1. General Provisions
This personal data processing policy has been prepared in accordance with Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter the Personal Data Law), and sets out the procedures for processing personal data and the measures to ensure personal data security undertaken by IE Amirian K.S. (hereinafter the Operator).
1.1. The Operator considers respect for human and civil rights and freedoms when processing personal data, including the protection of privacy and personal and family confidentiality, to be its most important objective and a condition of its activities.
1.2. This policy of the Operator on the processing of personal data (hereinafter the Policy) applies to all information that the Operator may obtain about visitors to https://looys.ru/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means processing personal data using computing equipment.
2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify the personal data.
2.3. Website means the collection of graphic and informational materials, computer programs and databases that make them available on the Internet at https://looys.ru/.
2.4. Personal data information system means the collection of personal data contained in databases and the information technologies and technical resources used to process it.
2.5. Depersonalization of personal data means actions that make it impossible, without additional information, to determine whether personal data belongs to a particular User or another personal data subject.
2.6. Processing of personal data means any action or operation, or set of actions or operations, performed on personal data with or without automated means, including collection, recording, systematization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (dissemination, provision or access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity or individual that independently or jointly with others organizes and/or performs personal data processing and determines the purposes of processing, the personal data to be processed and the actions or operations performed on the personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://looys.ru/.
2.9. Personal data authorized by the personal data subject for dissemination means personal data to which the subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized for dissemination in accordance with the Personal Data Law (hereinafter personal data authorized for dissemination).
2.10. User means any visitor to https://looys.ru/.
2.11. Provision of personal data means actions intended to disclose personal data to a particular person or a defined group of persons.
2.12. Dissemination of personal data means any actions intended to disclose personal data to an indefinite group of persons (transfer of personal data) or to make personal data available to an unlimited number of persons, including publication in the media, placement in information and telecommunications networks, or provision of access to personal data in any other manner.
2.13. Cross-border transfer of personal data means transferring personal data to the territory of a foreign state, to a foreign state authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions that irreversibly destroy personal data, making it impossible to restore its contents in the personal data information system, and/or destroy tangible media containing personal data.
3. Principal Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive accurate information and/or documents containing personal data from the personal data subject;
- continue processing personal data without the subject’s consent following withdrawal of that consent where grounds specified in the Personal Data Law exist;
- independently determine the composition and list of measures necessary and sufficient to fulfil the obligations established by the Personal Data Law and regulations adopted pursuant to 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 request, with information concerning the processing of their personal data;
- organize personal data processing in accordance with applicable legislation of the Russian Federation;
- respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the Personal Data Law;
- provide the competent authority responsible for protecting the rights of personal data subjects with the information it requests within 30 days of receipt of the request;
- publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
- take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions;
- cease transferring personal data (dissemination, provision or access), cease processing and destroy personal data in the manner and circumstances established by the Personal Data Law;
- fulfil other obligations established by the Personal Data Law.
4. Principal Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- obtain information concerning the processing of their personal data, except in circumstances provided for by federal laws. The Operator shall provide such information in an accessible form, and it must not contain personal data relating to other personal data subjects unless lawful grounds exist for disclosing it. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- require the Operator to clarify, block or destroy their personal data where it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose, and take measures provided by law to protect their rights;
- require prior consent for the processing of personal data to promote goods, works and services in the market;
- withdraw consent to the processing of personal data;
- appeal unlawful actions or omissions by the Operator in processing personal data to the competent authority responsible for protecting the rights of personal data subjects or to a court;
- exercise other rights provided by legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate information about themselves;
- notify the Operator of any clarification, update or modification of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, shall be liable in accordance with legislation of the Russian Federation.
5. Personal Data of the User That the Operator May Process
5.1. Surname, first name and patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. The Website also collects and processes depersonalized visitor data, including cookies, using Internet statistics services such as Yandex Metrica, Google Analytics and others.
5.5. The data listed above is referred to collectively as Personal Data throughout this Policy.
5.6. The Operator does not process special categories of personal data relating to race, nationality, political opinions, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data authorized for dissemination from the special categories referred to in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions established by Article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data authorized for dissemination shall be given separately from other consents to the processing of their personal data. The conditions established, in particular, by Article 10.1 of the Personal Data Law shall be observed. Requirements for the content of such consent are established by the competent authority responsible for protecting the rights of personal data subjects.
5.8.1 The User provides consent to the processing of personal data authorized for dissemination directly to the Operator.
5.8.2 No later than three working days after receiving that consent, the Operator shall publish information about the processing conditions and any prohibitions and conditions applicable to processing personal data authorized for dissemination by an unlimited number of persons.
5.8.3 Transfer (dissemination, provision or access) of personal data authorized by the subject for dissemination shall cease at any time upon the subject’s request. The request must include the subject’s surname, first name, patronymic if applicable, contact information (telephone number, email address or postal address), and a list of the personal data whose processing must cease. The personal data specified in that request may be processed only by the Operator to whom the request is addressed.
5.8.4 Consent to the processing of personal data authorized for dissemination ceases to have effect when the Operator receives the request specified in paragraph 5.8.3 of this Policy on the processing of personal data.
6. Principles of Personal Data Processing
6.1. Personal data shall be processed on a lawful and fair basis.
6.2. Personal data processing shall be limited to achieving specific, predetermined and lawful purposes. Processing incompatible with the purposes for which the personal data was collected is prohibited.
6.3. Databases containing personal data processed for mutually incompatible purposes must not be combined.
6.4. Only personal data relevant to the purposes of its processing shall be processed.
6.5. The content and volume of personal data processed shall correspond to the stated processing purposes. Personal data must not be excessive in relation to those purposes.
6.6. When processing personal data, its accuracy, sufficiency and, where necessary, relevance to the processing purposes shall be ensured. The Operator takes the necessary measures and/or ensures that measures are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form permitting identification of the subject for no longer than required by the processing purposes, unless the retention period is established by federal law or by a contract to which the subject is a party, beneficiary or guarantor. Personal data shall be destroyed or depersonalized when the processing purposes have been achieved or the need to achieve them no longer exists, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purposes of processing the User’s personal data are:
- informing the User by sending emails;
- concluding, performing and terminating civil-law contracts;
- providing the User with access to services, information and/or materials available at https://looys.ru/.
7.2. The Operator may also send the User notifications about new products and services, special offers and various events. The User may opt out of such informational messages at any time by emailing amadigitalagency@mail.ru with the subject “Unsubscribe from notifications about new products, services and special offers”.
7.3. Depersonalized User data collected through Internet statistics services is used to gather information about Users’ actions on the Website and to improve the quality of the Website and its content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for the Operator’s processing of personal data are:
- list the laws and regulations governing relations connected with your activities; for example, if your activities concern information technology, particularly website creation, you may specify Federal Law No. 149-FZ of July 27, 2006, “On Information, Information Technologies and Information Protection”;
- the Operator’s constitutional documents;
- contracts concluded between the Operator and personal data subjects;
- federal laws and other regulations concerning personal data protection;
- Users’ consent to the processing of their personal data and personal data authorized for dissemination.
8.2. The Operator processes the User’s personal data only when the User independently enters and/or submits it through special forms at https://looys.ru/ or sends it to the Operator by email. By completing the relevant forms and/or sending personal data to the Operator, the User expresses agreement with this Policy.
8.3. The Operator processes depersonalized User data where the User’s browser settings permit it, including enabled cookie storage and JavaScript.
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own will and in their own interest.
9. Conditions for Personal Data Processing
9.1. Personal data shall be processed with the subject’s consent to the processing of their personal data.
9.2. Processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, and to perform functions, powers and obligations imposed on the Operator by legislation of the Russian Federation.
9.3. Processing is necessary for the administration of justice and the enforcement of a court decision, or a decision of another authority or official subject to enforcement in accordance with legislation of the Russian Federation on enforcement proceedings.
9.4. Processing is necessary to perform a contract to which the personal data subject is a party, beneficiary or guarantor, or to conclude a contract at the subject’s initiative or a contract under which the subject will be a beneficiary or guarantor.
9.5. Processing 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 infringed.
9.6. Personal data to which an unlimited number of persons have been granted access by the subject or at the subject’s request (hereinafter publicly available personal data) is processed.
9.7. Personal data that must be published or disclosed under federal law is processed.
10. Procedures for Collection, Storage, Transfer and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to comply fully with applicable personal data protection legislation.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
10.2. The User’s personal data shall never, under any circumstances, be transferred to third parties except where required to comply with applicable law or where the subject has consented to the Operator transferring data to a third party to fulfil obligations under a civil-law contract.
10.3. If inaccuracies in personal data are identified, the User may update the data by sending a notification to info@looys.ru with the subject “Updating personal data”.
10.4. The processing period is determined by the achievement of the purposes for which personal data was collected, unless another period is established by a contract or applicable legislation.
The User may withdraw consent to personal data processing at any time by emailing the Operator at info@looys.ru with the subject “Withdrawal of consent to personal data processing”.
10.5. All information collected by third-party services, including payment systems, communication providers and other service providers, is stored and processed by those parties (operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or User must independently review those documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers referred to in this paragraph.
10.6. Prohibitions imposed by the subject on the transfer (other than granting access), processing, or processing conditions (other than obtaining access) of personal data authorized for dissemination do not apply where processing is carried out in state, public or other public interests defined by legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data when processing it.
10.8. The Operator stores personal data in a form permitting identification of the subject for no longer than required by the processing purposes, unless the retention period is established by federal law or by a contract to which the subject is a party, beneficiary or guarantor.
10.9. Processing may cease when its purposes have been achieved, the subject’s consent has expired or been withdrawn, or unlawful processing has been identified.
11. Actions Performed by the Operator on Personal Data Received
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (disseminates, provides or grants access to), depersonalizes, blocks, deletes and destroys personal data.
11.2. The Operator performs automated personal data processing with or without receiving and/or transmitting the information obtained through information and telecommunications networks.
12. Cross-Border Transfer of Personal Data
12.1. Before initiating a cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the data is to be transferred provides reliable protection for the rights of personal data subjects.
12.2. Cross-border transfers to foreign states that do not meet the above requirements may occur only where the subject has provided written consent to the cross-border transfer of their personal data and/or where necessary to perform a contract to which the subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons who obtain access to personal data must not disclose it to third parties or disseminate it without the subject’s consent, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User may obtain clarification on any matter concerning the processing of their personal data by contacting the Operator at info@looys.ru.
14.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://looys.ru/.