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 Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Global Resident (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy, as its most important goal and condition for its activities.
1.2. This Operator's Policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://global-resident.ru.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary suspension of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, accessible on the Internet at https://global-resident.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. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other personal data subject.
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), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and 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://global-resident.ru.
2.9. Personal data authorized by the personal data subject for distribution — personal data to which an unlimited number of persons have been granted access by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data authorized for distribution).
2.10. User — any visitor to the website https://global-resident.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. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in mass media, placement 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 a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Fundamental Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive reliable information and/or documents containing personal data from the personal data subject;
- in case of withdrawal of consent to the processing of personal data by the personal data subject, as well as the submission of a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
- provide information concerning the processing of personal data upon request of the personal data subject;
- 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 Law on Personal Data;
- report the necessary information to the authorized body for the protection of the rights of personal data subjects upon request of that body 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, distribution of personal data, as well as from other unlawful actions with respect to personal data;
- cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided by the Law on Personal Data;
- fulfill other obligations provided by the Law on Personal Data.
4. Fundamental 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 by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it shall not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
- demand from the operator clarification of their personal data, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
- require 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, as well as submit a request 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 actions or inaction of the Operator in the processing of their personal data;
- exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with reliable data about themselves;
- notify the Operator of clarification (updating, modification) 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 the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. During the processing of personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing personal data is ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails.
Personal data:
- surname, first name, patronymic;
- email address;
- phone numbers.
Legal grounds:
Federal Law "On Information, Information Technologies and Protection of Information" dated July 27, 2006 No. 149-FZ.
Types of personal data processing:
- collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data;
- sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to exercise the functions, powers and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding 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. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data to which an unlimited number of persons have been granted access by the personal data subject or at their request (hereinafter referred to as publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
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 current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or in case the personal data subject has given the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address privacy@global-resident.ru with the note "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 another period is provided for by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to the Operator's email address privacy@global-resident.ru with the note "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 said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Restrictions on transfer (except for providing access), as well as on processing or conditions of processing (except for gaining access) of personal data authorized for distribution, established by the personal data subject, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The conditions for termination of processing of personal data may include the achievement of the purposes of processing personal data, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to cease the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transmission of obtained information via information and telecommunication networks or without it.
10. Cross-border Transfer of Personal Data
10.1. Before commencing 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 cross-border transfer of personal data (such notification is submitted separately from the notification of the intention to process personal data).
10.2. Before 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.
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 and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may receive any clarifications on issues related to the processing of their personal data by contacting the Operator via email at privacy@global-resident.ru.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://global-resident.ru/privacy-policy/.
