PERSONAL DATA PROCESSING POLICY
1. General Provisions
This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152‑FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Individual Entrepreneur Belousova Valeria Andreevna, OGRNIP 320482700010764 (hereinafter — the Operator).
1.1. The Operator’s primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Operator’s Policy on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://apex-cgi.com.
2. Basic terms used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except when processing is necessary to update personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://apex-cgi.com.
2.4. Personal data information system — a set of personal data contained in databases, and the information technologies and technical means ensuring their processing.
2.5. Depersonalisation of personal data — actions as a result of which it becomes impossible to determine, without 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 using automation means or without such means with personal data, including collection, recording, systematisation, accumulation, storage, updating (modification, change), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data.
2.7. Operator — a state or municipal body, legal entity or individual that independently or jointly with other persons organises and/or carries out the processing of personal data, and also determines the purposes of processing, the composition of personal data to be processed, and the 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://apex-cgi.com.
2.9. Personal data permitted for dissemination by the personal data subject — personal data to which an unlimited circle of persons is granted access by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor of the website https://apex-cgi.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including making personal data public in the media, posting them in information and telecommunications 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 irrevocably destroyed without the possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— in the event the personal data subject withdraws consent to the processing of personal data, as well as upon receiving a request to stop processing 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 Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator must:
— provide the personal data subject, upon request, with information regarding the processing of his/her personal data;
— organise the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— notify the authorised body for the protection of the rights of personal data subjects, upon request, of the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Policy on personal data processing;
— take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions regarding personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other duties provided for by the Personal Data Law.
4. Basic 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 for by federal laws. The information is provided by the Operator to the personal data subject in an accessible form and must not contain personal data relating to other personal data subjects, unless 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 update their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights;
— impose a condition of prior consent when processing personal data for the purpose of marketing goods, works and services;
— withdraw consent to the processing of personal data, as well as to submit a request to stop processing personal data;
— appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorised 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 must:
— provide the Operator with accurate data about themselves;
— inform the Operator of any updates (changes, modifications) of their personal data.
4.3. Persons who provide the Operator with false 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. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, pre‑determined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging databases containing personal data processed for purposes incompatible with each other is not allowed.
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. Redundancy of processed personal data in relation to the stated purposes of processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and where necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or update incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identifying the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalised upon achievement of the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided for 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” No. 149‑FZ of July 27, 2006.
Types of processing of personal data:
7. Conditions for processing personal data
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of his/her personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing 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. Personal data processing 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. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data to which the personal data subject provides unrestricted access (hereinafter — 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 by implementing legal, organisational 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 prevent unauthorised persons from accessing personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator’s email address info@apex-cgi.com marked “Updating personal data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or current legislation.
The User may at any time withdraw his/her consent to the processing of personal data by sending a notice to the Operator’s email address info@apex-cgi.com marked “Withdrawal of consent to personal data processing”.
8.5. All information collected by third‑party services, including payment systems, communication means 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 [should familiarise themselves] with the said documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, established by the personal data subject, do not apply in cases of processing personal data for state, public or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
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 is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. The termination of personal data processing may be conditioned by: achievement of the purposes of processing, expiry of the consent period, withdrawal of consent by the personal data subject or a request to stop processing, as well as detection of unlawful processing of personal data.
9. Перечень действий, производимых Оператором с полученными персональными данными
9.1. Оператор осуществляет сбор, запись, систематизацию, накопление, хранение, уточнение (обновление, изменение), извлечение, использование, передачу (распространение, предоставление, доступ), обезличивание, блокирование, удаление и уничтожение персональных данных.
9.2. Оператор осуществляет автоматизированную обработку персональных данных с получением и/или передачей полученной информации по информационно-телекоммуникационным сетям или без таковой.
9. List of actions performed by the Operator with obtained personal data
9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, updating (modification, change), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving/transmitting the received information via information and telecommunications networks.
10. Cross‑border transfer of personal data
10.1. Before starting cross‑border transfer of personal data, the Operator must notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross‑border transfer of personal data (such notice is sent separately from the notice of intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain from the foreign state authorities, foreign individuals, foreign legal entities to whom the cross‑border transfer of personal data is planned, the relevant information.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarifications regarding the processing of his/her personal data by contacting the Operator via email at info@apex-cgi.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. 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://apex-cgi.com/privacy.
1. General Provisions
This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152‑FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Individual Entrepreneur Belousova Valeria Andreevna, OGRNIP 320482700010764 (hereinafter — the Operator).
1.1. The Operator’s primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Operator’s Policy on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://apex-cgi.com.
2. Basic terms used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except when processing is necessary to update personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://apex-cgi.com.
2.4. Personal data information system — a set of personal data contained in databases, and the information technologies and technical means ensuring their processing.
2.5. Depersonalisation of personal data — actions as a result of which it becomes impossible to determine, without 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 using automation means or without such means with personal data, including collection, recording, systematisation, accumulation, storage, updating (modification, change), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data.
2.7. Operator — a state or municipal body, legal entity or individual that independently or jointly with other persons organises and/or carries out the processing of personal data, and also determines the purposes of processing, the composition of personal data to be processed, and the 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://apex-cgi.com.
2.9. Personal data permitted for dissemination by the personal data subject — personal data to which an unlimited circle of persons is granted access by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor of the website https://apex-cgi.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including making personal data public in the media, posting them in information and telecommunications 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 irrevocably destroyed without the possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— in the event the personal data subject withdraws consent to the processing of personal data, as well as upon receiving a request to stop processing 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 Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator must:
— provide the personal data subject, upon request, with information regarding the processing of his/her personal data;
— organise the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— notify the authorised body for the protection of the rights of personal data subjects, upon request, of the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Policy on personal data processing;
— take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions regarding personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other duties provided for by the Personal Data Law.
4. Basic 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 for by federal laws. The information is provided by the Operator to the personal data subject in an accessible form and must not contain personal data relating to other personal data subjects, unless 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 update their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights;
— impose a condition of prior consent when processing personal data for the purpose of marketing goods, works and services;
— withdraw consent to the processing of personal data, as well as to submit a request to stop processing personal data;
— appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorised 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 must:
— provide the Operator with accurate data about themselves;
— inform the Operator of any updates (changes, modifications) of their personal data.
4.3. Persons who provide the Operator with false 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. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, pre‑determined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging databases containing personal data processed for purposes incompatible with each other is not allowed.
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. Redundancy of processed personal data in relation to the stated purposes of processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and where necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or update incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identifying the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalised upon achievement of the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided for 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” No. 149‑FZ of July 27, 2006.
Types of processing of personal data:
- Collection, recording, systematisation, accumulation, storage, destruction and depersonalisation of personal data; sending informational emails to the email address.
7. Conditions for processing personal data
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of his/her personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing 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. Personal data processing 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. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data to which the personal data subject provides unrestricted access (hereinafter — 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 by implementing legal, organisational 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 prevent unauthorised persons from accessing personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator’s email address info@apex-cgi.com marked “Updating personal data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or current legislation.
The User may at any time withdraw his/her consent to the processing of personal data by sending a notice to the Operator’s email address info@apex-cgi.com marked “Withdrawal of consent to personal data processing”.
8.5. All information collected by third‑party services, including payment systems, communication means 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 [should familiarise themselves] with the said documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, established by the personal data subject, do not apply in cases of processing personal data for state, public or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
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 is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. The termination of personal data processing may be conditioned by: achievement of the purposes of processing, expiry of the consent period, withdrawal of consent by the personal data subject or a request to stop processing, as well as detection of unlawful processing of personal data.
9. Перечень действий, производимых Оператором с полученными персональными данными
9.1. Оператор осуществляет сбор, запись, систематизацию, накопление, хранение, уточнение (обновление, изменение), извлечение, использование, передачу (распространение, предоставление, доступ), обезличивание, блокирование, удаление и уничтожение персональных данных.
9.2. Оператор осуществляет автоматизированную обработку персональных данных с получением и/или передачей полученной информации по информационно-телекоммуникационным сетям или без таковой.
9. List of actions performed by the Operator with obtained personal data
9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, updating (modification, change), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving/transmitting the received information via information and telecommunications networks.
10. Cross‑border transfer of personal data
10.1. Before starting cross‑border transfer of personal data, the Operator must notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross‑border transfer of personal data (such notice is sent separately from the notice of intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain from the foreign state authorities, foreign individuals, foreign legal entities to whom the cross‑border transfer of personal data is planned, the relevant information.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarifications regarding the processing of his/her personal data by contacting the Operator via email at info@apex-cgi.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. 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://apex-cgi.com/privacy.
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