Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been compiled 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 personal data processing procedure and the measures taken by EM Communications LLC (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator's utmost goal and condition for carrying out such activities is to respect the rights and freedoms of Russian citizens and other individuals when processing their personal data, including the protection of rights to privacy, personal and familial confidentiality.
1.2. The Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information the Operator may receive about visitors to the Operator's websites.
2. Basic Rights and Obligations of the Operator
2.1. The Operator has the right to:
2.2. The Operator is obligated to:
3. Basic Rights and Obligations of Personal Data Subjects
3.1. Personal data subjects have the right to:
4. Principles of Personal Data Processing
4.1. Personal data shall be processed lawfully and fairly.
4.2. Personal data shall be processed only to achieve specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes for which it was collected is prohibited.
4.3. Databases containing personal data processed for incompatible purposes shall not be combined.
4.4. Only personal data that is relevant to the purposes for which it is processed shall be processed.
4.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Processed personal data shall not be excessive in relation to the stated purposes of processing.
4.6. When processing personal data, the accuracy, sufficiency and, where necessary, relevance of the personal data in relation to the purposes for which it is processed shall be ensured. The Operator shall take the necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.
4.7. Personal data is stored in a form that allows identification of the data subject for no longer than required for the purposes of processing the personal data, unless the storage 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 upon the achievement of the processing purposes or when such purposes are no longer necessary, unless otherwise provided by federal law.
5. Procedure for the Collection, Storage, Transfer and Other Forms of Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
5.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
5.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent for the Operator to transfer such data to a third party for the fulfillment of obligations under a civil law contract.
5.3. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to info@em-comms.com.
5.4. The Operator ensures the confidentiality of personal data when processing it.
6. List of Actions Performed by the Operator with Obtained Personal Data
6.1. The Operator may collect, record, systematize, accumulate, store, clarify (update, change), retrieve, use, transfer (distribute, provide, access), depersonalize, block, delete and/or destroy personal data.
6.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.
7. Cross-Border Transfer of Personal Data
7.1. Prior to commencing any 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 the cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
7.2. Prior to submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
8. Final Provisions
8.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator via email at info@em-comms.com.
This personal data processing policy has been compiled 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 personal data processing procedure and the measures taken by EM Communications LLC (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator's utmost goal and condition for carrying out such activities is to respect the rights and freedoms of Russian citizens and other individuals when processing their personal data, including the protection of rights to privacy, personal and familial confidentiality.
1.2. The Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information the Operator may receive about visitors to the Operator's websites.
2. Basic Rights and Obligations of the Operator
2.1. The Operator has the right to:
- receive reliable information and/or documents containing personal data from the personal data subject;
- if the personal data subject revokes consent to the processing of personal data, or requests that the processing of personal data be terminated, the Operator has the right to continue processing the personal data without the consent of the personal data subject, provided 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 obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
2.2. The Operator is obligated to:
- provide the personal data subject, upon request, with information regarding the processing of their personal data;
- organize the processing of personal data in accordance with the current legislation of the Russian Federation;
- respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 10 days of receipt of such 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 unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution or other illegal actions in relation to personal data;
- cease transferring (distributing, providing, accessing) personal data, cease processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law;
- fulfill other obligations stipulated by the Personal Data Law.
3. Basic Rights and Obligations of Personal Data Subjects
3.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, except in cases where 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;
- request that the Operator clarify their personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
- revoke consent to the processing of personal data, as well as request the termination of the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against any potentially unlawful action or inaction by the Operator in the processing of their personal data;
- to exercise other rights stipulated by the laws of the Russian Federation.
- provide the Operator with accurate information about themselves;
- notify the Operator of any clarifications (updates, changes) to their personal data.
4. Principles of Personal Data Processing
4.1. Personal data shall be processed lawfully and fairly.
4.2. Personal data shall be processed only to achieve specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes for which it was collected is prohibited.
4.3. Databases containing personal data processed for incompatible purposes shall not be combined.
4.4. Only personal data that is relevant to the purposes for which it is processed shall be processed.
4.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Processed personal data shall not be excessive in relation to the stated purposes of processing.
4.6. When processing personal data, the accuracy, sufficiency and, where necessary, relevance of the personal data in relation to the purposes for which it is processed shall be ensured. The Operator shall take the necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.
4.7. Personal data is stored in a form that allows identification of the data subject for no longer than required for the purposes of processing the personal data, unless the storage 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 upon the achievement of the processing purposes or when such purposes are no longer necessary, unless otherwise provided by federal law.
5. Procedure for the Collection, Storage, Transfer and Other Forms of Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
5.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
5.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent for the Operator to transfer such data to a third party for the fulfillment of obligations under a civil law contract.
5.3. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to info@em-comms.com.
5.4. The Operator ensures the confidentiality of personal data when processing it.
6. List of Actions Performed by the Operator with Obtained Personal Data
6.1. The Operator may collect, record, systematize, accumulate, store, clarify (update, change), retrieve, use, transfer (distribute, provide, access), depersonalize, block, delete and/or destroy personal data.
6.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.
7. Cross-Border Transfer of Personal Data
7.1. Prior to commencing any 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 the cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
7.2. Prior to submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
8. Final Provisions
8.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator via email at info@em-comms.com.