Personal Data Protection Policy
1. General Provisions
This Personal Data Protection Policy is prepared in compliance with the Federal Law No. 152-FZ dd. July 27, 2006 "On Personal Data", and determines the procedure for processing and protection of personal data of Modern Advertising Technologies, CJSC (hereinafter the Data Controller).
2. General Definitions used in the Policy
- The key purpose and prerequisite of the Data Controller activities shall be the respect for and observance of rights and freedoms of a human and a citizen while processing their personal data, including protection of the privacy right, as well as personal and family secrets.
- This Personal Data Protection Policy of the Data Controller (hereinafter the Policy) shall apply to all and any information about visitors of http://dca.ru/ that the Data Controller might receive.
3. The Data Controller may process the following personal data of the User
- Automated processing of personal data – processing of personal data by means of computers;
- Blocking of personal data – temporary termination of personal data processing (except when such processing is required to clarify the personal data);
- Web site – a set of graphic and information materials, as well as computer programs and databases ensuring their availability in the Internet at the network address http://dca.ru/;
- Information system of personal data – a set of personal data contained in databases, and information technologies and techniques that provide for their processing;
- Depersonalization of personal data – actions which cause impossibility to determine the ownership of a specific User or another personal data subject of any personal data without using additional information;
- Personal data processing – any actions (operations) or set of actions (operations) performed to personal data by automation means or without using them, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access to) , depersonalization, blocking, deletion or destruction of personal data;
- Data controller – a state authority, a municipal body, a legal entity or an individual, who independently or in connection with other persons organizes and/or performs personal data processing, and determines the purposes of personal data processing, the composition of personal data subject to processing, or actions (operations) to be performed to personal data;
- Personal data – any information directly or indirectly related to a specific or identifiable User of the web site http://dca.ru/;
- User – any visitor of the web site http://dca.ru/;
- Personal data provisioning – actions aimed at disclosure of personal data to a specific person or a certain group of persons;
- Distribution of personal data – any actions aimed at disclosure of personal data to an unlimited range of persons (transfer of personal data) or at access to personal data of an indefinite range of persons, including publishing of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way;
- Cross-border transfer of personal data – transfer of personal data to any foreign authority, individual or legal entity in the territory of a foreign country;
- Destruction of personal data – any actions causing irrevocable destruction of personal data without the possibility to recover them in the personal data information system, and/or causing destruction of material carriers of personal data.
4. Purpose of Personal Data Processing
- First name, last name, patronymic name;
- Email address;
- Phone numbers;
- The web site also conducts collection and processing of impersonal user data (including cookies) using the internet statistics services (Yandex.Metrics, Google Analytics, etc.).
- All above mentioned data hereinafter shall be collectively referred to as the Personal Data.
5. Legal Basis for Personal Data Processing
- The purpose of processing of the User's personal data shall be informing the User by sending emails, conclusion, execution and termination of civil law contracts; providing the User with access to any services, materials and/or information contained on the web site.
- In addition, the Data Controller shall be entitled to send the User notices on new products and services, as well as special offers and events. The User may refuse to receive information messages by sending to the Data Controller an email to firstname.lastname@example.org marked "Waiver of notices of new products, services and special offers".
- The User's impersonal data gathered by Internet statistics services shall serve to collect information about the User's actions on the web site, and to improve the web site and its content.
6. Procedure of Collection, Storage, Transfer and Other Processing of Personal Data
- The Data Controller shall only process the User's personal data if the User independently completed and/or sent such data via special forms located at http://dca.ru/. By completing special forms and/or sending their personal data to the Data Controller, the User agrees with this Policy.
The safety of personal data processed by the Data Controller is ensured through implementation of legal, organizational and technical measures required to fully comply with the applicable legislation on personal data protection.
7. Cross-Border Transfer of Personal Data
- The Data Controller shall ensure the safety of personal data and take all possible measures to prevent access of unauthorized persons to the personal data.
- The User's personal data shall under no circumstances be transferred to any third parties, except where required in compliance with the applicable legislation.
- Should any inaccuracy revealed in the personal data, the User may independently update them by sending to the Data Controller an email to email@example.com marked "Updating of personal data".
- The period of personal data processing shall be indefinite. The User may at any time withdraw their consent to personal data processing by sending to the Data Controller an email to firstname.lastname@example.org marked "Withdrawal of consent to personal data processing".
8. Final Provisions
- Prior to any cross-border transfer of personal data, the Data Controller must assure that the foreign state to where it intends to transfer the personal data ensures reliable protection of rights of personal data subjects.
- If the above requirements are failed, cross-border transfer of personal data may be performed only if the personal data subject provided its written consent to a cross-border transfer of its personal data and/or execution of the contract to which it is a party.
- The User may receive any explanations on any questions on processing of their personal data by contacting the Data Controller via email email@example.com.
- This document shall reflect any changes in the personal data processing policy of the Data Controller. The Police shall be valid for an indefinite period of time until replaced by a new version.
- The current version of the Policy is freely available in the Internet at http://dca.ru/privacy/.
- Provisions hereof may at any time be amended by the Data Controller. Amendments to the Policy shall enter into force immediately upon posting (publishing) them at http://dca.ru/privacy/.