1. General Provisions
This Personal Data Processing Policy is drafted in accordance with the Law "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 carried out by the Operator (hereinafter – the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets, to be its most important goal and condition for conducting its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information the Operator may obtain about visitors to the website https://www.v-doma.com.
2. Key Terms 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 personal data processing (except when processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://www.v-doma.com.
2.4. Personal data information system – a set of personal data contained in databases and the technologies and technical tools ensuring their processing.
2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine, without using additional information, the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or a 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), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state or municipal body, legal or natural person who, independently or jointly with others, 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 related directly or indirectly to a specific or identifiable User of the website https://www.v-doma.com.
2.9. Personal data allowed by the subject for dissemination – personal data to which an unlimited number of persons have access, granted by the data subject by giving consent for the processing of personal data allowed for dissemination, in accordance with the procedure stipulated by the Personal Data Law (hereinafter – personal data allowed for dissemination).
2.10. User – any visitor of the website https://www.v-doma.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle 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 at familiarizing an unlimited number of persons with personal data, including publication 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 an authority of a foreign state, foreign natural or legal person.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further recovery in the personal data information system and/or destruction of material carriers of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the data subject accurate information and/or documents containing personal data;
— in the event of the withdrawal by the data subject of consent to the processing of personal data, and in the case of a request to terminate processing, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds provided for by the Personal Data Law;
— independently determine the list and composition of measures necessary and sufficient to ensure the fulfillment of obligations under the Personal Data Law and regulatory legal acts adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the data subject, upon request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with current legislation;
— respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of data subjects the required information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions;
— terminate the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in cases provided for by the Personal Data Law;
— fulfill other obligations stipulated 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 about the processing of their personal data, except as provided by federal laws. Information is provided by the Operator to the data subject in an accessible form and should not contain personal data related to other subjects unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand the Operator to clarify their personal data, block or destroy them if they are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the declared purpose of processing, as well as take legal measures to protect their rights;
— set a condition of prior consent for the processing of personal data for the purpose of marketing goods, works, and services;
— withdraw consent to the processing of personal data, and submit a request to stop processing;
— appeal unlawful acts or omissions of the Operator to the authorized body for the protection of data subjects' rights or in court;
— exercise other rights provided for by legislation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of clarification (updating, modification) of their personal data.
4.3. Persons who have provided inaccurate information about themselves or about another personal data subject without the latter’s consent are liable in accordance with the law.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not allowed.
5.3. It is not permitted to combine databases containing personal data that are processed for incompatible purposes.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the declared purposes of processing. Excessive processing of personal data in relation to the declared purposes is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of their processing are ensured. The Operator takes necessary measures and/or ensures their implementation to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized after the achievement of processing purposes or when there is no further 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 |
|---|---|
| Legal Grounds | consent to the processing of personal data |
| Personal Data | last name, first name, patronymic; email address; phone numbers |
7. Legal Grounds for Personal Data Processing
7.1. The legal grounds for personal data processing by the Operator are:
— contracts concluded between the Operator and the data subject;
— federal laws and other legal acts in the field of personal data protection;
— consent of Users to the processing of their personal data, to the processing of personal data allowed for dissemination.
7.2. The Operator processes the User’s personal data only if it is filled in and/or submitted by the User independently through special forms located on the website https://www.v-doma.com or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
7.3. The Operator processes depersonalized data about the User if it is allowed in the User's browser settings (e.g., saving cookies and using JavaScript technology).
7.4. The data subject independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.
8. Conditions for Personal Data Processing
8.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
8.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty or law, for the exercise of the functions, powers, and duties assigned to the Operator by legislation.
8.3. The processing of personal data is necessary for the administration of justice, execution of a court decision, or an act of another body or official to be enforced according to legislation.
8.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party or for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will benefit or act as a guarantor.
8.5. 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 data subject are not violated.
8.6. The processing of personal data is carried out for personal data that is made publicly available by the data subject or at their request (hereinafter – publicly available personal data).
8.7. Processing of personal data subject to publication or mandatory disclosure under federal law is carried out in accordance with the procedures established by law.
9. Procedure for Collection, Storage, Transmission, 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 meet fully the requirements of current legislation in the field of personal data protection.
9.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access by unauthorized persons.
9.2. The User’s personal data will never be transferred to third parties under any circumstances, except in cases related to compliance with applicable law or if the data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
9.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address info@v-doma.com marked “Personal data update.”
9.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different term is established by the contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification via email to the Operator at info@v-doma.com marked “Withdrawal of consent to the processing of personal data.”
9.5. All information that is collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject agrees with those documents. The Operator is not responsible for the actions of third parties, including service providers specified in this clause.
9.6. Prohibitions on the transfer (except granting access), as well as the processing or conditions of processing (except for access), of personal data permitted for dissemination by the data subject do not apply in cases of processing personal data in state, public, and other public interests as defined by legislation.
9.7. The Operator ensures the confidentiality of personal data during processing.
9.8. The Operator stores personal data in a form that allows identifying the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor.
9.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the data subject’s consent, or the withdrawal of consent by the data subject, as well as the identification of unlawful processing of personal data.
10. List of Actions Performed by the Operator with Received Personal Data
10.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
10.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
11. Cross-Border Transfer of Personal Data
11.1. Before starting the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state, to whose territory the transfer of personal data is intended, provides reliable protection of the rights of personal data subjects.
11.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if there is written consent of the personal data subject for the cross-border transfer of their personal data and/or the execution of a contract to which the personal data subject is a party.
12. Final Provisions
12.1. The User can receive any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator via email at info@v-doma.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://www.v-doma.com/privacy-policy.