Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been prepared 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 undertaken by the Limited Liability Company “FEDOTOV & PARTNERS” Intellectual Property Bureau (hereinafter — the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrecy, as its primary goal and condition for conducting its activities.
1.2. This Operator’s Policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors of the website https://fedotov-ip.ru.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://fedotov-ip.ru.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions that result in the impossibility of determining, without the use of additional information, 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), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, 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 a specific or identifiable User of the website https://fedotov-ip.ru.
2.9. Personal data allowed for dissemination by the subject of personal data — personal data to which access is provided to an unlimited number of persons by the subject of personal data by giving consent for their processing in the manner prescribed by the Personal Data Law (hereinafter — personal data allowed for dissemination).
2.10. User — any visitor of the website https://fedotov-ip.ru.
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 familiarizing an unlimited number of persons with personal data, including the publication of personal data in mass media, posting 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 is irreversibly destroyed with no possibility of further restoration of personal data content in the personal data information system and/or physical media of personal data are destroyed.
3. Main 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 the subject of personal data withdraws consent to the processing of personal data, or sends a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject if there are grounds specified in the Personal Data Law;
—independently determine the composition and list of measures necessary and sufficient to ensure the 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 request, with information regarding the processing of his/her personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects 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 personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unlimited 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, as well as from other unlawful actions with respect to personal data;
— cease transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
—receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, unless there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, to block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— stipulate a condition of prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and to submit a demand to cease the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of 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 accurate information about themselves;
— notify the Operator of clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without that person’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with one another, is not permitted.
5.4. Only personal data that meets the purposes of their processing shall be subject to processing.
5.5. The content and scope of personal data processed shall correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of its processing is not permitted.
5.6. In processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or surety. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or when there is no longer a need to achieve such purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
— informing the User by sending emails.
Personal data:
— last name, first name, patronymic;
— email address;
— telephone numbers.
Legal basis:
— Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ of July 27, 2006.
Types of personal data processing:
— transfer of personal data.
7. Conditions for Personal Data Processing
7.1. Personal data processing shall be carried out with the consent of the personal data subject 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 exercise 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 authority 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 personal data subject is a party, 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.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator 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.
7.6. Processing is carried out with respect to personal data made publicly available by the personal data subject or at his/her request (hereinafter — publicly available personal data).
7.7. Processing is carried out with respect to personal data 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 security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. Personal data of the User shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law, or if the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In the event that inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to the Operator’s email address info@fedotov-ip.ru marked “Update of 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 a different period is provided for by contract or applicable law.
The User may at any time withdraw his/her consent to the processing of personal data by sending the Operator a notification via email to the Operator’s email address info@fedotov-ip.ru marked “Withdrawal of consent to the processing of 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 such parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to familiarize himself/herself with these documents. The Operator is not responsible for the actions of third parties, including those specified in this clause, providers of services.
8.6. Restrictions established by the personal data subject on transfer (except for granting access), as well as on processing or conditions of processing (except for access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of processing personal data, the expiration of the validity period of the consent of the personal data subject, the withdrawal of consent by the personal data subject, a demand to cease personal data processing, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transmission of the obtained information via information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (this notification shall be submitted separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator is obliged to obtain from the authorities of the foreign state, foreign natural persons, or foreign legal entities to whom the cross-border transfer of personal data is intended, 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 or disseminate personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on matters concerning the processing of his/her personal data by contacting the Operator via email at info@fedotov-ip.ru.
12.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy shall remain 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://fedotov-ip.ru/privacy-en.
This Personal Data Processing Policy has been prepared 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 undertaken by the Limited Liability Company “FEDOTOV & PARTNERS” Intellectual Property Bureau (hereinafter — the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrecy, as its primary goal and condition for conducting its activities.
1.2. This Operator’s Policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors of the website https://fedotov-ip.ru.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://fedotov-ip.ru.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions that result in the impossibility of determining, without the use of additional information, 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), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, 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 a specific or identifiable User of the website https://fedotov-ip.ru.
2.9. Personal data allowed for dissemination by the subject of personal data — personal data to which access is provided to an unlimited number of persons by the subject of personal data by giving consent for their processing in the manner prescribed by the Personal Data Law (hereinafter — personal data allowed for dissemination).
2.10. User — any visitor of the website https://fedotov-ip.ru.
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 familiarizing an unlimited number of persons with personal data, including the publication of personal data in mass media, posting 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 is irreversibly destroyed with no possibility of further restoration of personal data content in the personal data information system and/or physical media of personal data are destroyed.
3. Main 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 the subject of personal data withdraws consent to the processing of personal data, or sends a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject if there are grounds specified in the Personal Data Law;
—independently determine the composition and list of measures necessary and sufficient to ensure the 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 request, with information regarding the processing of his/her personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects 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 personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unlimited 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, as well as from other unlawful actions with respect to personal data;
— cease transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
—receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, unless there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, to block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— stipulate a condition of prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and to submit a demand to cease the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of 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 accurate information about themselves;
— notify the Operator of clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without that person’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with one another, is not permitted.
5.4. Only personal data that meets the purposes of their processing shall be subject to processing.
5.5. The content and scope of personal data processed shall correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of its processing is not permitted.
5.6. In processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or surety. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or when there is no longer a need to achieve such purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
— informing the User by sending emails.
Personal data:
— last name, first name, patronymic;
— email address;
— telephone numbers.
Legal basis:
— Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ of July 27, 2006.
Types of personal data processing:
— transfer of personal data.
7. Conditions for Personal Data Processing
7.1. Personal data processing shall be carried out with the consent of the personal data subject 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 exercise 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 authority 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 personal data subject is a party, 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.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator 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.
7.6. Processing is carried out with respect to personal data made publicly available by the personal data subject or at his/her request (hereinafter — publicly available personal data).
7.7. Processing is carried out with respect to personal data 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 security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. Personal data of the User shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law, or if the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In the event that inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to the Operator’s email address info@fedotov-ip.ru marked “Update of 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 a different period is provided for by contract or applicable law.
The User may at any time withdraw his/her consent to the processing of personal data by sending the Operator a notification via email to the Operator’s email address info@fedotov-ip.ru marked “Withdrawal of consent to the processing of 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 such parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to familiarize himself/herself with these documents. The Operator is not responsible for the actions of third parties, including those specified in this clause, providers of services.
8.6. Restrictions established by the personal data subject on transfer (except for granting access), as well as on processing or conditions of processing (except for access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of processing personal data, the expiration of the validity period of the consent of the personal data subject, the withdrawal of consent by the personal data subject, a demand to cease personal data processing, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transmission of the obtained information via information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (this notification shall be submitted separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator is obliged to obtain from the authorities of the foreign state, foreign natural persons, or foreign legal entities to whom the cross-border transfer of personal data is intended, 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 or disseminate personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on matters concerning the processing of his/her personal data by contacting the Operator via email at info@fedotov-ip.ru.
12.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy shall remain 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://fedotov-ip.ru/privacy-en.
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