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1. General terms
This Privacy Policy was drawn in compliance with the Federal Law No.152-FZ "On Personal Data" of July 27, 2006 ("the Law on Personal Data") and defines a procedure for processing personal data and measures for protecting personal data taken by ТОО "FLAVIUM AGENCY" ("the Operator").
1.1. When processing personal data, the Operator is committed to respecting human rights and freedoms, including, but not limited to, personal and family privacy.
1.2. The Operator's policy on the processing of personal data ("the Policy") is applied to all information that the Operator can obtain about the users of the website flavium.agency
2. Key definitions
2.1. "Automated processing of personal data" means the processing of personal data with the use of computing equipment.
2.2. "Blocking of personal data" means a temporary termination of personal data processing, except when it serves to correct personal data. 2.3. "Website" means a set of graphic and information materials, as well as software and databases that make it available on the Internet at flavium.agency.
2.4. "Information system of personal data" means personal data contained in databases, as well as technologies and technical devices for processing such data.
2.5. "Depersonalization of personal data" means actions that make it impossible to relate, without additional information, personal data to a specific User or other personal data subject.
2.6. "Processing of personal data" means any action (operation), or set of actions (operations), performed, with or without the use of automation tools, in respect to personal data, including collecting, recording, organizing, accumulating, storing, correcting (updating, modifying), retrieving, using, transferring (distributing, sharing, providing access), depersonalizing, blocking, erasing and destroying personal data.2.7. "Operator" means a federal or local authority, company, or individual, which, on their own or with others, organizes and/or performs the processing of personal data, and defines the purposes of such processing, types of personal data subject to processing, and a set of actions (operations) performed with personal data.
2.8. "Personal data" means any information relating, directly or indirectly, to any identified or identifiable User of the website flavium.agency.
2.9. "Personal data allowed for distribution by a personal data subject" means personal data, which a personal data subject has made available to an indefinite number of persons by giving their consent to the processing of personal data, and which has been allowed by a personal data subject for distribution as provided by the Law on Personal Data ("personal data allowed for distribution").
2.10. "User" means any visitor of the website flavium.agency.
2.11. "Sharing of personal data" means a set of actions that serve to disclose personal data to a specific person or persons.
2.12. "Distribution of personal data" means any actions that serve to disclose personal data, or make it available, to an indefinite number of persons (personal data transfer), including publicly releasing personal data in mass media or information and telecommunication networks, or providing access to personal data in any other way.
2.13. "Cross-border transfer of personal data" means transfer of personal data to a foreign authority, foreign individual or foreign company located on the territory of a foreign state.
2.14. "Destruction of personal data" means any action that results in irrevocable destruction of personal data, which makes it impossible to restore such data in the information system of personal data, and/or destruction of physical carriers of personal data.
3. The Operator's rights and obligations
3.1. The Operator has a right to:
— receive from a personal data subject accurate information and/or documents containing personal data;
— should a personal data subject withdraw their consent to the processing of personal data, or file a request to terminate the processing of personal data, the Operator has a right to continue processing personal data without the subject's consent, if allowed under the Law on Personal Data;
— define a set of measures that are necessary and sufficient to fulfill its obligations under the Law on Personal Data and related regulations, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
—upon request from a personal data subject, provide them with information regarding the processing of their personal data;
— perform the processing of personal data under the existing laws of the Russian Federation;
— respond to inquiries and requests from subjects of personal data and their lawful representatives in compliance with the Law on Personal Data;
— upon request from an authority that protects the rights of personal data subjects, provide such authority with requested information within 10 days of receipt of the inquiry;
— publish or otherwise provide unlimited access to this Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or random access, destruction, modification, blocking, copying, sharing, and distribution, as well as other unlawful actions in regard to personal data;
— terminate the transfer (distribution, sharing, providing access) of personal data and destroy personal data as stipulated in the Law on Personal Data;
— perform other obligations under the Law on Personal Data.
4. Key rights and obligations of personal data subjects
4.1. Subjects of personal data have a right to:
— obtain information about the processing of personal data, except in cases provided by federal laws. The Operator will provide such information to a personal data subject in accessible form. Such information will not contain personal data related to other subjects of personal data, unless there are lawful reasons for disclosing such personal data. Types of such information and procedure for obtaining it is stipulated in the Law on Personal Data;
— request that the Operator corrects, blocks or destroys their personal data, if such data is incomplete, dated, inaccurate, unlawfully obtained or is not necessary for achieving the specified purpose, as well as take lawful measures to ensure the protection of their rights;
— request that the Operator should obtain their consent before processing personal data to promote products and services;
— withdraw their consent to personal data processing, as well as request the termination of personal data processing;
— file a complaint with an authority that protects the rights of personal data subjects or take legal action against the Operator's actions, or lack thereof, when processing their personal data;
— exercise other rights under the laws of the Russian Federation.
4.2. Subjects of personal data will:
— provide the Operator with accurate data;
— notify the Operator of the need to correct (update, modify) their personal data.
4.3. Persons, who provided the Operator with inaccurate data, or data on another subject without the latter's consent, will be held liable under the laws of the Russian Federation.
5. Principles of personal data processing
5.1. Processing of personal data is performed in a lawful and fair way.
5.2. Processing of personal data is limited by achieving specific, pre-determined, and lawful purposes. Processing of personal data, which does not serve to achieve the purposes of personal data collecting, is not allowed.
5.3. Combining databases that contain personal data, which is processed for incompatible purposes, is not allowed.
5.4. The Operator is only allowed to process personal data that serves the purposes of its processing.
5.5. Types and amount of processed personal data will correspond to the specified purposes of processing. Processing of excessive data, which does not serve to achieve the specified purposes, is not allowed.
5.6. Processing of personal data requires that such data is accurate, sufficient, and, if necessary, relevant for achieving the purposes of processing. The Operator will take the necessary steps, and/or ensure that such steps are taken, to erase or correct incomplete or inaccurate personal data.
5.7. Personal data will be stored in a form that allows for identification of a personal data subject, but no longer than required for the purposes of personal data processing, unless personal data storage times are provided by a federal law or a contract, to which a personal data subject is a party, beneficiary or guarantor. Processed personal data will be destroyed or depersonalized upon the achievement of the purposes of processing, or if achieving such purposes is no longer relevant and necessary, unless otherwise provided by a federal law.
6. Purposes of personal data processing
The purposes of personal data processing include entering into, execution, and termination of civil contracts.
Personal data:
Federal Law No.149-FZ "On Information, Information Technologies, and Protection of Information" of July 27, 2006
Types of personal data processing:
Collecting, recording, organizing, accumulating, storing, destructing, and depersonalizing personal data
7. Terms of personal data processing
7.1. Personal data is processed upon consent of a personal data subject.
7.2. Processing of personal data serves to achieve the purposes provided by an international contract or a law of the Russian Federation, and allows the Operator to exercise its functions, powers, and obligations under the law of the Russian Federation.
7.3. Processing of personal data serves to ensure justice, execute a decision made by a court or by other authority or official, which is enforceable under the laws of the Russian Federation.
7.4. Processing of personal data serves to execute a contract, to which a personal data subject is a party, beneficiary or guarantor; or to enter into a contract on the initiative of a personal data subject, or a contract, to which a personal data subject is a beneficiary or guarantor.
7.5. Processing of personal data serves to exercise the rights and lawful interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of a personal data subject are not infringed.
7.6. The Operator processes personal data, which has been made available to an unlimited number of persons by a personal data subject, or upon their request ("publicly available data").
7.7. The Operator processes personal data, which is subject to publication or mandatory disclosure under a federal law.
8. Procedure for collecting, storing, transferring, and other types of personal data processing
The safety of personal data processed by the Operator is ensured through a set of legal, organizational, and technical measures, in full compliance with the existing laws on the protection of personal data.
8.1. The Operator ensures the safety of personal data and takes all possible steps to prevent unauthorized access to such personal data. 8.2. Under no circumstances will a User's personal data be transferred to third parties, except for the purposes of complying with existing laws, or if a personal data subject has granted their consent to transfer such data to third parties for the purposes of fulfilling the obligations under civil contracts.
8.3. Upon detecting inaccuracies in their personal data, a User can update it by writing to the Operator mail@mail.com. The subject line of an email should read "Personal data update".
8.4. Personal data processing times are determined by the achievement of the purposes, for which such data has been collected, unless otherwise provided by a contract or existing laws.
A User can, at any time, withdraw their consent to the processing of their personal data by writing to the Operator at mail@mail.com. The subject line of an email should read "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the Operator under its User Agreement and Privacy Policy. The subject of personal data and / or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned herein.
8.6. User-imposed prohibitions regarding the transfer (except providing access) or processing of personal data, or terms of processing (except obtaining access) of publicly available data do not apply if such data is processed in the interests of the state, or in social or other public interests set forth in the laws of the Russian Federation.
8.7. The Operator will ensure the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows for identification of a personal data subject for no longer than is necessary for the purposes of data processing, unless storage times are provided by a federal law or a contract, to which a personal data subject is a party, beneficiary or guarantor.
8.9. Processing of personal data can be terminated upon the achievement of purposes of data processing, expiration of consent provided by a personal data subject, withdrawal of consent by a personal data subject, request to terminate the processing of personal data, or in cases of unlawful processing of personal data.
9. Actions regarding personal data performed by the Operator
9.1. Actions regarding personal data performed by the Operator include collecting, recording, organizing, accumulating, storing, correcting (updating, modifying), retrieving, using, transferring (distributing, sharing, providing access), depersonalizing, blocking, erasing and destroying personal data.
9.2. The Operator performs automated processing of personal data, with or without receiving and/or transferring obtained information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before performing cross-border transfer of personal data, the Operator will notify a competent authority, which protects the rights of personal data subjects, of its intention to perform cross-border transfer of personal data. Such notification is different from a notification of the intention to process personal data.
10.2. Before sending the notification mentioned in Clause 10.1 hereof, the Operator will receive all the necessary information from foreign authorities, foreign individuals or foreign companies, to whom the Operator intends to transfer personal data.
11. Confidentiality of personal data
The Operator and other parties, which have been granted access to personal data, will not disclose personal data to third parties or distribute personal data without the consent of a personal data subject, unless otherwise provided by a federal law.
12. Final provisions
12.1. A User can make any inquiries regarding the processing of their personal data by writing to the Operator at mail@mail.com.
12.2. This document will contain all changes made to the Policy by the Operator. The Policy is valid indefinitely until replaced by a newer version.
12.3. The current version of this Policy is publicly available on the Internet at flavium.agency.
This Privacy Policy was drawn in compliance with the Federal Law No.152-FZ "On Personal Data" of July 27, 2006 ("the Law on Personal Data") and defines a procedure for processing personal data and measures for protecting personal data taken by ТОО "FLAVIUM AGENCY" ("the Operator").
1.1. When processing personal data, the Operator is committed to respecting human rights and freedoms, including, but not limited to, personal and family privacy.
1.2. The Operator's policy on the processing of personal data ("the Policy") is applied to all information that the Operator can obtain about the users of the website flavium.agency
2. Key definitions
2.1. "Automated processing of personal data" means the processing of personal data with the use of computing equipment.
2.2. "Blocking of personal data" means a temporary termination of personal data processing, except when it serves to correct personal data. 2.3. "Website" means a set of graphic and information materials, as well as software and databases that make it available on the Internet at flavium.agency.
2.4. "Information system of personal data" means personal data contained in databases, as well as technologies and technical devices for processing such data.
2.5. "Depersonalization of personal data" means actions that make it impossible to relate, without additional information, personal data to a specific User or other personal data subject.
2.6. "Processing of personal data" means any action (operation), or set of actions (operations), performed, with or without the use of automation tools, in respect to personal data, including collecting, recording, organizing, accumulating, storing, correcting (updating, modifying), retrieving, using, transferring (distributing, sharing, providing access), depersonalizing, blocking, erasing and destroying personal data.2.7. "Operator" means a federal or local authority, company, or individual, which, on their own or with others, organizes and/or performs the processing of personal data, and defines the purposes of such processing, types of personal data subject to processing, and a set of actions (operations) performed with personal data.
2.8. "Personal data" means any information relating, directly or indirectly, to any identified or identifiable User of the website flavium.agency.
2.9. "Personal data allowed for distribution by a personal data subject" means personal data, which a personal data subject has made available to an indefinite number of persons by giving their consent to the processing of personal data, and which has been allowed by a personal data subject for distribution as provided by the Law on Personal Data ("personal data allowed for distribution").
2.10. "User" means any visitor of the website flavium.agency.
2.11. "Sharing of personal data" means a set of actions that serve to disclose personal data to a specific person or persons.
2.12. "Distribution of personal data" means any actions that serve to disclose personal data, or make it available, to an indefinite number of persons (personal data transfer), including publicly releasing personal data in mass media or information and telecommunication networks, or providing access to personal data in any other way.
2.13. "Cross-border transfer of personal data" means transfer of personal data to a foreign authority, foreign individual or foreign company located on the territory of a foreign state.
2.14. "Destruction of personal data" means any action that results in irrevocable destruction of personal data, which makes it impossible to restore such data in the information system of personal data, and/or destruction of physical carriers of personal data.
3. The Operator's rights and obligations
3.1. The Operator has a right to:
— receive from a personal data subject accurate information and/or documents containing personal data;
— should a personal data subject withdraw their consent to the processing of personal data, or file a request to terminate the processing of personal data, the Operator has a right to continue processing personal data without the subject's consent, if allowed under the Law on Personal Data;
— define a set of measures that are necessary and sufficient to fulfill its obligations under the Law on Personal Data and related regulations, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
—upon request from a personal data subject, provide them with information regarding the processing of their personal data;
— perform the processing of personal data under the existing laws of the Russian Federation;
— respond to inquiries and requests from subjects of personal data and their lawful representatives in compliance with the Law on Personal Data;
— upon request from an authority that protects the rights of personal data subjects, provide such authority with requested information within 10 days of receipt of the inquiry;
— publish or otherwise provide unlimited access to this Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or random access, destruction, modification, blocking, copying, sharing, and distribution, as well as other unlawful actions in regard to personal data;
— terminate the transfer (distribution, sharing, providing access) of personal data and destroy personal data as stipulated in the Law on Personal Data;
— perform other obligations under the Law on Personal Data.
4. Key rights and obligations of personal data subjects
4.1. Subjects of personal data have a right to:
— obtain information about the processing of personal data, except in cases provided by federal laws. The Operator will provide such information to a personal data subject in accessible form. Such information will not contain personal data related to other subjects of personal data, unless there are lawful reasons for disclosing such personal data. Types of such information and procedure for obtaining it is stipulated in the Law on Personal Data;
— request that the Operator corrects, blocks or destroys their personal data, if such data is incomplete, dated, inaccurate, unlawfully obtained or is not necessary for achieving the specified purpose, as well as take lawful measures to ensure the protection of their rights;
— request that the Operator should obtain their consent before processing personal data to promote products and services;
— withdraw their consent to personal data processing, as well as request the termination of personal data processing;
— file a complaint with an authority that protects the rights of personal data subjects or take legal action against the Operator's actions, or lack thereof, when processing their personal data;
— exercise other rights under the laws of the Russian Federation.
4.2. Subjects of personal data will:
— provide the Operator with accurate data;
— notify the Operator of the need to correct (update, modify) their personal data.
4.3. Persons, who provided the Operator with inaccurate data, or data on another subject without the latter's consent, will be held liable under the laws of the Russian Federation.
5. Principles of personal data processing
5.1. Processing of personal data is performed in a lawful and fair way.
5.2. Processing of personal data is limited by achieving specific, pre-determined, and lawful purposes. Processing of personal data, which does not serve to achieve the purposes of personal data collecting, is not allowed.
5.3. Combining databases that contain personal data, which is processed for incompatible purposes, is not allowed.
5.4. The Operator is only allowed to process personal data that serves the purposes of its processing.
5.5. Types and amount of processed personal data will correspond to the specified purposes of processing. Processing of excessive data, which does not serve to achieve the specified purposes, is not allowed.
5.6. Processing of personal data requires that such data is accurate, sufficient, and, if necessary, relevant for achieving the purposes of processing. The Operator will take the necessary steps, and/or ensure that such steps are taken, to erase or correct incomplete or inaccurate personal data.
5.7. Personal data will be stored in a form that allows for identification of a personal data subject, but no longer than required for the purposes of personal data processing, unless personal data storage times are provided by a federal law or a contract, to which a personal data subject is a party, beneficiary or guarantor. Processed personal data will be destroyed or depersonalized upon the achievement of the purposes of processing, or if achieving such purposes is no longer relevant and necessary, unless otherwise provided by a federal law.
6. Purposes of personal data processing
The purposes of personal data processing include entering into, execution, and termination of civil contracts.
Personal data:
- first name, last name, patronymic name;
- email address;
- phone numbers.
Federal Law No.149-FZ "On Information, Information Technologies, and Protection of Information" of July 27, 2006
Types of personal data processing:
Collecting, recording, organizing, accumulating, storing, destructing, and depersonalizing personal data
7. Terms of personal data processing
7.1. Personal data is processed upon consent of a personal data subject.
7.2. Processing of personal data serves to achieve the purposes provided by an international contract or a law of the Russian Federation, and allows the Operator to exercise its functions, powers, and obligations under the law of the Russian Federation.
7.3. Processing of personal data serves to ensure justice, execute a decision made by a court or by other authority or official, which is enforceable under the laws of the Russian Federation.
7.4. Processing of personal data serves to execute a contract, to which a personal data subject is a party, beneficiary or guarantor; or to enter into a contract on the initiative of a personal data subject, or a contract, to which a personal data subject is a beneficiary or guarantor.
7.5. Processing of personal data serves to exercise the rights and lawful interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of a personal data subject are not infringed.
7.6. The Operator processes personal data, which has been made available to an unlimited number of persons by a personal data subject, or upon their request ("publicly available data").
7.7. The Operator processes personal data, which is subject to publication or mandatory disclosure under a federal law.
8. Procedure for collecting, storing, transferring, and other types of personal data processing
The safety of personal data processed by the Operator is ensured through a set of legal, organizational, and technical measures, in full compliance with the existing laws on the protection of personal data.
8.1. The Operator ensures the safety of personal data and takes all possible steps to prevent unauthorized access to such personal data. 8.2. Under no circumstances will a User's personal data be transferred to third parties, except for the purposes of complying with existing laws, or if a personal data subject has granted their consent to transfer such data to third parties for the purposes of fulfilling the obligations under civil contracts.
8.3. Upon detecting inaccuracies in their personal data, a User can update it by writing to the Operator mail@mail.com. The subject line of an email should read "Personal data update".
8.4. Personal data processing times are determined by the achievement of the purposes, for which such data has been collected, unless otherwise provided by a contract or existing laws.
A User can, at any time, withdraw their consent to the processing of their personal data by writing to the Operator at mail@mail.com. The subject line of an email should read "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the Operator under its User Agreement and Privacy Policy. The subject of personal data and / or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned herein.
8.6. User-imposed prohibitions regarding the transfer (except providing access) or processing of personal data, or terms of processing (except obtaining access) of publicly available data do not apply if such data is processed in the interests of the state, or in social or other public interests set forth in the laws of the Russian Federation.
8.7. The Operator will ensure the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows for identification of a personal data subject for no longer than is necessary for the purposes of data processing, unless storage times are provided by a federal law or a contract, to which a personal data subject is a party, beneficiary or guarantor.
8.9. Processing of personal data can be terminated upon the achievement of purposes of data processing, expiration of consent provided by a personal data subject, withdrawal of consent by a personal data subject, request to terminate the processing of personal data, or in cases of unlawful processing of personal data.
9. Actions regarding personal data performed by the Operator
9.1. Actions regarding personal data performed by the Operator include collecting, recording, organizing, accumulating, storing, correcting (updating, modifying), retrieving, using, transferring (distributing, sharing, providing access), depersonalizing, blocking, erasing and destroying personal data.
9.2. The Operator performs automated processing of personal data, with or without receiving and/or transferring obtained information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before performing cross-border transfer of personal data, the Operator will notify a competent authority, which protects the rights of personal data subjects, of its intention to perform cross-border transfer of personal data. Such notification is different from a notification of the intention to process personal data.
10.2. Before sending the notification mentioned in Clause 10.1 hereof, the Operator will receive all the necessary information from foreign authorities, foreign individuals or foreign companies, to whom the Operator intends to transfer personal data.
11. Confidentiality of personal data
The Operator and other parties, which have been granted access to personal data, will not disclose personal data to third parties or distribute personal data without the consent of a personal data subject, unless otherwise provided by a federal law.
12. Final provisions
12.1. A User can make any inquiries regarding the processing of their personal data by writing to the Operator at mail@mail.com.
12.2. This document will contain all changes made to the Policy by the Operator. The Policy is valid indefinitely until replaced by a newer version.
12.3. The current version of this Policy is publicly available on the Internet at flavium.agency.