personal data, as well as from other unlawful actions with regard to personal data; stop the transfer (dissemination, provision, and access) of personal data; stop processing and destroying personal data in the manner and cases stipulated by the Personal Data Law; and fulfill other obligations stipulated by the Personal Data Law.

4. Main rights and obligations of personal data subjects

4.1. Personal data subjects have the right to receive information regarding the processing of their personal data, except in cases provided for by federal laws. The Opera shall provide information to the personal data subject in an accessible form. The data shall not contain personal data relating to other subjects of personal data, unless there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law; to demand from the operator to clarify his 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 to take measures provided for by law to protect their rights; to impose a condition of prior consent when processing personal data in order to promote 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 the subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of their personal data; to exercise other rights provided for by the legislation of the Russian Federation.
4.2. The subjects of personal data shall: provide the Operator with reliable data about themselves; inform the Operator about clarification (update, change) of their personal data
4.3. Persons who transferred to the Operator false information about themselves, or information about another personal data subject without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Surname, first name, patronymic.
5.2. E-mail address.
5.3. Telephone numbers.
5.4. Year, month, date and place of birth.
5.5. The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica, Google Analytics, and others).
5.6. The above-mentioned data are further discussed in the text of the policy, which is united by the general term Personal Data.
5.7. The Operator does not process special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, intimate life.
5.8. Processing of personal data authorized for dissemination from among the special categories of personal data specified in Article 10, paragraph 1 of the Personal Data Law is allowed 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 is executed separately from other consents to the processing of his or her personal data. At the same time, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law are complied with. The requirements for the content of such consent shall be established by the authorized body for the protection of the rights of personal data subjects.
5.9.1 The User provides the Operator directly with consent to the processing of personal data allowed for dissemination.
5.9.2 The Operator shall publish information about the conditions of processing, prohibitions, and conditions for the processing of personal data allowed for dissemination by an unlimited number of persons within three working days from the moment of receiving the said consent of the User.
5.9.3 Transfer (dissemination, provision, access) of personal data allowed by the personal data subject for dissemination shall be stopped at any time at the request of the personal data subject. This requirement shall include the surname, first name, patronymic (if available), 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 subject to termination. The personal data specified in this request may be processed only by the Operator to whom it has been sent.
5.9.4 Consent to the processing of personal data authorized for dissemination shall terminate upon receipt by the Operator of the request specified in Clause 5.9.3 of this Policy on Personal Data Processing.

6. Principles of personal data processing

6.1. Processing of personal data shall be carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
6.3. It is not permitted to merge databases containing personal data processed for incompatible purposes.
6.4. Only personal data that meet the purposes of their processing shall be processed.
6.5. The content and scope of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not permitted
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing are ensured. The Operator shall take the necessary measures and/or ensure that they 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 required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized when the purposes of processing have been achieved or when it is no longer necessary to achieve these purposes, unless otherwise provided for by federal law.

7. Purposes of personal data processing

7.1. The purpose of processing the User's personal data: informing the User by sending e-mails; providing the User with access to services, information and/or materials contained on the website https://denovogroup.ru/.
7.2. Also, the Operator has the right to send the User notifications about new products and services, special offers and various events. The User may always opt out of receiving informational messages by sending a letter to the Operator to the e-mail address hello@denovogroup.ru marked "Refusal to notify about new products and services and special offers"
7.3. The anonymized data of Users collected by means of Internet statistics services are used to collect information about Users' actions on the website, to improve the quality of the website and its content.

8. Legal basis for processing personal data

8.1. The legal grounds for processing personal data by the Operator are: List the legal acts regulating the relations related to your activity. For example, if your activity is related to information technologies, in particular, to the creation of websites, here you can specify Federal Law No 149-FZ "On Information, Information Technologies and Information Protection" of July 27, the operator's statutory documents; contracts concluded between the Operator and the personal data subject; federal laws and other regulatory legal acts in the field of personal data protection; Users' consent to the processing of their personal data and to the processing of personal data authorized for dissemination.
8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User himself/herself through special forms located on the website https://denovogroup.ru/ or sent to the Operator by e-mail. By filling out the relevant forms and/or sending his or her personal data to the Operator, the User expresses his or her consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (cookies and JavaScript technology enabled).
8.4. The personal data subject independently decides on the provision of his or her personal data and gives consent freely, of his or her own free will, and in his or her own interest.

9. Terms and Conditions of Personal Data Processing

9.1. Processing of personal data shall be carried out with the consent of the personal data subject to the processing of his or her personal data.
9.2. Processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or law and to fulfill the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings
9.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract 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 legitimate interests of the operator or third parties or for the achievement of socially important purposes, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Processing of personal data shall be carried out to which an unlimited number of persons have access by the personal data subject or at his/her request (hereinafter, publicly available personal data).
9.7. Processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for collection, storage, transfer and other types of personal data processing

The Security of personal data processed by the Operator shall be ensured by implementing legal, organizational and technical measures necessary for full compliance with the requirements of the applicable legislation in the field of personal data protection.

10.1. The Operator shall ensure safety of personal data and take all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User's personal data will never, under no circumstances, be transferred to third parties, except in cases related to the execution of the applicable law or if the subject of personal data has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.
10.3. In case of identifying inaccuracies in personal data, the User may update them independently by sending a notice to the Operator to the Operator's e-mail address, hello@denovogroup.ru, with the remark "Personal Data Update"
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is stipulated by the contract or applicable law. The User may withdraw his or her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address, hello@denovogroup.ru, marked "Withdrawal of consent to the processing of personal data"
10.5. All information that is collected by third-party services, including payment systems, communications, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The Personal Data Subject and/or User are obliged to familiarize themselves with the said documents in a timely manner. The Operator shall not be liable for the actions of third parties, including service providers specified in the current clause.
10.6. The prohibitions established by the personal data subject on the transfer (except for granting access) as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination shall not apply in cases of processing personal data in the state, public, or other public interests defined by the legislation of the Russian Federation.
10.7. When processing personal data, the Operator shall ensure confidentiality of personal data.
10.8. The Operator shall store personal data in a form that allows 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, a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.

11. List of actions performed by the Operator with the received personal data

11.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete, and destroy personal data.
11.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

12. Cross-border transfer of personal data

12.1. Prior to the commencement of trans-border transfer of personal data, the operator shall be obliged to ensure that the foreign state, to the territory of which the transfer of personal data is to be carried out, provides reliable protection of the rights of personal data subjects.
12.2. 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 the personal data subject consents in writing to the trans-border transfer of his or her personal data and/or if the contract is executed to which the personal data subject is a party.

13. Confidentiality of personal data

The Operator and other persons who have access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided for by federal law

14. Final Provisions

14.1. The User may obtain any clarifications on the issues of interest regarding the processing of their personal data by contacting the Operator via email at hello@denovogroup.ru
14.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://denovogroup.ru/en/policy