1. General provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” of July 27, 2006 (hereinafter, the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken by DATA WAVE LLC (hereinafter, the “Operator”) to ensure the security of personal data.
1.1. The Operator's most important objective and condition for carrying out its activities is the observance of human and civil rights and freedoms in the processing of an individual's personal data, including the protection of the rights to privacy and to personal and family secrecy.
1.2. This Personal Data Processing Policy of the Operator (hereinafter, the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://data-wave.ru.
2. Key terms used in the Policy
2.1. Automated processing of personal data: the processing of personal data by means of computer technology.
2.2. Blocking of personal data: the temporary cessation of personal data processing (except where the processing is necessary to rectify the personal data).
2.3. Website: a set of graphic and informational materials, as well as the computer programs and databases that ensure their availability on the Internet at the network address https://data-wave.ru.
2.4. Personal data information system: a set of personal data contained in databases, together with the information technologies and technical means that ensure its 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 personal data subject.
2.6. Processing of personal data: any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including the collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator: a state body, municipal body, legal entity or individual organizing and/or carrying out the processing of personal data, independently or jointly with other persons, as well as determining the purposes of personal data processing, the composition of the 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://data-wave.ru.
2.9. Personal data authorized by the personal data subject for dissemination: personal data to which access by an unlimited range of persons has been granted by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for dissemination in the manner provided for by the Personal Data Law (hereinafter, “personal data authorized for dissemination”).
2.10. User: any visitor to the website https://data-wave.ru.
2.11. Provision of personal data: actions aimed at disclosing personal data to a specific person or a specific range of persons.
2.12. Dissemination of personal data: any actions aimed at disclosing personal data to an indefinite range of persons (transfer of personal data) or at familiarizing an unlimited range of persons with personal data, including making personal data public in the mass media, posting it on information and telecommunication networks or providing access to personal data in any other manner.
2.13. Cross-border transfer of personal data: the transfer of personal data to the territory of a foreign state to an authority of that foreign state, a foreign individual 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 subsequently restoring the content of the personal data in the personal data information system and/or the physical media containing personal data are destroyed.
3. Key rights and obligations of the Operator
3.1. The Operator has the right to:
– receive accurate information and/or documents containing personal data from the personal data subject;
– in the event that the personal data subject withdraws consent to the processing of personal data, the Operator is entitled to continue processing personal data without the consent of the personal data subject where 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 the regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
– provide the personal data subject, at their request, with information concerning the processing of their personal data;
– organize the processing of personal data in the manner established by the applicable 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;
– provide the authorized body for the protection of the rights of personal data subjects, at the request of that body, with the necessary information within 30 days from the date of receipt of such a 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 to it, destruction, modification, blocking, copying, provision or dissemination of personal data, as well as against other unlawful actions in relation to personal data;
– cease the transfer (dissemination, provision, access) of personal data, cease the processing of personal data and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
– perform other obligations provided for by the Personal Data Law.
4. Key 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 the cases provided for by federal laws. Such information is 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, except where there are lawful grounds for disclosing such personal data. The list of such information and the procedure for obtaining it are established by the Personal Data Law;
– demand that the Operator rectify, block or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
– set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
– withdraw consent to the processing of personal data;
– appeal against unlawful actions or omissions of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
– 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 data about themselves;
– notify the Operator of any rectification (updating, modification) of their personal data.
4.3. Persons who have submitted to the Operator false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Depersonalized data about visitors (including cookies) is also collected and processed on the website using web analytics services (Yandex Metrica, Google Analytics and others).
5.5. The data listed above is hereinafter collectively referred to in the Policy as Personal Data.
5.6. The Operator does not process special categories of personal data concerning racial or national origin, political views, religious or philosophical beliefs or intimate life.
5.7. The processing of personal data authorized for dissemination that belongs to the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions provided for by Article 10.1 of the Personal Data Law are observed.
5.8. The User's consent to the processing of personal data authorized for dissemination is formalized separately from other consents to the processing of their personal data. In doing so, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 The User gives consent to the processing of personal data authorized for dissemination directly to the Operator.
5.8.2 The Operator is obliged, no later than three business days after receiving the User's said consent, to publish information on the conditions of processing and on the existence of prohibitions and conditions on the processing by an unlimited range of persons of personal data authorized for dissemination.
5.8.3 The transfer (dissemination, provision, access) of personal data authorized by the personal data subject for dissemination must be ceased at any time upon the demand of the personal data subject. Such a demand must include the last name, first name, patronymic (if any) and contact information (phone number, email address or postal address) of the personal data subject, as well as a list of the personal data whose processing is to be ceased. The personal data specified in such a demand may be processed only by the Operator to which the demand is addressed.
5.8.4 Consent to the processing of personal data authorized for dissemination ceases to be effective from the moment the Operator receives the demand specified in clause 5.8.3 of this Personal Data Processing Policy.
6. Principles of personal data processing
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The 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 permitted.
6.3. Combining databases containing personal data that is processed for mutually incompatible purposes is not permitted.
6.4. Only personal data that meets the purposes of its processing is subject to processing.
6.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of its processing.
6.6. When personal data is processed, its accuracy, sufficiency and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or rectify incomplete or inaccurate data.
6.7. Personal data is stored in a form that makes it possible to identify the personal data subject, for no longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law or by a contract to which the personal data subject is a party or under which the personal data subject is a beneficiary or guarantor. The personal data processed is destroyed or depersonalized upon achievement of the purposes of processing or when it is no longer necessary to achieve these purposes, unless otherwise provided for by federal law.
7. Purposes of personal data processing
7.1. Purposes of processing the User's personal data:
– informing the User by sending emails;
– conclusion, performance and termination of civil law contracts;
– providing the User with access to the services, information and/or materials contained on the website https://data-wave.ru.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may always opt out of receiving informational messages by sending the Operator an email at info@datawave.ru marked “Opt-out of notifications about new products and services and special offers”.
7.3. Depersonalized data of Users collected using web analytics services is used to collect information about the actions of Users on the website and to improve the quality of the website and its content.
8. Legal grounds for personal data processing
8.1. The legal grounds for the processing of personal data by the Operator are:
– the Operator's charter (constituent) documents;
– contracts concluded between the Operator and the personal data subject;
– federal laws and other regulatory legal acts in the field of personal data protection;
– Users' consents to the processing of their personal data and to the processing of personal data authorized for dissemination.
8.2. The Operator processes the User's personal data only if it is filled in and/or submitted by the User independently through the special forms located on the website https://data-wave.ru or sent to the Operator by email. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their agreement with this Policy.
8.3. The Operator processes depersonalized data about the User if this is permitted by the User's browser settings (the storage of cookies and the use of JavaScript technology are enabled).
8.4. The personal data subject independently decides on the provision of their personal data and gives consent freely, of their own will and in their own interest.
9. Conditions for personal data processing
9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, as well as to carry out the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act, an act of another body or an act of an official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or under which the personal data subject is a 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.
9.5. The processing of personal data 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.
9.6. Processing is carried out in respect of personal data to which access by an unlimited range of persons has been granted by the personal data subject or at their request (hereinafter, “publicly available personal data”).
9.7. Processing is carried out in respect of personal data subject to publication or mandatory disclosure in accordance with federal law.
10. Procedure for the collection, storage, transfer and other types of processing of personal data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
10.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has given the Operator consent to the transfer of the data to a third party for the performance of obligations under a civil law contract.
10.3. If any inaccuracies are found in the personal data, the User may update it independently by sending a notice to the Operator at the Operator's email address info@datawave.ru marked “Personal data update”.
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by a contract or applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator's email address info@datawave.ru marked “Withdrawal of consent to the processing of personal data”.
10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to independently familiarize themselves with those documents in a timely manner. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause.
10.6. The prohibitions established by the personal data subject on the transfer (other than the provision of access), as well as on the processing or the conditions of processing (other than obtaining access), of personal data authorized for dissemination do not apply in cases where personal data is processed in state, societal and other public interests defined by the legislation of the Russian Federation.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject, for no longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law or by a contract to which the personal data subject is a party or under which the personal data subject is a beneficiary or guarantor.
10.9. A condition for the cessation of personal data processing may be the achievement of the purposes of personal data processing, the expiry of the term of the personal data subject's consent or the withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.
11. List of actions performed by the Operator with the personal data obtained
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the information obtained via information and telecommunication networks.
12. Cross-border transfer of personal data
12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to verify that the foreign state to whose territory the personal data is intended to be transferred ensures reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only with the written consent of the personal data subject to the cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.
13. Confidentiality of personal data
The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties and not to disseminate it without the consent of the personal data subject, unless otherwise provided for by federal law.
14. Final provisions
14.1. The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator by email at info@datawave.ru.
14.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://data-wave.ru/politika-v-otnoshenii-obrabotki-personalnyh-dannyh/
