Personal data processing policy
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-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Act) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by COMPLICERTE TECHNOLOGIES RUS Limited Liability Company (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 human and civil rights and freedoms when processing his personal data, including the protection of his rights to privacy and personal and family secrets.
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- 1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about website visitors https://kt.team.
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2. The main concepts used in the Policy
2.1. Automated processing of personal data is the processing of personal data using computer technology.
2.2. Blocking personal data is a temporary cessation of personal data processing (except when processing is necessary to clarify personal data).
2.3. A website is a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at a network address .
2.4. A personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data is actions that make it impossible to determine, without using additional information, whether personal data belongs to a particular User or other personal data subject.
2.6. Personal data processing is any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator is a state body, a municipal body, a legal entity or an individual that, independently or jointly with other persons, organizes and/or processes personal data, as well as determines the purposes of personal data processing, the 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 specific or identifiable Website User https://kt.team.
2.9. Personal data allowed by a personal data subject for distribution is personal data to which an unlimited number of persons have access provided by the personal data subject by giving consent to the processing of personal data allowed by the personal data subject for distribution in accordance with the procedure provided for by the Personal Data Act (hereinafter referred to as personal data permitted for distribution).
2.10. User — any website visitor https://kt.team.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a certain circle of persons.
2.12. Dissemination of personal data is any action aimed at disclosing personal data to an indefinite number of persons (transferring personal data) or at familiarizing an unlimited number of people with personal data, including publishing personal data in the media, posting it on information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to a foreign state authority, a foreign individual or a foreign legal entity.
2.14. Personal data destruction is any action that results in the destruction of personal data irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and/or destroying material carriers of personal data.
2.2. Blocking personal data is a temporary cessation of personal data processing (except when processing is necessary to clarify personal data).
2.3. A website is a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at a network address .
2.4. A personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data is actions that make it impossible to determine, without using additional information, whether personal data belongs to a particular User or other personal data subject.
2.6. Personal data processing is any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator is a state body, a municipal body, a legal entity or an individual that, independently or jointly with other persons, organizes and/or processes personal data, as well as determines the purposes of personal data processing, the 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 specific or identifiable Website User https://kt.team.
2.9. Personal data allowed by a personal data subject for distribution is personal data to which an unlimited number of persons have access provided by the personal data subject by giving consent to the processing of personal data allowed by the personal data subject for distribution in accordance with the procedure provided for by the Personal Data Act (hereinafter referred to as personal data permitted for distribution).
2.10. User — any website visitor https://kt.team.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a certain circle of persons.
2.12. Dissemination of personal data is any action aimed at disclosing personal data to an indefinite number of persons (transferring personal data) or at familiarizing an unlimited number of people with personal data, including publishing personal data in the media, posting it on information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to a foreign state authority, a foreign individual or a foreign legal entity.
2.14. Personal data destruction is any action that results in the destruction of personal data irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and/or destroying material carriers of personal data.
3. The main rights and obligations of the Operator
3.1. The operator has the right to:
3.1.1. receive reliable information and/or documents containing personal data from the subject of personal data;
3.1.2. if the personal data subject withdraws consent to the processing of personal data, as well as a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Act;
3.1.3. independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Act and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Act or other federal laws.
3.2. The operator is obliged to:
3.2.1. provide the personal data subject, at his request, with information regarding the processing of his personal data;
3.2.2. organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
3.2.3. respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Act;
3.2.4. report the necessary information to the authorized body for the protection of the rights of personal data subjects at the request of this body within 10 days from the date of receipt of such a request;
3.2.5. publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
3.2.6. take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
3.2.7. stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Act;
3.2.8. perform other duties provided for by the Personal Data Act.
3.1.1. receive reliable information and/or documents containing personal data from the subject of personal data;
3.1.2. if the personal data subject withdraws consent to the processing of personal data, as well as a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Act;
3.1.3. independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Act and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Act or other federal laws.
3.2. The operator is obliged to:
3.2.1. provide the personal data subject, at his request, with information regarding the processing of his personal data;
3.2.2. organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
3.2.3. respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Act;
3.2.4. report the necessary information to the authorized body for the protection of the rights of personal data subjects at the request of this body within 10 days from the date of receipt of such a request;
3.2.5. publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
3.2.6. take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
3.2.7. stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Act;
3.2.8. perform other duties provided for by the Personal Data Act.
4. The main rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
4.1.1. receive information regarding the processing of his personal data, except as provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Act;
4.1.2. require the operator to clarify his personal data, block or destroy them 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 for by law to protect their rights;
4.1.3. require prior consent when processing personal data in order to promote goods, works and services on the market;
4.1.4. to withdraw consent to the processing of personal data, as well as to request the termination of personal data processing;
4.1.5. appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator's illegal actions or omissions when processing his personal data;
4.1.6. to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
4.2.1. provide the Operator with accurate information about yourself;
4.2.2. inform the Operator about clarifying (updating, changing) your personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
4.1.1. receive information regarding the processing of his personal data, except as provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Act;
4.1.2. require the operator to clarify his personal data, block or destroy them 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 for by law to protect their rights;
4.1.3. require prior consent when processing personal data in order to promote goods, works and services on the market;
4.1.4. to withdraw consent to the processing of personal data, as well as to request the termination of personal data processing;
4.1.5. appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator's illegal actions or omissions when processing his personal data;
4.1.6. to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
4.2.1. provide the Operator with accurate information about yourself;
4.2.2. inform the Operator about clarifying (updating, changing) your personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined and legitimate goals. Personal data processing that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data that are processed for purposes that are incompatible with each other.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and volume of personal data processed correspond to the stated processing goals. The processed personal data may not be redundant in relation to the stated purposes of their processing.
5.6. When processing personal data, it is ensured that personal data is accurate, sufficient, and, if necessary, relevant in relation to the purposes of processing personal data. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored 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 for storing personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data is destroyed or anonymized when the processing goals are achieved or if it is no longer necessary to achieve these goals, unless otherwise provided by federal law.
5.2. The processing of personal data is limited to achieving specific, predetermined and legitimate goals. Personal data processing that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data that are processed for purposes that are incompatible with each other.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and volume of personal data processed correspond to the stated processing goals. The processed personal data may not be redundant in relation to the stated purposes of their processing.
5.6. When processing personal data, it is ensured that personal data is accurate, sufficient, and, if necessary, relevant in relation to the purposes of processing personal data. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored 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 for storing personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data is destroyed or anonymized when the processing goals are achieved or if it is no longer necessary to achieve these goals, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing
informing the User by sending emails and arranging phone calls
Personal data
email address;
phone numbers;
last name and first name
Legal grounds
Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ of July 27, 2006
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data. Sending newsletters to an email address
7. Personal data processing conditions
7.1. Personal data is processed with the consent of the personal data subject to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a judicial act, an act of another body or official that is enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as to conclude an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data is processed, access to which an unlimited number of persons is provided by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a judicial act, an act of another body or official that is enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as to conclude an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data is processed, access to which an unlimited number of persons is provided by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. The procedure for collecting, storing, transferring and other types of processing 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 current legislation in the field of personal data protection.
8.1. The operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of 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 contract.
8.3. If inaccuracies in personal data are found, the User can update them independently by sending a notification to the Operator to the Operator's email address corporate@kt-team.ru → marked “Updating 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 current legislation.
The user can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator's email address corporate@kt-team.ru → marked “Revocation of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The operator is not responsible for the actions of third parties, including the service providers listed in this paragraph.
8.6. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or processing conditions (except for obtaining access) of personal data allowed for distribution do not apply when personal data is processed for state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the operator ensures the confidentiality of personal data.
8.8. The operator stores personal data in a form that makes it possible to identify the subject of personal data for no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. The condition for the termination of personal data processing may be the achievement of the goals of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the requirement to stop processing personal data, as well as the detection of illegal processing of personal data.
8.1. The operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of 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 contract.
8.3. If inaccuracies in personal data are found, the User can update them independently by sending a notification to the Operator to the Operator's email address corporate@kt-team.ru → marked “Updating 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 current legislation.
The user can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator's email address corporate@kt-team.ru → marked “Revocation of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The operator is not responsible for the actions of third parties, including the service providers listed in this paragraph.
8.6. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or processing conditions (except for obtaining access) of personal data allowed for distribution do not apply when personal data is processed for state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the operator ensures the confidentiality of personal data.
8.8. The operator stores personal data in a form that makes it possible to identify the subject of personal data for no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. The condition for the termination of personal data processing may be the achievement of the goals of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the requirement to stop processing personal data, as well as the detection of illegal processing of personal data.
9. The list of actions performed by the Operator with the received personal data
9.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, access), anonymizes, blocks, deletes and destroys personal data.
9.2. The operator performs automated processing of personal data with or without receiving and/or transmitting the information received via information and telecommunication networks.
9.2. The operator performs automated processing of personal data with or without receiving and/or transmitting the information received via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before starting activities involving the cross-border transfer of personal data, the operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to transfer personal data across borders (such a notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the operator is obliged to obtain relevant information from foreign authorities, foreign individuals, foreign legal entities that plan to transfer personal data across borders.
10.2. Before submitting the above notification, the operator is obliged to obtain relevant information from foreign authorities, foreign individuals, foreign legal entities that plan to transfer personal data across borders.
11. Personal data confidentiality
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.
12. Final provisions
12.1. The user can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail corporate@kt.team→.
12.2. This document will reflect any changes in 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://kt.team/service/policy.
12.2. This document will reflect any changes in 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://kt.team/service/policy.
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