Privacy policy

This document is an English translation of the Privacy Policy for informational purposes only. In case of any discrepancies or conflicts between the English and Russian versions, the Russian version shall prevail and be considered the official legal document.

The Privacy Policy of Individual Entrepreneur Rakhmakova Viktoria Aleksandrovna (hereinafter referred to as the "Entrepreneur") regarding personal data processing (hereinafter briefly referred to as the "Policy") defines its position and intentions in the field of processing and protecting personal data of any subjects, with the aim of complying with and protecting the rights and freedoms of each person and, in particular, the right to privacy, personal and family secrets, and protection of one's honor and good name.

The Policy is strictly implemented by all specialists engaged by the Entrepreneur.

The Policy applies to all personal data of subjects processed by the Entrepreneur with the use of automation tools and without the use of such tools.

Any personal data subject has access to this Policy.

1. Definitions

Personal data — any information relating to a directly or indirectly identified or identifiable natural person (citizen). Such information may include, in particular: full name, contact phone number and address, as well as other information.

Personal data processing — any action (operation) or set of actions (operations) with personal data, performed using automation tools or without using such tools. Such actions (operations) may include: collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data for the following purposes:

• processing and receiving payments from the Customer;
• delivering goods to the Customer;
• providing customer support to the Customer;
• communicating with the Customer, including sending notifications, requests and information regarding the use of Services, provision of services, as well as processing requests and applications from the Customer;
• informing the Customer about events and promotions conducted by the Entrepreneur;
• sending news messages.

2. The Entrepreneur processes personal data of the following persons:

• subjects with whom various civil law contracts have been concluded;
• various clients and counterparties of the Entrepreneur;
• registered users of the website https://avvaken.ru/.

3. Principles and Conditions of Personal Data Processing

By personal data security, the Entrepreneur means the protection of personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data, and takes the necessary legal, organizational and technical measures to protect personal data.

The processing and security of personal data by the Entrepreneur is carried out in accordance with the requirements of the Constitution of the Russian Federation, Federal Law No. 152-FZ "On Personal Data", subordinate acts, other federal laws of the Russian Federation that define cases and features of personal data processing, and guidance and methodological documents of FSTEC of Russia and FSB of Russia.

When processing personal data, the Entrepreneur adheres to the following principles:

• legality;
• limitation of personal data processing to the achievement of specific, predetermined and lawful purposes;
• prevention of personal data processing incompatible with the purposes of personal data collection;
• prevention of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
• processing of personal data that meets the purposes of their processing;
• content compliance.

The Entrepreneur processes personal data only if at least one of the following conditions is met:

• personal data processing is carried out with the consent of the personal data subject to the processing of their personal data;
• personal data processing is necessary to achieve the purposes provided by law, to implement and perform the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation;
• personal data processing is necessary for the performance of a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
• personal data processing is necessary for the exercise of the rights and legitimate interests of the Entrepreneur or third parties or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject;
• processing of personal data is carried out, access to which by an unlimited number of persons is provided by the personal data subject or at their request;
• processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

The Entrepreneur has the right to entrust the processing of citizens' personal data to third parties, on the basis of an agreement concluded with these parties. Persons who process personal data on behalf of the Entrepreneur undertake to comply with the principles and rules of processing and protection of personal data provided for by Federal Law No. 152-FZ "On Personal Data". For each person, a list of actions (operations) with personal data that will be performed by the individual entrepreneur processing personal data, the purposes of processing, the obligation of such person to maintain confidentiality and ensure the security of personal data during their processing, as well as requirements for the protection of processed personal data have been determined.

In cases established by the current legislation of the Russian Federation, the Entrepreneur has the right to transfer the personal data of citizens.

For informational support purposes, the Entrepreneur may create publicly available sources of employees' personal data, including directories and address books. With the employee's consent, publicly available sources of personal data may include their last name, first name, patronymic, date and place of birth, position, contact phone numbers, and email address. Information about an employee must be excluded from publicly available sources of personal data at any time at the employee's request or by court decision or other authorized state bodies.

The Entrepreneur destroys or depersonalizes personal data upon achieving the processing purposes or in case of loss of the need to achieve the purpose of their processing.

Checking the checkbox for advertising mailings means the User's full consent to receive information about special offers, new products and promotional campaigns via telecommunication networks and postal services (including, but not limited to SMS mailings, email mailings) and the processing of their personal data through collection, recording, systematization, accumulation, storage, clarification, extraction, use, carried out using automation tools, including in information and telecommunication networks, or without using such tools, for the purpose of organizing the sending of special offers, information about new products and promotional campaigns, processing requests and inquiries.

4. Rights of Personal Data Subject

A natural person whose personal data is being processed has the right to receive from the Entrepreneur the following:

• confirmation of the fact of processing their personal data;
• legal grounds and purposes of personal data processing;
• information about the methods of personal data processing used by the Entrepreneur;
• information about persons who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Entrepreneur or on the basis of federal law;
• a list of processed personal data related to the citizen from whom the request was received and the source of their receipt, unless another procedure for providing such data is provided by federal law;
• information about the terms of personal data processing, including the terms of their storage;
• name and address of the person processing personal data on behalf of the Entrepreneur;
• other information provided by Federal Law "On Personal Data" No. 152-FZ or other federal laws;
• demand clarification of their personal data, blocking or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
• withdraw their written consent to personal data processing;
• demand elimination of unlawful actions of the Entrepreneur in relation to their personal data;
• appeal the actions or inaction of the Entrepreneur to the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court if the citizen believes that the Entrepreneur processes their personal data in violation of the requirements of Federal Law No. 152-FZ "On Personal Data" or otherwise violates their rights and freedoms.

5. Liability

In case of failure to comply with the provisions of this Policy, the Entrepreneur bears liability in accordance with the current legislation of the Russian Federation.

The current version of the "Personal Data Processing Policy" is published on the website https://avvaken.ru/.

Information on Implemented Personal Data Protection Requirements

When processing personal data, the Entrepreneur takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data.

Such measures in accordance with Federal Law No. 152-FZ "On Personal Data" include:

• identification of threats to personal data security when processing them in personal data information systems;
• application of organizational and technical measures to ensure the security of personal data when processing them in personal data information systems, necessary to fulfill the requirements for personal data protection, the implementation of which ensures the levels of personal data security established by the Government of the Russian Federation;
• application of information security tools that have passed the conformity assessment procedure in the prescribed manner;
• assessment of the effectiveness of measures taken to ensure the security of personal data before putting the personal data information system into operation;
• detection of facts of unauthorized access to personal data and taking measures;
• restoration of personal data modified or destroyed as a result of unauthorized access to them;
• establishment of rules for access to personal data processed in the personal data information system, as well as ensuring registration and accounting of all actions performed with personal data in the personal data information system;
• control over the measures taken to ensure the security of personal data and the level of security of personal data information systems;
• conducting monitoring of user actions, conducting investigations into violations of personal data security requirements.