Personal data processing policy
1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-ФЗ as of July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and establishes the procedure for processing personal data and measures to ensure the security of personal data taken by Individual Entrepreneur Olesia Aleksandrovna Churilina, TIN 325502933603 (hereinafter referred to as the “Operator”).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of human and citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all personal data that the Operator may receive about visitors to the website https://perevod-live.ru, including by filling out forms on the website, as well as to all personal data that the Operator may receive from personal data subjects at the Operator’s offices, via WhatsApp or Telegram at +7-964-63-603-63 or by e-mail: perevod-live@yandex.ru.
1.3. The User’s performance of the following actions means his/her consent to this Policy and signing the Consent to the processing of personal data (Appendix No. 1 or Appendix No. 2 hereto):
- use of the website https://perevod-live.ru,including filling out forms on the website;
- communication with the Operator via WhatsApp or Telegram at +7-964-63-603-63 or by e-mail: perevod-live@yandex.ru
- provision of personal data to the Operator at one of its offices.
1.4. In case of disagreement with the terms of the Policy, the User must stop using the Operator’s website, communicating with the Operator via WhatsApp or Telegram at +7-964-63-603-63 or by e-mail: perevod-live@yandex.ru.
2. Basic Definitions Used in the Policy
2.1. Automated Processing of Personal Data means processing of personal data using means of computer technology.
2.2. Website means a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://perevod-live.ru.
2.3. Processing of Personal Data means any action (operation) or set of actions (operations) performed using automation tools (or without using such tools) with personal data, including collection, recording, systematization, accumulation, storage, update (amendment, modification), extraction, use, transfer (provision, access), deletion of personal data.
2.4. Operator means Individual Entrepreneur Olesia Aleksandrovna Churilina, TIN 325502933603, a legal entity that independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.5. Personal Data means any information related directly or indirectly to a specific or determinable User of the website https://perevod-live.ruor a person communicating with the Operator via WhatsApp or Telegram at +7-964-63-603-63 or by e-mail: perevod-live@yandex.ru, or a person providing personal data to the Operator at one of its offices.
2.6. User means any visitor to the website https://perevod-live.ru or a person sending personal data to WhatsApp or Telegram at +7-964-63-603-63 or to e-mail: perevod-live@yandex.ru or providing personal data to the Operator at one of its offices.
2.7. Cross-Border Transfer of Personal Data means transfer of personal data to the territory of a foreign state, to a government body of a foreign state, to a foreign individual or foreign legal entity.
3. 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 User;
- if the User revokes his/her consent to the processing of personal data, the Operator has the right to continue processing personal data without the User’s consent where there are legal causes 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 Personal Data Law and its subordinate regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
- provide the User, at his/her request, with information regarding the processing of his/her personal data;
- organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure normally used to protect such information in existing business practices;
- respond to requests and inquiries from Users and their legal representatives in accordance with the requirements of the Personal Data Law;
- communicate to the authorized body in charge of the protection of the rights of personal data subjects, upon request of this body, the required information within 30 days from the date of receipt of such a request;
- publish or otherwise provide unlimited access to this Policy;
- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to it, deletion, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
- stop the transfer (provision, access) of personal data, stop processing and delete personal data in the manner and cases stipulated by the Personal Data Law;
- fulfill other obligations as provided for by the Personal Data Law.
4. Rights and Obligations of the User
4.1. The User has the right to:- receive information regarding the processing of his/her personal data, except for cases stipulated by federal laws. The information shall be provided to the User by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except for cases where there are legal causes for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- demand that the Operator update his/her personal data, block or delete 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 measures provided by law to protect his/her rights;
- revoke the consent to the processing of personal data;
- appeal to the authorized body in charge of the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing his/her personal data;
- exercise other rights provided for by the legislation of the Russian Federation.
- provide the Operator with reliable data about himself / herself;
- inform the Operator about update (amendment, change) of his/her personal data.
5. Subject Matter of the Personal Data Processing Policy
5.1. This Policy sets forth the Operator’s obligations to maintain confidentiality and ensure protection of the privacy of personal data that the User provides through the use of the website https://perevod-live.ru, including by filling out forms on the website, at the Operator’s offices, by communicating with the Operator via WhatsApp or Telegram at +7-964-63-603-63 or by e-mail: perevod-live@yandex.ru.
5.2. The website also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and others). The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (the saving of cookies and the use of JavaScript technology are enabled).
5.3. Any other personal information not specified above is subject to secure storage and non-dissemination, except for cases provided in clause 8.2. hereof.
5.4. The above data is hereinafter grouped in the text of the Policy under the general definition of Personal Data.
6. Principles of Personal Data Processing
6.1. Personal data is processed on a lawful and equitable basis.
6.2. The User independently decides to provide his/her personal data and gives consent freely, of his/her own free will and in his/her interests.
6.3. The Operator processes the User’s personal data only if it is filled in and/or sent by the User independently through special forms located on the website https://perevod-live.ru, provided and transferred at the Operator’s offices, sent to the Operator via e-mail or in WhatsApp and Telegram messengers. By filling in the relevant forms and/or transferring his/her personal data to the Operator, the User expresses his/her consent to this Policy.
6.4. 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 collecting personal data is not allowed.
6.5. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
6.6. Only personal data that meets the purposes of its processing is subject to processing.
6.7. The content and volume of personal data being processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of its processing is not allowed.
6.8. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure their adoption to delete or update incomplete or inaccurate data.
7. Information on Personal Data Processing, Classified by Processing Purposes
7.1. Purpose of Data Processing:Provision of written and oral translation services to individuals and legal entities
Categories of personal data to be processed:surname, given name, patronymic; year of birth; month of birth; day of birth; place of birth; marital status; social status; property status; income; gender; e-mail address; residential address; registration address; telephone number; SNILS; TIN; citizenship; identity document details; driver’s license details; details of document certifying identity outside the Russian Federation; document details contained in the birth certificate; bank account number; personal account number; profession; position; information on work experience (including length of service, information on current employment with the name and bank account of the organization); military service status, military registration details; educational background; photo and video image of the face.
Categories of subjects whose personal data is processed:Counterparties; Counterparty representatives; Clients; Website visitors.
Legal cause for personal data processing:personal data is processed with the consent of the personal data subject to the processing of his/her personal data; Federal Law No. 152-ФЗ “On Personal Data”, the Civil Code of the Russian Federation.
List of actions:collection; recording; systematization; accumulation; storage; update (amendment, modification); extraction; use; transfer (provision, access); deletion.
The Operator carries out automated processing of personal data with or without receipt and/or transmission of the obtained information via information and telecommunication networks.
7.2. Purpose of Data Processing:Recruitment of personnel (job seekers) for vacant positions of the Operator
Categories of personal data to be processed:surname, given name, patronymic; year of birth; month of birth; day of birth; place of birth; marital status; income; gender; e-mail address; residential address; registration address; telephone number; SNILS; TIN; citizenship; identity document details; profession; information on work experience (including length of service, information on current employment with the name and bank account of the organization); military service status, military registration details; educational background; photo and video image of the face.
Categories of subjects whose personal data is processed:Job seekers.
Legal cause for personal data processing:personal data is processed with the consent of the personal data subject to the processing of his/her personal data; Federal Law No. 152-ФЗ “On Personal Data”, the Labour Code of the Russian Federation.
List of actions:collection; recording; systematization; accumulation; storage; update (amendment, modification); extraction; use; transfer (provision, access); deletion.
The Operator carries out automated processing of personal data with or without receipt and/or transmission of the obtained information via information and telecommunication networks.
8. Procedure for Collecting, Storing, Transferring and Other Types of Processing Personal Data
8.1. The Operator shall ensure the safety of personal data and take all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given the Operator his/her consent to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3.If any inaccuracies are detected in the personal data, the User can update it independently by sending the Operator a notice to the Operator’s e-mail address perevod-live@yandex.ru with the subject line “Update of personal data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or applicable law.
The User may revoke his/her consent to the processing of personal data at any time by sending the Operator a notice via e-mail to the Operator’s e-mail address perevod-live@yandex.ru with the subject line “Revocation 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 the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to independently and promptly familiarize themselves with the said documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. The Operator shall ensure the confidentiality of personal data when processing personal data.
8.7. The Operator shall store personal data in a form that allows the User to be identified and for no longer than it is required by the purposes of processing the personal data, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor, or the consent of the personal data subject.
8.8. The condition for termination of the personal data processing may be the achievement of the purposes of personal data processing, the expiration of the User’s consent or the revocation of the consent by the User, as well as the detection of illegal processing of personal data.
9. Ensuring the Security of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
The Operator independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Federal Law “On Personal Data” and its subordinate regulatory legal acts, unless otherwise provided by the said law or other federal laws.
Ensuring the security of personal data is achieved, in particular, as follows:
- by appointing a person responsible for organizing the processing of personal data;
- by developing local regulations governing the work with personal data (Personal Data Processing Policy);
- by publishing a document defining the personal data processing policy on the website;
- by implementing internal control over the compliance of personal data processing with the legislation of the Russian Federation;
- by assessing the harm that may be caused to personal data subjects in the event of a violation of the law;
- by identifying threats to the security of personal data when processing it in personal data information systems;
- by applying organizational and technical measures to ensure the security of personal data when processing it in information systems that are necessary to meet the requirements for the protection of personal data;
- by applying information security tools that have undergone the established procedure for conformity assessment;
- by assessing the effectiveness of measures taken to ensure the security of personal data before putting the personal data information system into operation;
- by accounting personal data machine carriers;
- by detecting facts of unauthorized access to personal data and taking relevant measures;
- by restoring personal data modified or deleted due to unauthorized access to it;
- by physical security of the information system (technical means and information carriers), providing for control of access to the premises of the information system;
- by establishing rules for access to personal data processed in the personal data information system, as well as ensuring the accounting of all actions performed with personal data in the information system;
- by monitoring the measures taken to ensure the security of personal data and the level of protection of information systems.
10. Cross-Border Transfer of Personal Data
The Operator does not carry out cross-border transfer of personal data.
11. Liability of the Parties
11.1. The Operator who has failed to fulfill its obligations to process personal data shall be liable for the losses incurred by the User in connection with the illegal use of personal data, in accordance with the legislation of the Russian Federation, except for the cases provided for in clauses 8.2. and 11.2. hereof.
11.2. In the event of loss or disclosure of confidential information, the Operator shall not be liable if this confidential information:
- became publicly known prior to its loss or disclosure.
- was received from a third party prior to its receipt by the Operator.
- was disclosed with the consent of the User.
11.3. The User shall be fully liable for failure to comply with the requirements of the legislation of the Russian Federation, including, but not limited to, laws on advertising, on the protection of copyright and related rights, on the protection of trademarks and service marks, including full liability for the content and form of materials.
11.4. The User agrees that the information provided to him/her as part of the Operator’s website may constitute an item of intellectual property, the rights to which are protected and belong to the Operator or partners who post such information on the Operator’s website. The User shall not have the right to change, lease, transfer on loan, sell, distribute or create derivative works based on such Content (in whole or in part), except for cases when such actions have been expressly permitted in writing by the owners of such Content in accordance with the terms of a separate agreement.
11.5. The Operator shall not be liable for any direct or indirect damages arising from the use or inability to use the website or individual services; unauthorized access to the User’s communications; statements or behaviour of any third party on the website.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail: perevod-live@yandex.ru.
12.2. 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.
12.3.The current version of the Policy is freely available on the Internet at https://perevod-live.ru.
Appendix No. 1
Consent to the Processing of Personal Data of a User / Client
This consent to the processing of personal data applies to the provision of his/her data by the personal data subject to Individual Entrepreneur Olesia Aleksandrovna Churilina, TIN 325502933603(hereinafter referred to as the “Operator”), and to its processing by the Operator, in accordance with Federal Law No. 152-ФЗ as of July 27, 2006 “On Personal Data”.
Purpose of data processing:Provision of written and oral translation services to individuals and legal entities
Categories of personal data for the processing of which consent is given (depending on the content of the document being translated):surname, given name, patronymic; year of birth; month of birth; day of birth; place of birth; marital status; social status; property status; income; gender; e-mail address; residential address; registration address; telephone number; SNILS; TIN; citizenship; identity document details; driver’s license details; details of document certifying identity outside the Russian Federation; document details contained in the birth certificate; bank account number; personal account number; profession; position; information on work experience (including length of service, information on current employment with the name and bank account of the organization); military service status, military registration details; educational background; photo and video image of the face.
List of actions with personal data for which consent is given:collection; recording; systematization; accumulation; storage; update (amendment, modification); extraction; use; transfer (provision, access); deletion;
Period during which this consent is valid:5 (five) years from the date of signing this consent, or until the date of revocation of the consent in writing, whichever comes first.
This is a specific, subject, informed, conscious and unambiguous consent.
In the event that I provide personal data of third parties, including contact information, I confirm that the personal data subject has been notified of the processing of his/her personal data by the Operator.
I hereby give my consent to the use of the provided personal data for sending the requested information by the Operator via information communication systems, SMS, by e-mail, by the specified phone number, via WhatsApp and Telegram.
Appendix No. 2
Consent to the Processing of Personal Data of a Job Seeker
This consent to the processing of personal data applies to the provision of his/her data by the personal data subject to Individual Entrepreneur Olesia Aleksandrovna Churilina, TIN 325502933603 (hereinafter referred to as the “Operator”), and to its processing by the Operator, in accordance with Federal Law No. 152-ФЗ as of July 27, 2006 “On Personal Data”.
Purpose of data processing:Recruitment of personnel (job seekers) for vacant positions of the Operator
Categories of personal data for the processing of which consent is given:surname, given name, patronymic; year of birth; month of birth; day of birth; place of birth; marital status; income; gender; e-mail address; residential address; registration address; telephone number; SNILS; TIN; citizenship; identity document details; profession; information on work experience (including length of service, information on current employment with the name and bank account of the organization); military service status, military registration details; educational background; photo and video image of the face.
List of actions with personal data for which consent is given:collection; recording; systematization; accumulation; storage; update (amendment, modification); extraction; use; transfer (provision, access); deletion;
Period during which this consent is valid:5 (five) years from the date of signing this consent, or until the day of revocation of the consent in writing, whichever comes first.
This is a specific, subject, informed, conscious and unambiguous consent.
In the event that I provide personal data of third parties, including contact information, I confirm that the personal data subject has been notified of the processing of his/her personal data by the Operator.
I hereby give my consent to the use of the provided personal data for sending the requested information by the Operator via information communication systems, SMS, by e-mail, by the specified phone number, via WhatsApp and Telegram.