Personal data processing policy

Personal data processing policy

1. General provisions

This personal data processing policy has been prepared in accordance with Federal Law dated 27.07.2006. №152-FZ “On Personal Data” (hereinafter the Personal Data Law) and establishes the procedure for processing personal data and the measures taken by Forum LLC (hereinafter the Operator) to ensure its security.

1.1. The Operator's primary objective and a condition of its activities is to respect human and civil rights and freedoms when processing personal data, including the rights to privacy and personal and family confidentiality.

1.2. This Operator's personal data processing policy (hereinafter the Policy) applies to all information the Operator may obtain about visitors to https://assistbot.ru.

2. Key terms used in the Policy

2.1. Automated processing of personal data means processing personal data using computer technology.

2.2. Blocking personal data means temporarily suspending its processing, except where processing is necessary to clarify the data.

2.3. Website means the collection of graphics, information, computer programs and databases that make them available on the Internet at https://assistbot.ru.

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

2.5. Anonymization of personal data means actions that make it impossible, without additional information, to identify the specific User or other data subject to whom the data relates.

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

2.7. Operator means a state body, municipal body, legal entity or individual that independently or jointly organizes and/or carries out personal data processing and determines its purposes, the data to be processed and the actions performed on that data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://assistbot.ru.

2.9. Personal data authorized by the data subject for dissemination means personal data to which unrestricted public access has been granted by the data subject through consent to processing of personal data authorized for dissemination under the Personal Data Law (hereinafter personal data authorized for dissemination).

2.10. User means any visitor to https://assistbot.ru.

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

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transferring personal data) or making it available to an unrestricted audience, including publication in the media, placement on information and telecommunications networks or granting access in any other way.

2.13. Cross-border transfer of personal data means transferring 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 that irreversibly destroy the data so its content cannot subsequently be restored in the personal data information system and/or that destroy physical media containing the data.

3. Principal rights and obligations of the Operator

3.1. The Operator may:

– obtain accurate information and/or documents containing personal data from the data subject;

– continue processing personal data without the data subject's consent after consent is withdrawn, where grounds specified in the Personal Data Law apply;

– independently determine the measures necessary and sufficient to fulfill obligations under the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by that Law or other federal laws.

3.2. The Operator must:

– provide the data subject, on request, with information concerning the processing of their personal data;

– organize personal data processing in accordance with applicable Russian law;

– respond to inquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law;

– provide the authorized body for protection of data subjects' rights with the necessary information within 30 days of receiving its request;

– publish or otherwise provide unrestricted access to this Personal Data Processing Policy;

– take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions;

– stop transferring (disseminating, providing, granting access to) personal data, cease processing it and destroy it in the manner and cases provided for by the Personal Data Law;

– fulfill other obligations under the Personal Data Law.

4. Principal rights and obligations of data subjects

4.1. Data subjects may:

– obtain information concerning the processing of their personal data, except as provided by federal law. The Operator provides this information in an accessible form, without personal data relating to other data subjects unless there are lawful grounds for its disclosure. The scope of information and procedure for obtaining it are established by the Personal Data Law;

– require the Operator to clarify, block or destroy personal data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose, and take measures provided by law to protect their rights;

– require prior consent for personal data processing for the purpose of promoting goods, works and services on the market;

– withdraw consent to personal data processing;

– appeal the Operator's unlawful actions or omissions in processing their personal data to the authorized body for protection of data subjects' rights or to a court;

– exercise other rights provided by Russian law.

4.2. Data subjects must:

– provide accurate information about themselves to the Operator;

– notify the Operator of clarifications (updates or changes) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another data subject without that person's consent are liable under Russian law.

5. The Operator may process the following User personal data

5.1. Surname, first name and patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. The website also collects and processes anonymized visitor data, including cookies, using web analytics services such as Yandex Metrica, Google Analytics and others.

5.5. The data listed above is collectively referred to in this Policy as Personal Data.

5.6. The Operator does not process special categories of personal data concerning race, ethnicity, political opinions, religious or philosophical beliefs, or intimate life.

5.7. Processing personal data authorized for dissemination that falls within the special categories specified in part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions in Article 10.1 of that Law are observed.

5.8. The User's consent to processing personal data authorized for dissemination is obtained separately from other consents to processing their personal data. The conditions specified, in particular, in Article 10.1 of the Personal Data Law apply. Requirements for the content of such consent are established by the authorized body for protection of data subjects' rights.

5.8.1 The User gives consent to processing personal data authorized for dissemination directly to the Operator.

5.8.2 Within three business days of receiving the User's consent, the Operator must publish information on the processing terms and any prohibitions or conditions on processing the personal data authorized for dissemination by an unrestricted audience.

5.8.3 Transfer (dissemination, provision, access) of personal data authorized by the data subject for dissemination must cease at any time at the data subject's request. The request must include the data subject's surname, first name and patronymic (if any), contact details (phone number, email or postal address) and a list of personal data whose processing must stop. The personal data specified in the request may be processed only by the Operator to whom it is addressed.

5.8.4 Consent to processing personal data authorized for dissemination ceases to have effect when the Operator receives the request specified in clause 5.8.3 of this Personal Data Processing Policy.

6. Principles of personal data processing

6.1. Personal data is processed lawfully and fairly.

6.2. Processing is limited to achieving specific, predetermined and lawful purposes. Processing incompatible with the purposes for which personal data was collected is prohibited.

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

6.4. Only personal data relevant to the processing purposes is processed.

6.5. The content and volume of personal data processed must correspond to the stated purposes. Processing excessive personal data in relation to those purposes is prohibited.

6.6. Personal data must be accurate, adequate and, where necessary, up to date in relation to the processing purposes. The Operator takes and/or ensures the necessary measures to delete or clarify incomplete or inaccurate data.

6.7. Personal data is stored in a form permitting identification of the data subject for no longer than required by the processing purposes, unless a retention period is established by federal law or an agreement to which the data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized once the purposes are achieved or no longer need to be achieved, unless federal law provides otherwise.

7. Purposes of personal data processing

7.1. The purposes of processing the User's personal data are:

– informing the User by email;

– providing the User with access to services, information and/or materials available at https://assistbot.ru.

7.2. The Operator may also send the User notifications about new products and services, special offers and various events. The User may opt out at any time by emailing info@assistbot.ru with the subject “Opt out of notifications about new products, services and special offers”.

7.3. Anonymized User data collected through web analytics services is used to gather information about Users' actions on the website and improve the website and its content.

8. Legal grounds for personal data processing

8.1. The legal grounds for the Operator's processing of personal data are:

– agreements between the Operator and the data subject;

– federal laws and other regulations concerning personal data protection;

– Users' consent to processing their personal data and personal data authorized for dissemination.

8.2. The Operator processes the User's personal data only when the User independently enters and/or submits it through special forms at https://assistbot.ru or emails it to the Operator. By completing the forms and/or sending personal data to the Operator, the User consents to this Policy.

8.3. The Operator processes anonymized User data if the User's browser settings permit it (cookies and JavaScript are enabled).

8.4. The data subject independently decides to provide their personal data and gives consent freely, voluntarily and in their own interest.

9. Conditions for personal data processing

9.1. Personal data is processed with the data subject's consent.

9.2. Processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to perform functions, powers and duties assigned to the Operator by Russian law.

9.3. Processing is necessary for the administration of justice or enforcement of a judicial act, or an act of another body or official, enforceable under Russian legislation on enforcement proceedings.

9.4. Processing is necessary to perform an agreement to which the data subject is a party, beneficiary or guarantor, or to conclude an agreement at the data subject's initiative or under which the data subject will be a beneficiary or guarantor.

9.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve objectives of public importance, provided that the data subject's rights and freedoms are not infringed.

9.6. Processing is carried out on personal data to which the data subject has granted unrestricted public access or which has been made public at their request (hereinafter publicly available personal data).

9.7. Processing is carried out on personal data subject to publication or mandatory disclosure under federal law.

10. Collection, storage, transfer and other processing of personal data

The 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 law.

10.1. The Operator safeguards personal data and takes all possible measures to prevent access by unauthorized persons.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except where required by applicable law or where the data subject has consented to the Operator transferring data to a third party to fulfill obligations under a civil-law agreement.

10.3. If inaccuracies are found in personal data, the User may update it by notifying the Operator at info@assistbot.ru with the subject “Personal data update”.

10.4. The processing period is determined by fulfillment of the purposes for which personal data was collected, unless another period is provided by an agreement or applicable law.
The User may withdraw consent to personal data processing at any time by emailing the Operator at info@assistbot.ru with the subject “Withdrawal of consent to personal data processing”.

10.5. Information collected by third-party services, including payment systems, communication providers and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreements and Privacy Policies. The data subject and/or User must independently review those documents in a timely manner. The Operator is not liable for third-party actions, including those of the service providers listed in this clause.

10.6. Prohibitions imposed by the data subject on transferring personal data authorized for dissemination, except granting access, and on processing it or the conditions of processing, except obtaining access, do not apply when processing serves state, public or other public interests defined by Russian law.

10.7. The Operator ensures the confidentiality of personal data when processing it.

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

10.9. Processing may cease when its purposes are achieved, the data subject's consent expires or is withdrawn, or unlawful processing is identified.

11. Actions performed by the Operator on personal data received

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

11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the information through information and telecommunications networks.

12. Cross-border transfer of personal data

12.1. Before starting cross-border transfers of personal data, the Operator must ensure that the foreign state to which the data will be transferred reliably protects data subjects' rights.

12.2. Cross-border transfers to foreign states that do not meet the above requirements may take place only with the data subject's written consent to the cross-border transfer and/or to perform an agreement to which the data subject is a party.

13. Confidentiality of personal data

The Operator and other persons with access to personal data must not disclose it to third parties or disseminate it without the data subject's consent, unless federal law provides otherwise.

14. Final provisions

14.1. The User may obtain clarification on any questions concerning processing of their personal data by emailing the Operator at info@assistbot.ru.

14.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy remains effective indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available online at https://assistbot.ru/politika-konfidentsialnosti