1. General provisions
This policy of Limited Liability Company "Media Capital" LLC, OGRN: 1217800151909, on processing of personal data is written in accordance with the requirements of the Federal Law of 27.07.2006 Nr. No.152-FZ "On Personal Data" (hereinafter - the "Personal Data Law") and determines the order of processing of personal data and measures to ensure security of personal data, taken by "Media Capital" LLC (hereinafter - the "Operator") in processing of personal data.
1.1 The Operator's main goal and condition of its activity is observance of human and citizen's rights and freedoms during processing of their personal data, including protection of rights to privacy, personal and family secrets.
1.2 The present policy of the Operator concerning processing of personal data (further - Policy) is applied to all information, which the Operator can receive about visitors of the website https://mcapital.agency, and also operates in relation to all personal data, which is processed by "Media Capital" LLC as the Operator.
2. Basic concepts used in the Policy
2.1 Automated processing of personal data - processing of personal data by means of computer equipment.
2.2 Blocking of personal data - temporary suspension of processing of personal data (except in cases where the processing is necessary to clarify personal data)
2.3 Website means 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://mcapital.agency.
2.4 Personal Data Information System - a set of personal data contained in databases of personal data, and information technology and technical means ensuring their processing.
2.5 Anonymization of personal data - actions, as a result of which it is impossible to determine, without using additional information, whether the personal data belongs to a particular User or another subject of personal data (hereinafter also - the subject).
2.6 Processing of personal data - any action (operation) or set of actions (operations) with personal data performed with or without the use of automation means, including: collection; recording; systematization; accumulation; storage; clarification (updating, modification); extraction; use; transfer (distribution, provision, access); depersonalization; blocking; erasure; destruction of personal data.
2.7. Personal Data Operator (Operator) - a state body, municipal body, legal entity or individual, independently or jointly with other persons, organizing and (or) carrying out processing of personal data, as well as determining the purpose of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information related directly or indirectly to a certain or defined User of the website https://mcapital.agency, or any other individual, whose personal data is processed by LLC "Media Capital" as the Operator.
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 the Law on Personal Data (hereinafter - Personal Data, allowed for distribution).
2.10. User - any visitor to the https://mcapital.agency website.
2.11. Provision of Personal Data - actions aimed at disclosure of Personal Data to a certain person or a certain circle of persons.
2.12. Dissemination of Personal Data - any action aimed at disclosure of Personal Data to an indefinite range of persons (transfer of Personal Data), or to make Personal Data available to an unlimited number of persons, including disclosure of Personal Data in the media, posting in information and telecommunications networks or providing access to Personal Data in any other way.
2.13. Cross-border transfer of Personal Data means transfer of 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 resulting in the destruction of Personal Data irretrievably with the impossibility of further restoration of the Personal Data content in the Personal Data information system and (or) destruction of tangible media of Personal Data.
3. The Operator's basic rights and obligations
3.1 The operator has the right:
- Receive from the subject of personal data reliable information and/or documents containing Personal Data;
- In case of revocation of the personal data subject's consent to the Personal Data Processing, the Operator has the right to continue the Personal Data Processing without the personal data subject's consent, on the grounds set forth in the Personal Data Law;
- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws
- Assign Processing of Personal Data to another person with the consent of the Personal Data subject, unless otherwise provided for by the Federal Law, based on a contract to be concluded with such person. The person processing Personal Data on behalf of the Operator must comply with the principles and rules of Personal Data processing stipulated by the Personal Data Law;
3.2 The Operator shall:
- Provide the subject of personal data at his/her request with information relating to the processing of his/her Personal Data;
- Organize Personal Data Processing in the manner prescribed by applicable laws of the Russian Federation;
- To respond to requests and inquiries of subjects of personal data and their legal representatives, in accordance with the requirements of the Law on Personal Data;
- Inform the authorized agency for protection of rights of subjects of personal data, upon request of such 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, supply, distribution of personal data, as well as other unlawful acts in relation to Personal Data
- Cease transfer (distribution, provision, access) of Personal Data, stop Processing and destroy Personal Data in the manner and cases provided by the Personal Data Law;
- Perform other obligations under the Personal Data Law.
4. The main rights and obligations of subjects of personal data
4.1 Client of personal data has the right:
- To receive information relating to the processing of his personal data, except in cases provided for by federal laws. 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 the disclosure of such Personal Data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
- To demand from the Operator the clarification of his Personal Data, their Blocking or Destruction if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and to take statutory measures to protect his rights;
- to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and 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 Subjects of personal data shall:
- provide the Operator with reliable data about themselves;
- Inform the Operator of the clarification (updating, modification) of their Personal Data.
4.3 Persons, who provided the Operator with false information about themselves, or information about another subject of personal data 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 or subject of personal data
5.1. Surname, first name, patronymic.
5.2. E-mail address.
5.4. ear, month, date and place of birth.
5.5. Images (photos).
5.6. Information about nationality.
5.7. Details of personal identification document.
5.8. Identification number of the taxpayer, date of registration, details of the certificate of registration with the tax authority.
5.9 Address of actual residence and registration at the place of residence and (or) at the place of stay.
5.10. The site also collects and processes impersonal data about visitors (including cookies) using Internet statistical services (Yandex Metrika and Google Analytics, etc.).
5.11. The above-mentioned data is hereinafter referred to in the Policy as Personal Data.
5.12. The Operator does not process special categories of Personal Data relating to race, ethnicity, political views, religious or philosophical beliefs, and intimate life.
5.13. Processing of personal data, allowed for dissemination, from among special categories of Personal Data specified in Part 1 of Article 10 of the Personal Data Law, is allowed if the prohibitions and conditions specified in Article 10.1 of the Personal Data Law are observed, or if the subject of personal data has given his consent in writing to the processing of such data.
5.14 The User's (subject's) consent to the processing of personal data allowed for dissemination shall be executed separately from other consents to the processing of his/her personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. The requirements for the content of such consent shall be established by the competent authority for the protection of personal data subjects' rights.
5.14.1 The consent to the processing of personal data allowed for distribution, the User (subject) provides to the Operator directly.
5.14.2 The Operator shall, within three working days of receiving the above consent from the User (subject), publish information about the processing conditions, prohibitions and conditions on the processing of the Personal Data permitted for distribution to an unlimited number of persons.
5.14.3 The transfer (distribution, provision, access) of Personal Data, authorized by the subject of personal data for distribution, must be terminated at any time at the request of the subject of personal data. This requirement must include the surname, first name, patronymic (if any), contact information (phone number, e-mail address or mailing address) of the subject of personal data, as well as a list of Personal Data whose processing is to be terminated. The Personal Data specified in this request may only be processed by the Operator to which it is sent.
5.14.4 The consent to the processing of Personal Data, which is permitted for distribution, ceases to have effect from the moment of receipt by the Operator of the request, specified in paragraph 5.14.3 of this Policy in respect of the Processing of Personal Data.
6. Principles of Personal Data Processing
6.1 Processing of personal data shall be carried out on a lawful and fair basis.
6.2 Processing of Personal Data is limited to achieving specific, predetermined and legitimate purposes. Processing of Personal Data that is incompatible with the purposes of Personal Data collection shall not be permitted.
6.3 It shall not be permitted to combine databases containing Personal Data processed for purposes incompatible with each other.
6.4 Only Personal Data that meet the purposes of its processing shall be processed.
6.5 The content and scope of processed Personal Data shall be consistent with the stated Processing purposes. The redundancy of processed Personal Data in relation to the stated processing objectives shall not be allowed. 6.6.
6.6 When processing Personal Data, the Operator shall ensure the accuracy of Personal Data, their sufficiency and, if necessary, relevance in relation to the purpose of Personal Data processing. The Operator shall take 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 to identify the subject of Personal Data no longer than 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 subject of Personal Data is a party, a beneficiary or a guarantor. Processed Personal Data shall be destroyed or depersonalized upon attainment of the processing objectives or when it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.
7. Purposes of Processing of Personal Data
7.1 The purpose of Processing of Personal Data of the User (subject):
- informing the User by sending e-mails;
- Conclusion, execution and termination of civil law contracts;
- providing access to the User to the services, information and/or materials contained on the website https://mcapital.agency.
7.2 Also the Operator has the right to send notifications about new products and services, special offers and different events to the User (subject). The User (subject) can always refuse to receive information messages by sending an email to the Operator at firstname.lastname@example.org with the note "Refuse notifications about new products and services and special offers".
7.3 The anonymized data of the Users, collected with the help of the Internet statistics services, serves for collecting information about the Users' actions on the site, improving the quality of the site and its content.
8. Legal Basis for Processing of Personal Data
8.1 The legal basis for the processing of personal data by the Operator are:
- statutory (constitutive) documents of the Operator;
- Contracts concluded between the Operator and the subject of personal data;
- Federal laws, other regulatory legal acts in the field of Personal Data protection;
- The consent of the Users (subjects) to the processing of their personal data, as well as their consent to the processing of personal data allowed for dissemination.
8.2. The Operator processes the Personal Data of the User (subject) only if they are filled in and/or sent by the User (subject) themselves through the special forms located on the website https://mcapital.agency or sent to the Operator via e-mail. By filling out the relevant forms and/or sending his/her personal data to the Operator the User (subject) expresses his/her consent to this Policy.
8.4 The subject of personal data independently decides to provide his personal data and gives his consent freely, willingly and in his own interest.
9. Conditions for processing of personal data
9.1 Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2 Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform 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 to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially important goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6 Processing of personal data, access to which is provided by the subject of personal data or at his/her request (hereinafter - publicly accessible personal data).
9.7 Processing of personal data subject to publication or compulsory disclosure in accordance with the federal law.
10. Procedure for Collection, Storage, Transfer and Other Processing of Personal Data
Security of Personal Data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully meet the requirements of applicable laws in the area of Personal Data protection.
10.1. The Operator shall ensure security of Personal Data and shall take all possible measures to prevent access to Personal Data by unauthorized persons.
10.2 Personal data of the User (subject) will never, under no circumstances be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract or for other necessary purposes, not contradicting the current legislation.
10.3 In case of detection of inaccuracies in the Personal Data, the User may update them on their own by sending a notice to the Operator's e-mail address email@example.com with the note "Updating of Personal Data".
10.4 The term of Processing of Personal Data shall be determined by achieving the purposes for which the Personal Data was collected, unless another term is stipulated by contract or applicable law.
The user (subject) may withdraw their consent to the processing of personal data at any time by sending a notice via e-mail to the Operator's e-mail address firstname.lastname@example.org, marked "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 obtaining 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 makes it possible to identify the subject of Personal Data no longer than 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 subject of Personal Data is a party, a beneficiary or a guarantor.
10.9. The condition for termination of Personal Data Processing may be achievement of the Personal Data Processing objectives, expiry of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as detection of unlawful Personal Data Processing.
11. List of Actions Performed by the Operator with Personal Data Received
11.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (distribution, provision, access), anonymize, block, delete and destroy Personal Data.
11.2 The Operator shall perform automated processing of Personal Data with or without receipt and/or transmission of received information via information and telecommunication networks.
12. cross-border transfer of Personal Data
12.1 Before trans-border transfer of Personal Data, the Operator must ensure that the foreign country to whose territory the transfer of Personal Data is intended to take place provides reliable protection of Personal Data subjects' rights.
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 has consented in writing to the cross-border transfer of his/her Personal Data and/or to the performance of an agreement, to which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons obtaining access to Personal Data must not disclose to third parties and must not disseminate Personal Data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final provisions
14.1 The User (data subject) may obtain any explanations on questions of interest regarding the processing of their personal data by contacting the Operator by e-mail at email@example.com.
14.2 This document will reflect any changes in the Policy of the Limited Liability Company "Media Capital" in relation to the processing of personal data. The Policy shall be valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://mcapital.agency/privacy.