1. General provisions 1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy) has been developed in compliance with the requirements of Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) in order to ensure the protection of human and civil rights and freedoms when processing personal data including the protection of the rights to privacy, personal and family secrets. 1.2. The Policy applies to all personal data that Individual entrepreneur Fedyukin Artem Aleksandrovich INN 665903932872 OGRNIP 314667906400012 and his employees or third parties working under the contract and subject to this Policy) processes on
https://silaslova.su/course202401 https://golos-sila.com/5-oshibok,
https://golos-sila.com/trening_sila_slova4,
And
https://golos-sila.com/trening_sila_slova11 and (hereinafter referred to as the Operator).
1.3. The Policy applies to the relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.
1.4. In compliance with the requirements of Part 2 of Article 18.1 of the Law on Personal Data, this Policy is published freely on the Internet on the Operator's website.
1.5. Basic concepts used in the Policy:
personal data is any information related directly or indirectly to a specific or identifiable natural person (personal data subject);
personal data processing is any action (operation) or set of actions (operations) with personal data performed with or without automation tools.
automated personal data processing is the processing of personal data using computer technology;
providing personal data is an action aimed at disclosing personal data to a specific person or a specific group of people.;
blocking of personal data is the temporary termination of the processing of personal data (except in cases where the processing is necessary to clarify personal data);
destruction of personal data is an action that makes it impossible to restore the content of personal data in the person's information personal data and information technologies and technical means that ensure their processing.
1.6. Basic rights and obligations of the Operator.
1.6.1. The Operator has the right to:
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.;
to entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of a contract concluded with this person. The person who processes personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by the Law on Personal Data, to respect the confidentiality of personal data, and to take the necessary measures to ensure the fulfillment of duties. provided for by the Law on Personal Data;
if the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, provided there are grounds specified in the Personal Data Act.
1.6.2. The Operator is obliged to:
organize the processing of personal data in accordance with the requirements of the Law on Personal Data;
respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Act;
notify the authorized body for the protection of the rights of personal data subjects (the Federal Service for Supervision of Communications, Information Technology and Mass Communications (Roskomnadzor)) upon request of this body, the necessary information is provided within 10 working days from the date of receipt of such request. This period may be extended, but not for more than five business days. To do this, the Operator must be referred to Roskomnadzor.
a reasoned notification indicating the reasons for extending the deadline for providing the requested information;
in accordance with the procedure established by the federal executive governmental body authorized in the field of security, to ensure interaction with the state system for detecting, preventing and eliminating the consequences of computer attacks on information resources of the Russian Federation, including informing it about computer incidents that have resulted in the unlawful transfer (provision, dissemination, access) of personal data.
1.7. Basic rights of the personal data subject.
1.7.1. The personal data subject has the right to:
receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, 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 are established by the Law on Personal Data;
to 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 to take legal measures to protect their rights.;
give prior consent to the processing of personal data for the purposes of promotion
in the market of goods, works and services;
to appeal to Roskomnadzor or in court against illegal actions or omissions of the Operator when processing his personal data.
1.8. Control over the fulfillment of the requirements of this Policy is carried out by an authorized person responsible for organizing the processing of personal data by the Operator.
1.9. Responsibility for violation of the requirements of the legislation of the Russian Federation and regulatory acts of the Operator in the field of personal data processing and protection is determined in accordance with the legislation of the Russian Federation.
2. Purposes of personal data collection
2.1. 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 personal data collection is not allowed.
2.2. Only personal data that meets the purposes of their processing is subject to processing.
2.3. The processing of personal data by the Operator is carried out for the following purposes:
carrying out its business activities in accordance with the law, including the conclusion and execution of contracts with counterparties;
identification of the Subject of personal data registered on the Operator's website for registration of the application;
providing the Subject of personal data with access to personalized Website resources;
establishing feedback with the Personal Data Subject, including sending notifications, requests regarding the use of the Site, provision of services, processing of requests and requests;
notifications about the service status;
providing technical support for working with the website;
communication with the Subject of personal data when contacting through the website;
2.4. The processing of personal data of employees may be carried out solely for the purpose of ensuring compliance with laws and other regulatory legal acts.
3. Legal grounds for personal data processing
3.1. The legal basis for the processing of personal data is a set of regulatory legal acts, in compliance with which and in accordance with which the Operator processes personal data, including:
The Constitution of the Russian Federation;
The Civil Code of the Russian Federation;
The Labor Code of the Russian Federation;
The Tax Code of the Russian Federation;
other regulatory legal acts regulating relations related to the Operator's activities.
3.2. The legal basis for the processing of personal data are also:
contracts concluded between the Operator and the subjects of personal data;
consent of personal data subjects to the processing of their personal data.
4. Scope and categories of personal data processed,
categories of personal data subjects
4.1. The content and scope of the personal data being processed must comply with the stated purposes of processing provided for in sec. 2 of this Policy. The personal data being processed should not be redundant in relation to the stated purposes of their processing.
4.2. The Operator may process personal data of the following categories of personal data subjects:
4.2.1. Clients and counterparties of the Operator - for the purposes of the Operator's activities:
surname, first name, patronymic;
contact information (including email address, phone number, login/Telegram ID);
information from cookies;
other personal data provided by clients and counterparties necessary for the conclusion and execution of contracts.
4.3. The processing of biometric personal data by the Operator (information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established) is carried out in accordance with the legislation of the Russian Federation.
4.4. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, except in cases provided for by the legislation of the Russian Federation.
5. Procedure and conditions of personal data processing
5.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.
5.2. The processing of personal data is carried out with the consent of the subjects of personal data to the processing of their personal data, as well as without it in cases provided for by the legislation of the Russian Federation.
5.3. The Operator processes personal data for each purpose of their processing in the following ways:
non-automated processing of personal data;
automated processing of personal data with or without transmission of the received information via information and telecommunication networks;
mixed processing of personal data.
5.4. The Operator's employees, whose job responsibilities include processing personal data, are allowed to process personal data.
5.5. The processing of personal data for each purpose of processing specified in clause 2.3 of the Policy is carried out by:
receiving personal data in oral and written form directly from the subjects of personal data;
entering personal data into the logs, registers and information systems of the Operator;
using other methods of personal data processing.
5.6. Disclosure and dissemination of personal data to third parties is prohibited without the consent of the personal data subject, unless otherwise provided by federal law. Consent to the processing of personal data authorized by the personal data subject for dissemination is issued separately from other consents of the personal data subject to the processing of his personal data.
Requirements for the content of consent to the processing of personal data authorized by the personal data subject
approved by Roskomnadzor Order No. 18 dated 02/24/2021.
5.7. The transfer of personal data to the bodies of inquiry and investigation, the Federal Tax Service, the Pension Fund of the Russian Federation, the Social Insurance Fund and other authorized executive authorities and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
5.8. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, distribution and other unauthorized actions.
5.9. The Operator stores personal data in a form that allows determining the subject of personal data for no longer than is required by each purpose of processing personal data, unless the period of storage of personal data is established by federal law or contract.
5.9.1. Personal data on paper is stored by the Operator during the retention periods of documents for which these periods are stipulated by the legislation on archival affairs in the Russian Federation (Federal Law No. 125-FZ dated 22.10.2004 "On Archival Affairs in the Russian Federation", a list of standard administrative archival documents formed in the course of the activities of state bodies, local self-government bodies, etc.). local governments and organizations, indicating the terms of their storage (approved by the Order of the Federal Archive dated December 20, 2019 N 236)) and is 3 years.
5.9.2. The storage period of personal data processed in personal data information systems corresponds to the storage period of personal data on paper.
5.10. The Operator stops processing personal data in the following cases::
the fact of their illegal processing has been revealed. The deadline is within three working days from the date of detection.;
the goal of their processing has been achieved;
the consent of the personal data subject to the processing of the specified data has expired or been revoked.
5.9.1. Personal data on paper is stored by the Operator during the retention periods of documents for which these periods are stipulated by the legislation on archival affairs in the Russian Federation (Federal Law No. 125-FZ dated 22.10.2004 "On Archival Affairs in the Russian Federation", a list of standard administrative archival documents formed in accordance with the Legislation of the Russian Federation on Archival the case in the Russian Federation). in the course of the activities of state bodies, local self-government bodies, etc.). local self-government bodies and organizations, indicating the terms of their storage (approved by Federal Archive Order No. 236 dated December 20, 2019)) and is 3 years.
5.9.2. The storage period of personal data processed in personal data information systems corresponds to the storage period of personal data on paper.
5.10. The Operator stops processing personal data in the following cases::
the fact of their illegal processing has been revealed. The deadline is within three working days from the date of detection.;
the goal of their processing has been achieved;
the consent of the personal data subject to the processing of the specified data has expired or been revoked when, according to the Law on Personal Data, the processing of this data is allowed only with consent.
5.11. Upon achieving the purposes of personal data processing, as well as in the event that the personal data subject withdraws consent to their processing, the Operator stops processing this data, unless
otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor.;
The operator does not have the right to process personal data without the consent of the personal data subject on the grounds provided for by the Law on Personal Data or other federal laws.;
no other agreement is provided for between the Operator and the personal data subject.
5.12. When a personal data subject requests the Operator to terminate the processing of personal data within a period not exceeding 10 working days from the date of receipt by the Operator of the relevant request, the processing of personal data is terminated, except in cases provided for by the Law on Personal Data. The specified period may be extended, but not more than five working days. To do this, the Operator must send a reasoned notification to the subject of personal data indicating the reasons for the extension of the period.
5.13. When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the cases specified in the Law on Personal Data. data.
6. Updating, correction, deletion, destruction
of personal data, responses to requests from subjects for access
to personal data
6.1. Confirmation of the fact of personal data processing by the Operator, the legal grounds and purposes of personal data processing, as well as other information specified in Part 7 of Article 14 of the Law on Personal Data, are provided by the Operator to the personal data subject or his representative within 10 working days from the date of request or receipt of a request from the personal data subject or his representative. This period may be extended, but not for more than five business days. To do this, the Operator should send a reasoned notification to the personal data subject indicating the reasons for extending the deadline for providing the requested information.
The request must contain:
the number of the main identity document of the personal data subject or his representative, information about the date of issue of the specified document and the issuing authority.;
information confirming the personal data subject's participation in the relationship with the Operator (contract number, date of conclusion of the contract, conditional designation and (or) other information), or information otherwise confirming the fact of personal data processing by the Operator;
signature of the personal data subject or his representative.
The request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
The operator provides the information specified in Part 7 of Article 14 of the Law on Personal Data to the personal data subject or his representative in the form in which the relevant request or request is sent, unless otherwise specified in the request or request.
If the request of the personal data subject does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data, or the subject does not have access rights to the requested information, a reasoned refusal is sent to him.
The right of a personal data subject to access his personal data may be restricted in accordance with Part 8 of Article 14 of the Law on Personal Data, including if the access of a personal data subject to his personal data violates the rights and legitimate interests of third parties.
6.2. In case of detection of inaccurate personal data when contacting a personal data subject or his representative, or at their request or at the request of Roskomnadzor, the Operator blocks personal data related to this personal data subject from the moment of such request or receipt of the specified request for the verification period, if blocking personal data does not violate the rights and legitimate interests of the subject personal data
does not violate the rights and legitimate interests of the personal data subject or third parties.
If the inaccuracy of personal data is confirmed, the Operator, based on information provided by the personal data subject or his representative or Roskomnadzor, or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes the blocking of personal data.
6.3. In case of detection of unlawful processing of personal data when contacting (requesting) a personal data subject or his representative or Roskomnadzor, the Operator shall block unlawfully processed personal data related to this personal data subject from the moment of such request or receipt of the request.
6.4. If the Operator, Roskomnadzor, or another interested person identifies the fact of unlawful or accidental transfer (provision, dissemination) of personal data (access to personal data) that has resulted in a violation of the rights of personal data subjects, the Operator:
within 24 hours, notifies Roskomnadzor of the incident, the alleged causes that have resulted in a violation of the rights of personal data subjects, the alleged harm caused to the rights of personal data subjects and the measures taken to eliminate the consequences of the incident, as well as provides information about the person authorized by the Operator to interact with Roskomnadzor on issues related to the incident.;
within 72 hours, notifies Roskomnadzor of the results of the internal investigation of the identified incident and provides information about the persons whose actions caused it (if any).
6.5. Procedure for destruction of personal data by the Operator.
6.5.1. Conditions and terms of destruction of personal data by the Operator:
achievement of the purpose of processing personal data or loss of the need to achieve this goal - within 30 days;
achieving the maximum retention period for documents containing personal data is within 30 days.;
the provision by the personal data subject (his representative) of confirmation that the personal data was obtained illegally or is not necessary for the stated purpose of processing - within seven working days.;
revocation by the personal data subject of consent to the processing of his personal data, if their retention is no longer required for the purpose of their processing, within 30 days.The consent is revoked by sending a corresponding request to the Operator's email:
info@silavtebe.fun6.5.2. Upon achieving the purpose of processing personal data, as well as in the event that the personal data subject withdraws consent to their processing, personal data is subject to destruction, unless
otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor.;
The operator does not have the right to process personal data without the consent of the personal data subject on the grounds provided for by the Law on Personal Data or other federal laws.;
no other agreement is provided for between the Operator and the personal data subject.
6.5.3. The destruction of personal data is carried out by a commission established by the Operator.
6.5.4. The methods of destruction of personal data are established in the Operator's local regulations.
7. Cookie processing
7.1. By continuing to use the Operator's website, the Personal Data Subject consents to the automated processing of personal data (cookies, information about actions performed on the website, information about the devices used for this purpose, information obtained from the Unified Authentication and Authorization System (USIA), date and time of the session) by performing the following actions: collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, blocking, deletion, destruction.
7.2. Data processing is carried out in order to improve the operation of the Operator's website and improve its services. The consent is valid from the moment it is provided and during the entire period of use of the site.
7.3. In case of refusal of data processing, the Personal data Subject must stop using the portal or disable cookies in the browser settings.