Personal data processing policy
1 General provisions
This policy of processing of personal data is made according to requirements of the Federal law dated 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - Personal Data Law) and determines the procedure of personal data processing and measures to ensure security of personal data undertaken by "Spinemedics" LLC (hereinafter - the Operator).
1.1The Operator's most important purpose and requirement for carrying out its activities is to observe human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.
1.2 The present Operator's personal data processing policy (hereinafter the "Policy") applies to all information that the Operator may receive on visitors of the https://SpineMedics.ru website.
2 Basic Terms Used in this Policy
2.1 Automated processing of personal data - processing of personal data by means of computer technology.
2.2 Blocking of personal data - temporary suspension 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 information materials, as well as computer programs and databases, ensuring their availability on the Internet at https://SpineMedics.ru 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. Anonymisation 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 specific User or other subject of personal data.
2.6 Processing of personal data - 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 (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, 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://SpineMedics.ru.
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 by 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 https://SpineMedics.ru.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain scope of persons.
2.12. Distribution of personal data - any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize an unlimited number of persons with personal data, including publication of personal data in the media, posting in the 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 a foreign state authority, foreign individual 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 bearing personal data are destroyed.
3. Basic rights and obligations of the Operator
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 set out in the Personal Data Law;
- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided by the Personal Data Law and the regulations adopted in accordance therewith, 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;
- Organize the processing of personal data in the manner prescribed by applicable laws of the Russian Federation;
- respond to requests and enquiries of personal data subjects and their legal representatives, in accordance with the requirements of the Personal Data Law
- 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 stipulated by the Personal Data Law
- Perform other duties provided by the Personal Data Law.
4 Basic rights and obligations of subjects of personal data
4.1 Personal data subjects have the right:
- To receive information relating to the processing of their personal data, except in the cases stipulated by federal laws. The information is provided to the subject of personal data by the operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are set out in the Personal Data Law;
- To require the operator to clarify his personal data, to block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and to take statutory measures to protect his rights;
- to require prior consent when processing personal data for the purpose of promoting goods, works or services on the market;
- to withdraw the consent to the processing of personal data
- to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the operator in the processing of his personal data
- To exercise other rights provided by the legislation of the Russian Federation.
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 inaccurate information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the laws 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. Phone numbers.
5.4 The site also collects and processes visitors' anonymised data (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics, etc.).
5.5 The above-mentioned data are hereinafter referred to in this Policy as Personal Data.
5.6 The Operator shall not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.
5.7 Processing of personal data, allowed for distribution, from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law, is allowed, if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are observed.
5.8 The User's consent to the processing of personal data permitted for distribution shall be executed separately from other consents to the processing of their personal data. The conditions stipulated, in particular, by 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.
5.8.1 The consent for the processing of personal data permitted for distribution shall be given by the User directly to the Operator.
5.8.2 The Operator is obliged, within three working days from the receipt of the above consent of the User, to publish information about the conditions of processing, prohibitions and conditions for the processing of personal data permitted for distribution to an unlimited range of persons.
5.8.3 The transfer ( distribution, provision, access) of personal data, authorised by the personal data subject for distribution, must be terminated at any time on the request of the personal data subject. This request must 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 on which processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data authorised for distribution shall cease upon receipt by the Operator of the request referred to in clause 5.8.3 of this Policy regarding the processing of personal data.
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 objectives. No processing of personal data which is incompatible with the purposes for which the personal data is collected shall 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. Processed personal data shall not be excessive in relation to the stated processing purposes.
6.6 During the processing of 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 incomplete or inaccurate data is removed or clarified.
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 anonymised upon attainment of the processing objectives or if it is no longer necessary to attain those objectives, unless otherwise stipulated by federal law.
7. Purposes of processing of personal data
7.1 The purpose of processing of personal data of the User:
- informing the User by sending emails;
- Conclusion, performance and termination of civil law contracts;
- giving the User access to services, information and/or materials contained on the https://SpineMedics.ru website.
7.2. Also the Operator has the right to send the User notifications about new products and services, special offers and different events. The User can always refuse receiving information messages by sending an email to the Operator at email@example.com 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 is used to collect information about Users' actions on the website and to improve the quality of the website and its content.
8. Legal basis for processing personal data
8.1 The legal basis for the processing of personal data by the operator are
- Contracts concluded between the operator and the subject of personal data;
- Federal laws and other legal acts in the sphere of personal data protection
- The User's consent to the processing of their personal data, and to the processing of personal data that is permitted for distribution.
8.2. The operator processes the User's personal data only if they are filled in and/or sent by the User himself via special forms located on the website https://SpineMedics.ru or sent to the Operator by e-mail. By completing the relevant forms and/or sending his personal data to the Operator, the User expresses his consent to this Policy.
8.4 The subject of personal data decides independently on the provision of his personal data and gives consent freely, willingly and in his own interest.
9. Conditions for the processing of personal data
9.1 Processing of personal data shall be subject to the consent of the data subject to the processing of their personal data.
9.2 Processing of personal data is necessary for achievement of the objectives stipulated in the international treaty of the Russian Federation or the law, for performance of 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 to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4 Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which the personal data subject is a party, as well as for conclusion of an agreement on the initiative of the personal data subject or an agreement, under which the personal data subject will be a beneficiary or guarantor.
9.5 Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially important objectives, provided that this does not violate the rights and freedoms of the personal data subject.
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.
10. Procedure for 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 to comply fully with the requirements of current legislation in the area of personal data protection.
10.1. The operator ensures the safety of personal data and takes all possible measures, which exclude access to personal data by unauthorised persons.
10.2 The personal data of the User will never, under no circumstances be transferred to third parties, except in cases related to the execution of the applicable laws or if the personal data subject has given consent to the Operator for the transfer of 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 firstname.lastname@example.org, 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 email to the Operator's email address email@example.com with the note "Withdrawal of consent to the processing of personal data".
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 that 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, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as identification of unlawful processing of personal data.
11. List of actions carried out by the operator with the personal data received
11.1. The operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers ( distribution, provision, access), anonymises, blocks, deletes and destroys 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.
12. Cross-border transfer of personal data
12.1 The operator is obliged to make sure that the foreign country, on the territory of which the personal data transfer is supposed to be carried out, provides reliable protection of the personal data subjects' rights before the start of the cross-border transfer of personal data.
12.2 The cross-border transfer of personal data to foreign countries, which do not meet the above requirements, may take place only if the personal data subject consents in writing to the cross-border transfer of his/her personal data and/or the execution of an agreement, 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 or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
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 e-mail at firstname.lastname@example.org.
14.2 This document will reflect any changes to the personal data processing policy of the Operator. The Policy remains in force without limit of time until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://SpineMedics.ru/privat.