1. General ProvisionsThis Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by Ivan Viktorovich Melnikov (Individual Entrepreneur) (the “Operator”).
1.1. The Operator considers the observance of 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 one of the principal objectives and conditions 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 https://abhgroup.co.
2. Key Terms Used in This Policy2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify the personal data.
2.3. Website means the collection of graphic and informational materials, software and databases that make such materials available on the Internet at https://abhgroup.co.
2.4. Personal data information system means the combination of personal data contained in databases and the information technologies and technical means used to process such data.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data means any action or set of actions performed with or without automation in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification or updating, retrieval, use, transfer (distribution, provision or access), depersonalization, 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 other persons organizes and/or carries out personal data processing and determines the purposes of processing, the categories of personal data to be processed and the actions performed with such data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://abhgroup.co.
2.9. Personal data permitted by the personal data subject for distribution means personal data made available to an unlimited number of persons by the subject through consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law.
2.10. User means any visitor to https://abhgroup.co.
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. Distribution of personal data means actions aimed at disclosing personal data to an indefinite number of persons or otherwise making such data available to an unlimited number of persons, including publication in the media, posting on information and telecommunications networks, or granting access by other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data means actions resulting in the irreversible destruction of personal data so that its content cannot subsequently be restored in a personal data information system and/or the physical destruction of storage media containing such data.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to:
· receive accurate information and/or documents containing personal data from the personal data subject;
· continue processing personal data without the subject’s consent where legal grounds under the Personal Data Law remain applicable after consent is withdrawn or a request to stop processing is received;
· independently determine the measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and related regulations, unless otherwise provided by applicable law.
3.2. The Operator is required to:
· provide the personal data subject, upon request, with information relating to the processing of their personal data;
· organize personal data processing in accordance with applicable Russian law;
· respond to requests from personal data subjects and their legal representatives in accordance with the Personal Data Law;
· provide the authorized body for the protection of personal data subjects’ rights with requested information within 10 days of receiving the request;
· publish or otherwise ensure unrestricted access to this Policy;
· implement legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions;
· stop transfer, stop processing and destroy personal data in the procedure and cases provided by the Personal Data Law;
· perform other duties established by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:
· receive information relating to the processing of their personal data, except in cases provided by federal law. Such information must be provided by the Operator in an accessible form and must not contain personal data relating to other subjects unless there are lawful grounds for disclosure;
· require the Operator to clarify, block or destroy personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take other measures provided by law to protect their rights;
· require prior consent for personal data processing carried out for the promotion of goods, works and services;
· withdraw consent to personal data processing and request termination of processing;
· challenge unlawful actions or omissions of the Operator before the authorized personal data authority or in court;
· exercise other rights provided by Russian law.
4.2. Personal data subjects are required to provide accurate information about themselves and inform the Operator of any updates or changes to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent are liable in accordance with Russian law.
5. Principles of Personal Data Processing5.1. Personal data is processed lawfully and fairly.
5.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes for which personal data was collected is not permitted.
5.3. Databases containing personal data processed for incompatible purposes may not be combined.
5.4. Only personal data relevant to the purposes of processing may be processed.
5.5. The content and volume of personal data processed must correspond to the stated purposes. Excessive processing in relation to those purposes is not permitted.
5.6. The Operator must ensure the accuracy, sufficiency and, where necessary, relevance of personal data and must take measures to delete or correct incomplete or inaccurate data.
5.7. Personal data must be stored in a form that allows identification of the data subject for no longer than required for the purposes of processing, unless a different retention period is established by federal law or contract. Personal data must be destroyed or depersonalized once the purpose of processing has been achieved or the need for processing has ceased, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose: Informing the User by sending emails.
Personal data processed: Surname, first name, patronymic; telephone numbers.
Legal basis: Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”.
Type of processing: Transfer of personal data.
7. Conditions for Processing Personal Data7.1. Personal data is processed with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, or to perform functions, powers and duties assigned to the Operator under Russian law.
7.3. Processing is necessary for the administration of justice or the enforcement of a judicial act or other enforceable act in accordance with Russian enforcement legislation.
7.4. Processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, or to enter into a contract initiated by the subject.
7.5. 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 violated.
7.6. Personal data made publicly available by the personal data subject or at their request may be processed.
7.7. Personal data subject to publication or mandatory disclosure under federal law may be processed.
8. Procedure for Collection, Storage, Transfer and Other Processing of Personal DataThe security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with applicable personal data protection requirements.
8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access.
8.2. User personal data will not be transferred to third parties except where required by applicable law or where the personal data subject has consented to transfer for the performance of obligations under a civil-law agreement.
8.3. If inaccuracies are identified, the User may update their personal data by emailing ivan@abhgroup.co with the subject line “Personal Data Update”.
8.4. The processing period is determined by the achievement of the purposes for which the personal data was collected, unless another period is established by contract or applicable law. A User may withdraw consent at any time by emailing ivan@abhgroup.co with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. Information collected by third-party services, including payment systems, communications providers and other service providers, is stored and processed by those parties in accordance with their own user agreements and privacy policies. The Operator is not responsible for the actions of such third parties.
8.6. Restrictions established by a personal data subject on transfer or processing of personal data permitted for distribution do not apply where processing is carried out in state, public or other legally defined public interests.
8.7. The Operator ensures confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form permitting identification of the subject for no longer than required by the purposes of processing unless a different period is established by federal law or contract.
8.9. Processing may be terminated when its purposes are achieved, consent expires or is withdrawn, a request to stop processing is received, or unlawful processing is identified.
9. Actions Performed by the Operator with Personal Data9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies, retrieves, uses, transfers, depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated personal data processing with or without receiving and/or transferring information through information and telecommunications networks.
10. Cross-Border Transfer of Personal Data10.1. Before beginning cross-border transfer activities, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such transfers. This notice is submitted separately from the notice of intent to process personal data.
10.2. Before submitting such notice, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals or foreign legal entities to which personal data is planned to be transferred.
11. Confidentiality of Personal DataThe Operator and any other persons with access to personal data must not disclose or distribute such data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions12.1. Users may obtain clarification on any questions concerning personal data processing by contacting the Operator at ivan@abhgroup.co.
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 replaced by a new version.
12.3. The current version of the Policy is publicly available at https://abhgroup.co/police.
1.1. The Operator considers the observance of 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 one of the principal objectives and conditions 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 https://abhgroup.co.
2. Key Terms Used in This Policy2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify the personal data.
2.3. Website means the collection of graphic and informational materials, software and databases that make such materials available on the Internet at https://abhgroup.co.
2.4. Personal data information system means the combination of personal data contained in databases and the information technologies and technical means used to process such data.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data means any action or set of actions performed with or without automation in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification or updating, retrieval, use, transfer (distribution, provision or access), depersonalization, 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 other persons organizes and/or carries out personal data processing and determines the purposes of processing, the categories of personal data to be processed and the actions performed with such data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://abhgroup.co.
2.9. Personal data permitted by the personal data subject for distribution means personal data made available to an unlimited number of persons by the subject through consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law.
2.10. User means any visitor to https://abhgroup.co.
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. Distribution of personal data means actions aimed at disclosing personal data to an indefinite number of persons or otherwise making such data available to an unlimited number of persons, including publication in the media, posting on information and telecommunications networks, or granting access by other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data means actions resulting in the irreversible destruction of personal data so that its content cannot subsequently be restored in a personal data information system and/or the physical destruction of storage media containing such data.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to:
· receive accurate information and/or documents containing personal data from the personal data subject;
· continue processing personal data without the subject’s consent where legal grounds under the Personal Data Law remain applicable after consent is withdrawn or a request to stop processing is received;
· independently determine the measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and related regulations, unless otherwise provided by applicable law.
3.2. The Operator is required to:
· provide the personal data subject, upon request, with information relating to the processing of their personal data;
· organize personal data processing in accordance with applicable Russian law;
· respond to requests from personal data subjects and their legal representatives in accordance with the Personal Data Law;
· provide the authorized body for the protection of personal data subjects’ rights with requested information within 10 days of receiving the request;
· publish or otherwise ensure unrestricted access to this Policy;
· implement legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions;
· stop transfer, stop processing and destroy personal data in the procedure and cases provided by the Personal Data Law;
· perform other duties established by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:
· receive information relating to the processing of their personal data, except in cases provided by federal law. Such information must be provided by the Operator in an accessible form and must not contain personal data relating to other subjects unless there are lawful grounds for disclosure;
· require the Operator to clarify, block or destroy personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take other measures provided by law to protect their rights;
· require prior consent for personal data processing carried out for the promotion of goods, works and services;
· withdraw consent to personal data processing and request termination of processing;
· challenge unlawful actions or omissions of the Operator before the authorized personal data authority or in court;
· exercise other rights provided by Russian law.
4.2. Personal data subjects are required to provide accurate information about themselves and inform the Operator of any updates or changes to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent are liable in accordance with Russian law.
5. Principles of Personal Data Processing5.1. Personal data is processed lawfully and fairly.
5.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes for which personal data was collected is not permitted.
5.3. Databases containing personal data processed for incompatible purposes may not be combined.
5.4. Only personal data relevant to the purposes of processing may be processed.
5.5. The content and volume of personal data processed must correspond to the stated purposes. Excessive processing in relation to those purposes is not permitted.
5.6. The Operator must ensure the accuracy, sufficiency and, where necessary, relevance of personal data and must take measures to delete or correct incomplete or inaccurate data.
5.7. Personal data must be stored in a form that allows identification of the data subject for no longer than required for the purposes of processing, unless a different retention period is established by federal law or contract. Personal data must be destroyed or depersonalized once the purpose of processing has been achieved or the need for processing has ceased, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose: Informing the User by sending emails.
Personal data processed: Surname, first name, patronymic; telephone numbers.
Legal basis: Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”.
Type of processing: Transfer of personal data.
7. Conditions for Processing Personal Data7.1. Personal data is processed with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, or to perform functions, powers and duties assigned to the Operator under Russian law.
7.3. Processing is necessary for the administration of justice or the enforcement of a judicial act or other enforceable act in accordance with Russian enforcement legislation.
7.4. Processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, or to enter into a contract initiated by the subject.
7.5. 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 violated.
7.6. Personal data made publicly available by the personal data subject or at their request may be processed.
7.7. Personal data subject to publication or mandatory disclosure under federal law may be processed.
8. Procedure for Collection, Storage, Transfer and Other Processing of Personal DataThe security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with applicable personal data protection requirements.
8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access.
8.2. User personal data will not be transferred to third parties except where required by applicable law or where the personal data subject has consented to transfer for the performance of obligations under a civil-law agreement.
8.3. If inaccuracies are identified, the User may update their personal data by emailing ivan@abhgroup.co with the subject line “Personal Data Update”.
8.4. The processing period is determined by the achievement of the purposes for which the personal data was collected, unless another period is established by contract or applicable law. A User may withdraw consent at any time by emailing ivan@abhgroup.co with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. Information collected by third-party services, including payment systems, communications providers and other service providers, is stored and processed by those parties in accordance with their own user agreements and privacy policies. The Operator is not responsible for the actions of such third parties.
8.6. Restrictions established by a personal data subject on transfer or processing of personal data permitted for distribution do not apply where processing is carried out in state, public or other legally defined public interests.
8.7. The Operator ensures confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form permitting identification of the subject for no longer than required by the purposes of processing unless a different period is established by federal law or contract.
8.9. Processing may be terminated when its purposes are achieved, consent expires or is withdrawn, a request to stop processing is received, or unlawful processing is identified.
9. Actions Performed by the Operator with Personal Data9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies, retrieves, uses, transfers, depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated personal data processing with or without receiving and/or transferring information through information and telecommunications networks.
10. Cross-Border Transfer of Personal Data10.1. Before beginning cross-border transfer activities, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such transfers. This notice is submitted separately from the notice of intent to process personal data.
10.2. Before submitting such notice, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals or foreign legal entities to which personal data is planned to be transferred.
11. Confidentiality of Personal DataThe Operator and any other persons with access to personal data must not disclose or distribute such data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions12.1. Users may obtain clarification on any questions concerning personal data processing by contacting the Operator at ivan@abhgroup.co.
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 replaced by a new version.
12.3. The current version of the Policy is publicly available at https://abhgroup.co/police.
