Policy on Personal Data Processing
1. General Provisions
This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152‑FZ of 27.07.2006 “On Personal Data” (hereinafter – the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by C‑PRO LLC (hereinafter – the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality, as the most important goal and condition of its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may receive about visitors to the website https://truedevops.io/ (http://truedevops.io/).
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data by means of computer technology.
2.2. Blocking of personal data – temporary cessation of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://truedevops.io/ (http://truedevops.io/).
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://truedevops.io/ (http://truedevops.io/).
2.9. Personal data allowed by the subject of personal data for dissemination – personal data to which an unlimited number of persons has been granted access by the subject of personal data by giving consent to the processing of personal data allowed for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data allowed for dissemination).
2.10. User – any visitor to the website https://truedevops.io/ (http://truedevops.io/).
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 number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publishing personal data in the media, posting it 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 an authority of a foreign state, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or material media 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 the event that the subject of personal data withdraws consent to the processing of personal data, and/or sends a request demanding cessation of the processing of personal data, continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the 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 is obliged to:
– provide the subject of personal data, upon his/her request, with information regarding the processing of his/her personal data;
– organize the processing of personal data in the manner established by the applicable laws of the Russian Federation;
– respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide the authorized body for the protection of the rights of subjects of personal data, upon request of this body, with the necessary information within 10 days from the date of receipt of such a request;
– publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with respect to personal data;
– cease transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
– fulfill other obligations stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
– receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
– demand that the Operator clarify their personal data, block or destroy them if personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
– set a condition of prior consent when personal data are processed for the purpose of promoting goods, works and services on the market;
– withdraw consent to the processing of personal data, as well as send a demand to cease the processing of personal data;
– appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in processing their personal data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
– provide the Operator with reliable information about themselves;
– inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.
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 the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes of their processing is not allowed.
5.6. In processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identifying the subject of personal data no longer than required by the purposes of processing personal data, unless a period for storing personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or in case the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
Informing the User by sending emails.
Personal data:
– surname, first name, patronymic;
– email address;
– telephone numbers.
Legal grounds:
Federal Law “On Information, Information Technologies and Information Protection” No. 149‑FZ of 27.07.2006.
Types of personal data processing:
– collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data;
– sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data are processed with the consent of the subject of personal data to the processing of his/her personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary or guarantor, 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 a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. Personal data are processed for which access to an unlimited number of persons has been provided by the subject of personal data or at his/her request (hereinafter – publicly available personal data).
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer 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 applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or when the subject of personal data has given the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If inaccuracies in personal data are revealed, the User may update them independently by sending the Operator a notification to the Operator’s email address sales@seadox.pro with the note “Updating personal data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or applicable law.
The User may at any time withdraw consent to the processing of personal data by sending the Operator a notification by email to the Operator’s email address sales@seadox.pro with the note “Withdrawal of consent to personal data processing”.
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 independently familiarizes him/herself with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the subject of personal data on transfer (other than granting access), as well as on processing or conditions of processing (other than obtaining access) of personal data allowed for dissemination do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data no longer than required by the purposes of processing personal data, unless a period for storing personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.9. Grounds for termination of personal data processing may include: achievement of the purposes of processing personal data; expiry of the period of validity of the consent of the subject of personal data; withdrawal of consent by the subject of personal data or a demand to cease processing of personal data; and detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such.
10. Cross‑Border Transfer of Personal Data
10.1. Before starting activities involving cross‑border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross‑border transfer of personal data (such notification is sent separately from the notification of the intention to carry out processing of personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals and foreign legal entities to which cross‑border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate 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 relating to the processing of his/her personal data by contacting the Operator via email at sales@seadox.pro.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://truedevops.io/privacy.
This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152‑FZ of 27.07.2006 “On Personal Data” (hereinafter – the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by C‑PRO LLC (hereinafter – the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality, as the most important goal and condition of its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may receive about visitors to the website https://truedevops.io/ (http://truedevops.io/).
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data by means of computer technology.
2.2. Blocking of personal data – temporary cessation of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://truedevops.io/ (http://truedevops.io/).
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://truedevops.io/ (http://truedevops.io/).
2.9. Personal data allowed by the subject of personal data for dissemination – personal data to which an unlimited number of persons has been granted access by the subject of personal data by giving consent to the processing of personal data allowed for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data allowed for dissemination).
2.10. User – any visitor to the website https://truedevops.io/ (http://truedevops.io/).
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 number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publishing personal data in the media, posting it 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 an authority of a foreign state, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or material media 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 the event that the subject of personal data withdraws consent to the processing of personal data, and/or sends a request demanding cessation of the processing of personal data, continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the 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 is obliged to:
– provide the subject of personal data, upon his/her request, with information regarding the processing of his/her personal data;
– organize the processing of personal data in the manner established by the applicable laws of the Russian Federation;
– respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide the authorized body for the protection of the rights of subjects of personal data, upon request of this body, with the necessary information within 10 days from the date of receipt of such a request;
– publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with respect to personal data;
– cease transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
– fulfill other obligations stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
– receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
– demand that the Operator clarify their personal data, block or destroy them if personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
– set a condition of prior consent when personal data are processed for the purpose of promoting goods, works and services on the market;
– withdraw consent to the processing of personal data, as well as send a demand to cease the processing of personal data;
– appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in processing their personal data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
– provide the Operator with reliable information about themselves;
– inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.
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 the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes of their processing is not allowed.
5.6. In processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identifying the subject of personal data no longer than required by the purposes of processing personal data, unless a period for storing personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or in case the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
Informing the User by sending emails.
Personal data:
– surname, first name, patronymic;
– email address;
– telephone numbers.
Legal grounds:
Federal Law “On Information, Information Technologies and Information Protection” No. 149‑FZ of 27.07.2006.
Types of personal data processing:
– collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data;
– sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data are processed with the consent of the subject of personal data to the processing of his/her personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary or guarantor, 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 a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. Personal data are processed for which access to an unlimited number of persons has been provided by the subject of personal data or at his/her request (hereinafter – publicly available personal data).
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer 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 applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or when the subject of personal data has given the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If inaccuracies in personal data are revealed, the User may update them independently by sending the Operator a notification to the Operator’s email address sales@seadox.pro with the note “Updating personal data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or applicable law.
The User may at any time withdraw consent to the processing of personal data by sending the Operator a notification by email to the Operator’s email address sales@seadox.pro with the note “Withdrawal of consent to personal data processing”.
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 independently familiarizes him/herself with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the subject of personal data on transfer (other than granting access), as well as on processing or conditions of processing (other than obtaining access) of personal data allowed for dissemination do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data no longer than required by the purposes of processing personal data, unless a period for storing personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.9. Grounds for termination of personal data processing may include: achievement of the purposes of processing personal data; expiry of the period of validity of the consent of the subject of personal data; withdrawal of consent by the subject of personal data or a demand to cease processing of personal data; and detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such.
10. Cross‑Border Transfer of Personal Data
10.1. Before starting activities involving cross‑border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross‑border transfer of personal data (such notification is sent separately from the notification of the intention to carry out processing of personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals and foreign legal entities to which cross‑border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate 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 relating to the processing of his/her personal data by contacting the Operator via email at sales@seadox.pro.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://truedevops.io/privacy.
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