PSRN 320508100308912
TIN 890304185793
Sole Trader Baranova Irina Vladimirovna
June 20, 2020
Personal Data Processing Policy
1. INTRODUCTION
1.1.The Personal Data Processing Policy (hereinafter referred to as the "Policy") is issued and applied by Sole Trader Baranova Irina Vladimirovna (hereinafter referred to as the "Operator") in accordance with clause 2, Part 1, Article 18.1 of the Federal Law of 27.07.2006 N 152 — FL "On Personal Data"
This Policy defines the procedure and conditions of the Operator in relation to the processing of personal data, establishes provisions aimed at compliance with the legislation of the Russian Federation concerning the processing of personal dataAll issues related to the processing of personal data that are not regulated by this Policy are resolved in accordance with the current legislation of the Russian Federation in the field of personal data.
2.MAIN PROVISIONS
2.1.The purpose of personal data processing is: the provision of services by the Operator on behalf of the personal data subject.
2.2. The processing is organized by the Operator on the principles of:
- legality of the purposes and methods of personal data processing, integrity and fairness in the Operator's activities;
- the reliability of personal data, their sufficiency for the purposes of processing, the inadmissibility of processing personal data that is excessive in relation to the purposes stated when collecting personal data;
- processing only those personal data that meet the purposes of their processing. The processed personal data should not be redundant in relation to the stated purposes of their processing;
- compliance of the content and volume of the processed personal data with the declared processing purposes.
- the inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes that are not compatible with each other;
- ensuring the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing. The operator takes the necessary measures or ensures that they are taken to delete or clarify incomplete or inaccurate data;
- storage of personal data in a form that allows you to determine the subject of personal data, no longer than the purposes of personal data processing require;
- ensuring the recording, systematization, accumulation, storage, clarification (updates, changes), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.
2.3. The Operator processes the following personal data:
- first and last name of the personal data subject;
- phone number of the personal data subject;
- the email address of the personal data subject.
2.4. The personal data specified above are processed using automation tools and without the use of automation tools. When processing personal data without the use of automation tools, the Operator is guided by the Regulation on the specifics of personal data processing carried out without the use of automation tools, approved by the Decree of the Government of the Russian Federation N 687.2.5of September 15, 2008.
2.5.When processing personal data, the Operator applies legal, organizational and technical measures to ensure the security of personal data in accordance with Article 19 of the Federal Law N 152-FL of 27.07.2006 "On Personal Data". The operator provides services by placing its website on the website
https://baron-pro.ru/, which is a software " GETKURS 2.0.", designed to create an online school and organize the learning process on the Internet. On the website getcourse.ruThe HTTPS extension to the HTTP protocol is used in order to increase security and protect information.
2.6.The Operator does not disclose or distribute personal data to third parties without the consent of the personal data subject, except in cases provided for by the current legislation of the Russian Federation and this Policy.
2.7. The assessment of the harm that may be caused to personal data subjects in case of violation by the Operator of the requirements of Federal Law N152-FL "On Personal Data" dated 27.07.2006 is determined in accordance with Articles 15, 151, 152, 1101 of the Civil Code of the Russian Federation.
2.7.1The ratio of the specified harm and the measures taken by the Operator aimed at preventing, preventing and/or eliminating its consequences is determined in accordance with the Federal Law of the Russian Federation of 27.07.2006 N 152-FL "On Personal Data".
2.8. Conditions for processing personal data by the Operator:
1) personal data is processed by the Operator after the subject of personal data accepts the offer for the provision of services.
2) according to paragraph 5 of Article 6 of Federal Law N 152-FL of 27.07.2006 "On Personal Data", the subject of personal data accepts the offer on his own initiative and is a party and beneficiary under the contract concluded by him. In this case, a separate consent to the processing of the subject's personal data is not required.
3) the terms of this Policy are available to users in open access, until the acceptance of the offer for the provision of services.
2.9. The storage of personal data of users is carried out in a form that allows determining the subject of personal data.
2.10.Personal data is subject to destruction upon achievement of the processing purposes. The deletion of personal data is carried out by deleting the account, after which such an account cannot be restored.
2.11. Interaction with federal executive authorities on the processing and protection of personal data of subjects whose personal data is processed by the Operator is carried out within the framework of the legislation of the Russian Federation.
3. THIRD PARTIES INVOLVED IN THE PROCESSING OF PERSONAL DATA
3.1. Sistema GETKURS LLC (https://getcourse.ru/) TIN 9731055900 / IEC 773101001, PSRN 1197746675170, location: 121596, Moscow, Gorbunova Street, house 2 building 3, room 3.
3.2.Hosting services and dedicated server services are provided by Selectel LLC https://selectel.ru/about/details.
4. RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA
4.1.The Operator or his legal representative is responsible for the processing of personal data.
4.2. Responsible for the processing of personal data:
4.2.1.performs internal control over compliance with the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data
4.2.2.controls the reception and processing of requests and requests of personal data subjects or their representatives;
4.2.3. takes measures to detect the facts of unauthorized access to personal data;
4.2.4.performs constant monitoring of ensuring the level of protection of personal data;
4.2.5. performs internal control and (or) audit of compliance of personal data processing with the Federal Law N152-FL of 27.07.2006 "On Personal Data" and regulatory legal acts adopted in accordance with it.
5. THE PROCEDURE FOR ENSURING THE RIGHTS OF THE PERSONAL DATA SUBJECT BY THE OPERATOR
5.1.The subjects of personal data or their representatives have the rights provided for by the Federal Law of 27.07.2006 N 152-FL "On Personal Data".
5.2.The Operator ensures the rights of personal data subjects in accordance with the procedure established by Chapters 3 and 4 of the Federal Law N 152-FL of 27.07.2006 "On Personal Data"
5.3.The powers of the representative to represent the interests of each personal data subject are confirmed by a corresponding power of attorney
5.4. The information specified in Part 7 of Article 22 of the Federal Law N 152-FL of 27.07.2006 "On Personal Data" is provided to the personal data subject in an accessible form without personal data relating to other personal data subjects, except for cases where there are legal grounds for disclosure of such personal data, in electronic form. At the request of the subject of personal data, they can be duplicated on paper.
5.5. The information specified in Part 7 of Article 22 of the Federal Law N 152-FL of 27.07.2006 "On Personal Data" is provided to the subject of personal data or his representative upon personal request or upon receipt of a request from the subject of personal data or his representative. The request must contain the number of the main identity document of the personal data subject or his representative, information about the date of issue of the specified document and the issuing authority, information confirming the participation of the personal data subject in relations with the Operator (contract number, date of conclusion of the contract, conditional verbal designation and (or) other information), or information otherwise confirming the fact of processing personal data by the Operator, the signature of the personal data subject or his representative. If there is a technical possibility, the request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
5.6. The right of the personal data subject to access to his personal data may be restricted in accordance with federal laws.
5.7. The right of the personal data subject to access to his personal data may be restricted in accordance with federal laws.