Privacy Policy Regarding Personal Data Processing
1. General Provisions
This personal data processing policy is developed 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 Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by AA2G1 LTD (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of rights to privacy, personal, and family secrets.
1.2. This policy of the Operator regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://aa2g1ltd.com.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing technology.
2.2. Blocking of personal data – temporary cessation of processing personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases that provide their availability on the Internet at the network address https://aa2g1ltd.com.
2.4. Information system of personal data – a collection of personal data contained in databases, and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data – actions that result in the inability to determine without the use of additional information the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual who 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 subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://aa2g1ltd.com.
2.9. Personal data permitted by the subject of personal data for distribution – personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent to the processing of personal data permitted for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User – any visitor to the website https://aa2g1ltd.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in the media, placement in 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 authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions that result in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the information system of personal data and/or the destruction of physical carriers of personal data.
3. Main 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 subject of personal data;
– in case of withdrawal of consent to the processing of personal data by the subject, continue processing personal data without the consent of the subject if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
– provide the subject of personal data, upon request, with information regarding the processing of their personal data;
– organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
– respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide the authorized body for the protection of the rights of subjects of personal data with the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions 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 provided for by the Personal Data Law;
– fulfill other obligations provided for by the Personal Data Law.
4. Main Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
– receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data related to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
– demand from the Operator the clarification of their personal data, their blocking, or destruction in case the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
– set conditions for prior consent when processing personal data for the purpose of promoting goods, works, and services;
– withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when processing their personal data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
– provide the Operator with reliable data about themselves;
– inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who provided the Operator with unreliable information about themselves or information about another subject of personal data without the latter's consent are liable in accordance with the legislation of the Russian Federation
5. The Operator May Process the Following Personal Data of the User
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized data about visitors (including "cookie" files) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The above-mentioned data is collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data related to racial or ethnic origin, political views, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data permitted for distribution from special categories of personal data specified in part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for 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 is obtained separately from other consents for the processing of their personal data. The conditions provided for, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.8.1 The consent to the processing of personal data permitted for distribution is provided by the User directly to the Operator.
5.8.2 The Operator is obliged to publish information about the conditions of processing, the presence of prohibitions, and conditions for processing personal data permitted for distribution to an unlimited number of persons within three working days from the date of receipt of the User's consent.
5.8.3 The transfer (distribution, provision, access) of personal data permitted for distribution by the subject of personal data must be ceased at any time at the request of the subject of personal data. This request must include the last name, first name, patronymic (if available), contact information (phone number, email address, or postal 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 whom it is directed.
5.8.4 The consent to the processing of personal data permitted for distribution ceases to be valid upon receipt by the Operator of the request specified in paragraph 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
6.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
6.4. Only personal data that meets the purposes of their processing shall be processed.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of their processing is not permitted.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, of which the subject of personal data is a party, a beneficiary, or a guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data includes:
– informing the User by sending emails;
– concluding, executing, and terminating civil law contracts;
– providing the User with access to services, information, and/or materials contained on the website https://aa2g1ltd.com.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the Operator at the email address info@aa2g1ltd.com with the subject «Refusal of notifications about new products and services and special offers».
7.3. Anonymized data of Users collected through internet statistics services is used to gather information about Users' actions on the site, improve the quality of the site and its content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for the processing of personal data by the Operator include:
– Federal Law "On Information, Information Technologies, and Information Protection" No. 149-FZ of July 27, 2006;
– federal laws and other regulatory legal acts in the field of personal data protection;
– consents of Users for the processing of their personal data, for the processing of personal data permitted for distribution.
8.2. The Operator processes the personal data of the User only if they are filled out and/or sent by the User independently through special forms located on the website https://aa2g1ltd.com or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (including the saving of "cookie" files and the use of JavaScript technology).
8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions for Processing Personal Data
9.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data.
9.2. The 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 functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another authority or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, or for the performance of a contract in which the subject of personal data is a beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
9.5. The 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 significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. The processing of personal data is carried out for which access has been provided to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
9.7. The processing of personal data that is subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for Collection, Storage, Transfer, and Other Types of Processing 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 current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address info@aa2g1ltd.com with the subject «Update of Personal Data».
10.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different term is provided for by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@aa2g1ltd.com with the subject «Withdrawal of Consent to Process Personal Data».
10.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves in a timely manner with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
10.6. The prohibitions established by the subject of personal data on the transfer (except for providing access) and on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data during processing.
10.8. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, of which the subject of personal data is a party, a beneficiary, or a guarantor.
10.9. The conditions for terminating the processing of personal data may include the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, or the withdrawal of consent by the subject of personal data, as well as the detection of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information through information and telecommunications networks or without such transmission.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to which the transfer of personal data is intended provides reliable protection of the rights of subjects of personal data.
12.2. The cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out if there is written consent from the subject of personal data for the cross-border transfer of their personal data and/or for the performance of a contract to which the subject of personal data is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at info@aa2g1ltd.com.
14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at the address https://aa2g1ltd.com/personaldata.