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 27.07.2006 “On Personal Data” (the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Artem Andreevich Korotkov (the Operator) to ensure the security of personal data.

1.1. The Operator considers respect for human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and personal and family confidentiality, to be the most important objective and condition of its activities.

1.2. This Personal Data Processing Policy of the Operator (the Policy) applies to all information that the Operator may obtain about visitors to the website https://otclick.hr.

2. Basic terms used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computing equipment.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify personal data.

2.3. Website means the collection of graphic and informational materials, computer programs and databases that make them available on the Internet at https://otclick.hr.

2.4. Personal data information system means the collection of personal data contained in databases, together with the information technologies and technical means used to process them.

2.5. Anonymization of personal data means actions that make it impossible, without additional information, to determine whether personal data belong to a particular User or another personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data, with or without automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, amendment), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of personal data processing, the personal data to be processed and the actions (operations) performed on personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://otclick.hr.

2.9. Personal data authorized by the personal data subject for dissemination means personal data to which the subject has granted access to an unlimited number of persons by consenting to the processing of personal data authorized for dissemination in accordance with the procedure established by the Personal Data Law (personal data authorized for dissemination).

2.10. User means any visitor to the website https://otclick.hr.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means 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 publication in the media, placement on information and telecommunications networks or provision of access to personal data in any other manner.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of that state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore their contents in a personal data information system, and/or the destruction of physical media containing personal data.

3. Principal rights and obligations of the Operator

3.1. The Operator has the right to:

• obtain accurate information and/or documents containing personal data from the personal data subject;
• continue processing personal data without the subject’s consent if the subject withdraws consent to processing or submits a request to stop processing, where grounds provided for by the Personal Data Law exist;
• independently determine the composition and list of measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject, upon request, with information concerning the processing of their personal data;
• organize personal data processing in accordance with the current legislation of the Russian Federation;
• respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the competent authority for the protection of personal data subjects’ rights with the information it requests within 10 days of receiving the request;
• publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
• take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions concerning personal data;
• stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and circumstances provided for by the Personal Data Law;
• fulfill other obligations provided for by the Personal Data Law.

4. Principal rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

• obtain information concerning the processing of their personal data, except in the cases provided for by federal laws. The Operator must provide this information in an accessible form, and it must not contain personal data relating to other subjects unless there are lawful grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• require the Operator to clarify, block or destroy their personal data where the data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take measures provided for by law to protect their rights;
• require prior consent for personal data processing for the purpose of promoting goods, works and services on the market;
• withdraw consent to personal data processing and submit a request to stop personal data processing;
• appeal against the Operator’s unlawful actions or inaction in processing their personal data to the competent authority for the protection of personal data subjects’ rights or in court;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate data about themselves;
• inform the Operator of clarifications (updates, amendments) to their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without that subject’s consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing incompatible with the purposes for which personal data were collected is prohibited.

5.3. Databases containing personal data processed for mutually incompatible purposes must not be combined.

5.4. Only personal data that meet the purposes of their processing may be processed.

5.5. The content and volume of personal data processed must correspond to the stated purposes of processing. Personal data processed must not be excessive in relation to those purposes.

5.6. When personal data are processed, their accuracy, sufficiency and, where necessary, relevance to the purposes of processing must be ensured. The Operator takes and/or ensures the taking of necessary measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data must be stored in a form that permits identification of the personal data subject for no longer than is required by the purposes of processing, unless a retention period is established by federal law or a contract to which the subject is a party, beneficiary or guarantor. Personal data being processed must be destroyed or anonymized when the purposes of processing have been achieved or the need to achieve them has ceased, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing

Entering into, performing and terminating civil-law contracts

Personal data

Surname, first name and patronymic

Telephone numbers

Legal grounds

Contracts entered into between the Operator and the personal data subject

Types of personal data processing

Collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data

7. Conditions for personal data processing

7.1. Personal data are processed with the personal data subject’s consent to the processing of their personal data.

7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.

7.3. Personal data processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official that is enforceable under the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary to perform a contract to which the personal data subject is a party, beneficiary or guarantor, or to enter into a contract at the subject’s initiative or a contract under which the subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not infringed.

7.6. Personal data to which an unlimited number of persons have been granted access by the personal data subject or at their request are processed (publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure under federal law are processed.

8. Procedure for collecting, storing, transferring and otherwise processing personal data

The security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with the requirements of current personal data protection legislation.

8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized persons from accessing them.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where required to comply with current legislation or where the personal data subject has consented to the Operator transferring the data to a third party to fulfill obligations under a civil-law contract.

8.3. If inaccuracies in personal data are identified, the User may update them by sending a notification to the Operator’s email address, otclick.hr@yandex.ru, marked “Updating personal data”.

8.4. The duration of personal data processing is determined by achievement of the purposes for which the data were collected, unless a different period is provided for by a contract or current legislation.

The User may withdraw consent to personal data processing at any time by emailing a notification to the Operator at otclick.hr@yandex.ru, marked “Withdrawal of consent to personal data processing”.

8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions imposed by the personal data subject on the transfer (except granting access), processing or conditions of processing (except obtaining access) of personal data authorized for dissemination do not apply where personal data are processed in state, social or other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing them.

8.8. The Operator stores personal data in a form that permits identification of the personal data subject for no longer than is required by the purposes of processing, unless a retention period is established by federal law or a contract to which the subject is a party, beneficiary or guarantor.

8.9. Grounds for terminating personal data processing may include achievement of the purposes of processing, expiry of the subject’s consent, withdrawal of consent by the subject or a request to stop processing, as well as the discovery of unlawful personal data processing.

9. Actions performed by the Operator on personal data received

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, amends), retrieves, uses, transfers (disseminates, provides, grants access to), anonymizes, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated personal data processing, with or without receiving and/or transmitting the information obtained over information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before commencing cross-border personal data transfer activities, the Operator must notify the competent authority for the protection of personal data subjects’ rights of its intention to transfer personal data across borders. This notification is sent separately from the notification of the intention to process personal data.

10.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals and foreign legal entities to which cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have obtained access to personal data must not disclose them to third parties or disseminate them without the personal data subject’s consent, unless otherwise provided by federal law.

12. Final provisions

12.1. The User may obtain explanations on any matters concerning the processing of their personal data by contacting the Operator by email at otclick.hr@yandex.ru.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in force 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://otclick.hr/privacy/.