1 General provisions
This policy of personal data processing is compiled in accordance with the requirements of the Federal Law of 27.07.2006. No152-ФЗ "On Personal Data" (hereinafter - the Law on Personal Data) and determines the order of processing of personal data and measures to ensure security of personal data undertaken by Media Consult LLC (hereinafter - the Operator).
1.1 The Operator's most important purpose 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 Operator's personal data processing policy (hereinafter the "Policy") applies to all information that the Operator may receive about visitors to https://blackbeltmedia.ru
2. basic concepts used in the policy
2.1 Automated processing of personal data is the processing of personal data by means of computer technology.
2.2 Blocking of personal data - temporary suspension of processing of personal data (unless the processing is necessary to clarify the personal data).
2.3 Website - a collection of graphic and informational materials, as well as computer programs and databases, making them available on the Internet at the network address https://blackbeltmedia.ru
2.4 Personal data information system - a set of personal data contained in databases of personal data and information technologies and technical means ensuring its processing.
2.5 Impersonalisation of personal data - actions that make it impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another subject of personal data.
2.6 Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7 Operator - a state body, municipal authority, legal entity or natural person, independently or together with other persons, arranging and (or) carrying out the processing of personal data, as well as determining 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 an identified or identifiable User of https://blackbeltmedia.ru
2.9. Personal data permitted by the subject of personal data for dissemination - personal data, access to which is granted to an unlimited number of persons by the subject of personal data by giving consent to processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for dissemination).
2.10. A user is any visitor to the https://blackbeltmedia.ru website.
2.11. Provision of personal data means 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 number 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, 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 state authority, foreign natural person or foreign legal entity.
2.14. Destruction of personal data - any action resulting in the destruction of personal data irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) the destruction of tangible media of personal data.
3. the basic rights and obligations of the operator
3.1. The operator has the right:
- to obtain from the personal data subject reliable information and/or documents containing personal data;
- in case the personal data subject withdraws consent to personal data processing, the operator has the right to continue processing personal data without the consent of the personal data subject on the grounds specified in the Personal Data Law;
- to independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations
3.2 The operator shall:
- provide the personal data subject, at his/her request, with information relating to the processing of his/her personal data;
- organise the processing of personal data in accordance with the procedure established by applicable Russian legislation;
- respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- communicate to the competent authority for the protection of personal data subjects, upon request from that authority, the necessary
4. Basic rights and obligations of subjects of personal data
4.1. Personal data subjects have the right:
- to receive information relating to the processing of their personal data, except in cases provided 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 require the operator to clarify its personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated processing purpose, and to take statutory measures to protect its rights;
- to condition prior consent when processing personal data in order to market goods
4.2 Personal data subjects shall:
- provide the Operator with accurate data about themselves;
- inform the Operator about the clarification (updating, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without their consent shall be liable in accordance with Russian law.
5. The operator may process the following personal data of the User
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. The website also collects and processes anonymised visitor data (including cookies) using internet statistics services (Yandex Metrika and Google Analytics and others).
5.5. The above data are hereinafter referred to in the Policy under the general term Personal Data.
5.6. The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data, authorised for dissemination, from among the special categories of personal data specified in Article 10(1) of the Personal Data Law, shall be permitted if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are complied with.
5.8. The User's consent to the processing of personal data authorised for distribution shall be executed separately from other consents to the processing of their personal data. The conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. The requirements for the content of such consent shall be established by the authority responsible for the protection of personal data subjects' rights.
5.8.1 The User consents to the processing of personal data authorised for distribution directly to the Operator.
5.8.2 The Operator shall, within three working days of receipt of the above consent of the User, publish information about the conditions of processing, prohibitions and conditions on the processing of personal data authorised for distribution to an unlimited number of persons.
5.8.3 Transfer (dissemination, provision, access) of personal data permitted by the personal data subject for dissemination must be terminated at any time at the request of the personal data subject. This request must include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom the request has been sent.
5.8.4 Consent to the processing of personal data authorised for distribution shall terminate upon receipt by the Operator of the request referred to in section 5.8.3 of this Policy for the processing of personal data.
6. Principles of personal data processing
6.1 Personal data shall be processed lawfully and fairly.
6.2. Processing of personal data shall be 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 Databases containing personal data whose processing is incompatible with each other shall not be merged.
6.4. Only personal data that is suitable for the purposes for which it is processed shall be processed.
6.5 The content and scope of personal data processed shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.
6.6 When processing personal data, the accuracy of personal data, its sufficiency and, where necessary, its relevance in relation to the purposes of personal data processing shall be ensured.The operator shall take the 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 identification of the personal data subject for no longer than the purpose of personal data processing requires, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalised upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.
7. Purposes of personal data processing
7.1 Purpose of processing the User's personal data:
- informing the User by sending emails;
- concluding, executing and terminating civil law contracts;
- specifying details of orders and briefs for developing advertising campaigns.
7.2. The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User can always opt out of receiving information messages by sending an email to the Operator at love@blackbeltmedia.ru marked "Opt-out of notifications of new products and services and special offers".
7.3 The anonymised User data collected via Internet statistical services is used to gather information about Users' activities on the website and to improve the quality of the website and its content.
8. Legal basis for processing personal data
8.1. The legal grounds for the processing of personal data by the Operator are:
- the Operator's statutory (constituent) documents;
- agreements concluded between the Operator and the subject of personal data;
- federal laws, other regulatory legal acts in the field of personal data protection;
- Users' consent to process their personal data, to process personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if the User fills in and/or sends them himself via special forms located on the website https://bl_ckbeltmedi_.ru or sent to the Operator via e-mail. By filling in the relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to the surrendered Policy.
8.3 The Operator processes anonymised data about the User if this is permitted in the User's browser settings (cookie saving and the use of JavaScript technology are enabled).
8.4 The subject of personal data shall independently decide on the provision of his or her personal data and give consent freely, willingly and in his or her own interest.
9. Terms of personal data processing
9.1. The processing of personal data shall be subject to the consent of the personal data subject to the processing of his/her personal data.
9.2 The processing of personal data is necessary in order to achieve the objectives,
provided by an international treaty of the Russian Federation or by law, to carry out 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 authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4 Processing of personal data is necessary in order to fulfil an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as to conclude an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5 The processing of personal data is necessary in order to pursue legitimate interests of the operator or third parties or to achieve socially important objectives, provided that the rights and freedoms of the personal data subject are not infringed thereby.
9.6 Personal data shall be processed to which access is granted to an unlimited number of persons by the subject of personal data or at his or her request (hereinafter "publicly accessible personal data").
9.7 Personal data subject to publication or compulsory disclosure under federal law shall be processed.
10. Procedure for the collection, storage, transfer and other processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organisational and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.
10.1 The operator shall ensure the security of personal data and shall take all possible measures to exclude access to personal data by unauthorised persons.
10.2 Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfil obligations under a civil law contract.
10.3 If inaccuracies in the personal data are identified, the User may update the personal data themselves by sending a notification to the Operator's email address love@blackbeltmedia.ru, marked "Update of personal data".
10.4 The time period for processing personal data is determined by achieving the purposes for which the personal data was collected, unless a different time period is stipulated by the contract or applicable law. The user may withdraw their consent to the processing of personal data at any time by sending a notice by e-mail to the Operator's e-mail address love@blackbeltmedia.ru, marked "Withdrawal of consent to process personal data".
10.5 All information that is collected by third party services, including payment systems, means of communication and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to acquaint themselves with the said documents in a timely manner. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
10.6 The prohibitions established by the personal data subject on the transfer (other than granting access) and on the processing or conditions of processing (other than obtaining access) of personal data authorised for distribution shall not apply in cases of processing of personal data for state, public and other public interests as defined by Russian law.
10.7 The operator shall ensure the confidentiality of personal data when processing personal data.
10.8. The operator shall store personal data in a form that allows the identification of the personal data subject for no longer than the purposes of personal data processing require, unless the storage period of personal data is prescribed by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor under which the personal data subject is a beneficiary.
10.9 A condition for the termination of personal data processing may be the achievement of the personal data processing objectives, expiry of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as the detection of unlawful personal data processing.
11. List of Actions Performed by the Operator with Personal Data
11.1. The Operator shall collect, record, systematise, accumulate, store, clarify (update, change), extract, use, transfer (distribution, provision, access), anonymise, block, delete and destroy personal data.
11.2 The Operator shall carry out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunication networks.
12. cross-border transfer of personal data
12.1 Before transborder transfer of personal data, the Operator shall ensure that the foreign country to whose territory the transfer of personal data is to take place provides adequate protection of the rights of personal data subjects.
12.2 The cross-border transfer of personal data to foreign countries that do not meet the aforementioned requirements may only take place if the personal data subject consents in writing to the cross-border transfer of his/her personal data and/or performance of the agreement to which the personal data subject is a party.
13. Confidentiality of personal data
The operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator by e-mail at love@blackbeltmedia.ru.
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 https://blackbeltmedia.ru/privacy.
