Personal Data Processing Policy
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 APS LLC (hereinafter referred to as the Operator).
1.1
The Operator considers the protection of rights and freedoms of individuals, including the protection of the right to privacy, personal and family secrets, to be its most important goal and condition for conducting its activities.
1.2
This Policy applies to all information that the Operator may receive about visitors to the website
https://apsplatform.ru.
2. Basic Concepts Used in the Policy
2.1
Automated processing of personal data - processing of personal data using computer tools.
2.2
Blocking of personal data - temporary suspension of personal data processing (except for cases where processing is necessary for clarifying personal data).
2.3
Website - a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address
https://apsplatform.ru.
2.4
Personal data information system - a collection of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5
Anonymization of personal data - actions as a result of which it is impossible to determine the ownership of personal data by a specific User or another personal data subject without using additional information.
2.6
Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7
Operator - a state body, municipal body, legal or natural person who, alone or jointly with others, organizes and/or performs personal data processing, as well as determines the purposes of personal data processing, the composition of personal data subject to processing, and 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://apsplatform.ru.
2.9
Personal data allowed for distribution by the subject of personal data - personal data to which an unlimited number of persons have access at the request of the subject of personal data by giving consent to the processing of personal data allowed for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.11
Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12
Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an indefinite circle of persons with personal data, including publication in the media, placement in information and telecommunication 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, a foreign individual, or a foreign legal entity.
2.14
Destruction of personal data - any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoring the content of personal data in the personal data information system and/or the physical carriers of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1
The Operator has the right:
To receive from the subject of personal data reliable information and/or documents containing personal data;
In case of revocation of consent to the processing of personal data by the subject of personal data, as well as the submission of a request to stop processing personal data, the Operator is entitled to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
To independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2
The Operator must:
Provide the subject of personal data, at their request, with information related to the processing of their personal data;
Organize the processing of personal data in the manner established by current Russian legislation;
Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
Notify the authorized body for the protection of the rights of subjects of personal data in the request of this body the necessary information within 10 days from the date of receipt of such a request;
Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, or other unlawful actions in relation to personal data;
Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
Fulfill other obligations provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1
Subjects of personal data have the right:
To receive information related to the processing of their personal data, except as provided 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 obtaining it is established by the Personal Data Law;
To require the Operator to clarify their personal data, block or delete it in case the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
To set a condition for prior consent when processing personal data for the purpose of marketing, promotion, and advertising;
To revoke consent to the processing of personal data, as well as to submit a request to stop processing personal data;
To appeal against unlawful actions or omissions of the Operator when processing their personal data to the authorized body for the protection of the rights of subjects of personal data or in court;
To exercise other rights provided by Russian legislation.
4.2
Subjects of personal data must:
Provide the Operator with accurate information about themselves;
Inform the Operator about any updates or changes to their personal data.
4.3
Persons who provide the Operator with inaccurate information about themselves or information about another subject of personal data without their consent shall bear responsibility in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1
Processing of personal data is carried out on a lawful and fair basis.
5.2
Processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3
It is not allowed to combine databases containing personal data that are processed for purposes incompatible with each other.
5.4
Only personal data that meets the purposes of their processing is subject to processing.
5.5
The content and volume of processed personal data correspond to the stated purposes of their processing. Excess processing of personal data in relation to the stated purposes of their processing is not allowed.
5.6
When processing personal data, the Operator ensures the accuracy of personal data, their sufficiency, and, if necessary, their relevance in relation to the purposes of personal data processing. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7
Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, or side of the contract, beneficiary or guarantor under which the subject of personal data is a party. Processed personal data is destroyed or anonymized upon achieving the purposes of personal data processing or if it is no longer necessary to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Using the site means the subject of personal data agrees to the processing of their personal data for the purpose of increasing the awareness of site visitors about products and services, providing advertising information, and optimizing advertising. Such consent takes effect from the moment the subject of personal data visits the site and remains in effect for the periods established by Russian legislation.
The site collects user IP addresses. This information is used to identify and resolve technical issues, as well as to monitor the correctness of operations performed.
APS LLC takes efforts to protect personal data that are automatically transmitted during the visit to the site:
Source of access to the site and information of the search or advertising request;
Data about the user's device (including IP address, resolution, version, and other attributes characterizing the user's device);
User clicks, page views, filling out fields;
Data characterizing audience segments;
Session parameters;
Time of visit;
Other user information.
Legal basis - constituent documents of the Operator
Types of personal data processing:
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
Sending informational emails to the email address
7. Conditions for Processing Personal Data
7.1
Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2
Processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties assigned by the legislation of the Russian Federation to the Operator.
7.3
Processing of personal data is necessary for the administration of justice, execution of a court decision, or a decision of another body or official in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4
Processing of personal data is necessary for the performance of a contract, one party to which, or the beneficiary or guarantor under which, is the subject of personal data, 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 the beneficiary or guarantor.
7.5
Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6
Processing of personal data is carried out if the subject of personal data has made their personal data publicly available or at their request (hereinafter referred to as publicly available personal data).
7.7
Processing of personal data is carried out if personal data is to be published or made mandatory to disclose in accordance with federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
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.
8.1
The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2
The User's personal data is never, under any circumstances, transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given the Operator consent to transfer the data to a third party to fulfill obligations under a civil contract.
8.3
If inaccuracies are found in the User's personal data, the User can update them independently by sending a notification to the Operator's email address
info@apsplatform.ru with the note "Update of personal data".
8.4
The processing of personal data is terminated upon achievement of the purposes for which the personal data were collected, unless otherwise provided by contract or current legislation.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to info@apsplatform.ru with the note "Revocation of consent to process personal data".
8.5
All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreements and Privacy Policies. The subject of personal data and/or the aforementioned documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6
Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by Russian legislation.
8.7
When processing personal data, the Operator ensures the confidentiality of personal data.
8.8
The Operator processes personal data in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, or side of the contract, beneficiary or guarantor under which the subject of personal data is a party.
8.9
The termination of personal data processing may be caused by the achievement of the purposes of personal data processing, the expiration of the subject's consent to personal data processing, the revocation of consent by the subject of personal data, or a request to stop processing personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1
The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2
The Operator performs automated processing of personal data with the receipt and/or transfer of the resulting information over information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1
Before starting activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data about its intention to perform cross-border transfer of personal data (such notification is submitted separately from the notification of intent to process personal data).
10.2
Before submitting the aforementioned notification, the Operator must obtain the necessary information from the authorities of a foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. 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.
12. Final Provisions
12.1
The User may obtain any clarifications on issues of interest by contacting the Operator using the email address
info@apsplatform.ru
12.2
Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.