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Privacy policy

1. General provisions

This regulation, which defines the personal data processing policy, is prepared in accordance with
the requirements of Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” (hereinafter –
Personal Data Law) and defines the personal data processing procedure and personal data security
measures undertaken by the LLC "TeleCom Care" (hereinafter – “Operator”).
1.1. The Operator’s most important objective and condition for carrying out its activities is to
respect human and civil rights and freedoms when processing personal data, including the
protection of the rights to privacy, personal and family secrets.
1.2. The Operator’s personal data processing policy (the “Policy”) applies to all information that
the Operator may receive about visitors to the website https://telecomcare.ru.


2. Basic concepts used in the Policy

2.1. Automated processing of personal data is processing of personal data by means of computer
technology.
2.2. Blocking of personal data is temporary suspension of personal data processing (unless
processing is necessary to clarify personal data).
2.3. The website is a collection of graphic and informational material, as well as computer
programs and databases, making them available on the Internet at a network address
https://telecomcare.ru.
2.4. Personal data information system is the totality of personal data contained in databases of
personal data, and ensuring its processing with the use of information technologies and technical
means.
2.5. De-identification of personal data is actions that make it impossible to determine, without the
use of additional information, whether the personal data belongs to a specific User or another
subject of personal data.
2.6. Processing of personal data is any action (operation) or a set of actions (operations) performed
with or without the use of automation means with personal data, including collection, recording,
systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer
(distribution, provision, access), anonymization, blocking, removal, or destruction of personal
data.
2.7. Operator is a government agency, municipal authority, legal entity or natural person,
independently or together with other persons, arranging and (or) performing processing of personal
data, as well as determining the purposes of personal data processing, composition of personal
data to be processed, actions (operations) performed with personal data.
2.8. Personal data is any information relating directly or indirectly to an identified or identifiable
User of the website https://telecomcare.ru.
2.9. Personal data permitted by the personal data subject for dissemination – personal data to which
access is granted to an unlimited number of persons by the personal data subject by giving consent
to processing of personal data permitted by the personal data subject for dissemination in the
manner prescribed by the Personal Data Law (hereinafter – “personal data permitted for
dissemination”).
2.10. User is any visitor to the website https://telecomcare.ru.
2.11. Provision of personal data is the act of disclosing personal data to a certain person or a certain
circle of persons.
2.12. Dissemination of personal data is any actions aimed at disclosure of personal data to an
indefinite range of persons (transfer of personal data) or to make personal data available to an
unlimited range of persons, including disclosure of personal data in the media, placement in
information and telecommunications networks or providing access to personal data in any other
way.
2.13. Cross-border transfer of personal data is the transfer of personal data to the territory of a
foreign country to a foreign authority, a foreign physical person or a foreign legal entity.
2.14. Destruction of personal data is any action resulting in the destruction of personal data
irretrievably with the impossibility of further restoration of personal data content in the
information system of personal data and (or) destruction of tangible media of personal data.


3. Operator`s rights and obligations

3.1. The Operator has the right to:
– receive accurate information and/or documents containing personal data from the data subject;
– if the personal data subject withdraws their consent to the processing of personal data, the
Operator may continue the processing of personal data without the consent of the personal data
subject on the grounds set out in the Personal Data Law;
– Independently determine the composition and list of measures necessary and sufficient to ensure
the fulfilment of obligations under the Personal Data Law and regulations adopted in accordance
with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
– provide the data subject, at his or her request, with information relating to the processing of his
or her personal data;
– organize the processing of personal data in accordance with the procedure laid down in the
applicable laws of the Russian Federation;
– respond to requests and enquiries from personal data subjects and their legal representatives in
accordance with the requirements of the Personal Data Law;
– inform the authority responsible for the protection of personal data subjects’ rights
of the required information upon request of this authority within 10 business
days from the date of receipt of such request;
– publish or otherwise provide unrestricted access to this policy on the processing of personal data;
– take legal, organizational and technical measures to protect personal data against unauthorized
or accidental access, destruction, modification, blocking, copying, provision, distribution of
personal data, as well as against other unlawful acts in relation to personal data;
– stop the transfer (dissemination, provision, access) of personal data, cease processing and destroy
personal data in the manner and cases provided for in the Personal Data Law.


4. Basic rights and obligations of subjects of personal data

4.1. Personal data subjects have the right to:
– receive information relating to the processing of his or her personal data, except in cases provided
for by federal laws. Information shall be provided to the personal data subject by the Operator in
an accessible form and shall not contain personal data relating to other personal data subjects,
unless there are legitimate grounds for disclosing such personal data. The list of information and
the procedure for obtaining it is established by the Personal Data Law;
– demand that the Operator clarify, block or destroy personal data if the personal data is
incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of
processing, and to take statutory measures to protect their rights;
– give prior consent to the processing of personal data for the purpose of promoting goods, works
and services;
– to withdraw consent to the processing of personal data;
– appeal to the competent authority for the protection of the rights of personal data subjects or to
a court of law against unlawful acts or omissions of the Operator in processing his personal data.
4.2. Personal data subjects shall:
– provide the Operator with accurate information about themselves;
– inform the Operator of updates or changes to their personal data.
4.3. Persons who provided the Operator with false information about themselves or information
about another personal data subject without their consent shall be liable in accordance with Russian
law.


5. Principles of personal data processing

5.1. The processing of personal data shall be lawful and fair.
5.2. Processing of personal data shall be limited to achieving specific, predetermined and
legitimate purposes. Processing of personal data that is incompatible with the purposes of personal
data collection shall not be permitted.
5.3. Databases containing personal data whose processing is incompatible with one another may
not be merged.
5.4. Only personal data that fulfils the purposes for which it is processed should be processed.
5.5. The content and scope of personal data processed shall comply with the stated processing
purposes. Processed personal data shall not be excessive in relation to the stated processing
purposes.
5.6. When processing personal data, the Operator shall ensure the accuracy of personal data, its
sufficiency and, where necessary, its relevance in relation to the purpose of personal data
processing. The Operator shall take necessary measures and/or ensure that such measures are taken
to remove or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject
for no longer than is required by the purposes of personal data processing, unless the period of
personal data storage is established by federal law, an agreement to which the personal data subject
is a party, a beneficiary or a guarantor under which the personal data subject is a beneficiary.
Processed personal data shall be destroyed or depersonalized upon attainment of the processing
objectives or if it is no longer necessary to attain such objectives, unless otherwise provided by
federal law.


6. Purposes of personal data processing

The purpose of personal data processing:
To inform User, by sending e-mails
Personal data
  • Surname, first name, patronymic (if applicable);
  • e-mail address;
  • phone number
Legal basis for processing personal data
  • Federal Law No. 149-FZ of 27 July 2006 on Information, Information Technology and Information Protection.

7. Terms of personal data processing

7.1. Personal data is processed by the Operator in accordance with the requirements of Russian
law.
7.2. The Operator processes personal data:
- with or without the consent of the personal data subjects to the processing of their personal data
in cases stipulated by Russian law;
- access by an unlimited number of persons to which the personal data subject has provided or at
his or her request (hereinafter “publicly accessible personal data”);
- that are subject to publication or compulsory disclosure under federal laws.
7.3. The Operator processes personal data for each processing purpose in the following ways:
- non-automated processing of personal data;
- automated processing of personal data, with or without transmission of the information received
via information and telecommunication networks;
- mixed processing of personal data.
7.4. Employees of the Operator whose job duties include the processing of personal data are
permitted to process personal data.
7.5. Disclosure to third parties and dissemination of personal data without the consent of the
personal data subject shall not be permitted, unless otherwise provided by federal law. Consent for
processing of personal data permitted by the personal data subject for dissemination shall be
executed separately from other consents of the personal data subject for processing of his/her
personal data.
Requirements for the content of consent to the processing of personal data, authorized by the
personal data subject for dissemination, approved by the competent authority for the protection of
personal data subjects’ rights.
7.6. The transfer of personal data to the bodies of enquiry and investigation, the Federal Tax
Service, the Social Fund of the Russian Federation and other authorized executive authorities and
organizations is carried out in accordance with the requirements of Russian legislation.
7.7. The Operator shall take the necessary legal, organizational and technical measures to protect
personal data from unauthorized or accidental access, destruction, modification, blocking,
distribution and other unauthorized actions.


8. Personal Data Collection, Storage, Transfer, And Other Processing Procedures

8.1. The Operator ensures the security of personal data and takes all possible measures to exclude
access to personal data by unauthorized persons.
8.2. Your personal data will never, under any circumstances, be disclosed to third parties, unless:
– related to the implementation of existing legislation;
– if the personal data subject has given consent to the Operator to transfer the data to a third party
to fulfil obligations under a civil law contract or to achieve another purpose specified in advance
in the consent to the transfer;
– the cases described in point 3.1 of this policy regarding the processing of personal data.
8.3. If inaccuracies in the personal data are identified, the User can update the personal data
themselves by sending a notification to the Operator’s email address maxim.laptev@telecomcare.ru marked “Update of personal data”.
8.4. The time period for processing personal data is determined by achieving the purposes for
which the personal data were collected, unless a different time period is stipulated by contract or
applicable law.
The User may withdraw their consent to the processing of personal data at any time,
by sending a written request electronically to maxim.laptev@telecomcare.ru.
8.5. All information that is collected by third party services, including payment systems, means
of communication and other service providers, is stored and processed by these parties (Operators)
in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or
the User is obliged to acquaint themselves with the said documents in a timely manner. The
Operator shall not be liable for the actions of third parties, including the service providers referred
to in this clause.
8.6. The prohibitions established by the personal data subject on the transfer (other than granting
access) and processing or conditions of processing (other than obtaining access) of personal data
permitted for dissemination shall not apply in cases of processing of personal data in the state,
public and other public interests as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator shall store personal data in a form that makes it possible to identify the subject
of personal data no longer than required by the purposes of personal data processing, unless the
period of storage of personal data is established by federal law, an agreement to which the subject
of personal data is a party, a beneficiary or a guarantor.
8.9. A condition for the termination of personal data processing may be the achievement of the
personal data processing objectives, expiry of the personal data subject’s consent or withdrawal of
consent by the personal data subject, as well as the discovery of unlawful personal data processing.


9. List of actions taken by the Operator with the personal data received

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates,
changes), extracts, uses, transmits (distributes, provides access), anonymizes, blocks, deletes, and
destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving
and/or transmitting the information received via information and telecommunication networks.


10. Cross-border transfer of personal data

10.1. Before cross-border transfer of personal data, the Operator must inform the authority responsible for the protection of personal data subjects’ rights about intention to perform cross-border transfer of personal data.
10.2. Before transborder transfer of personal data, the Operator must ensure that the foreign country to whose territory the transfer of personal data is to take place provides adequate protection of the rights of personal data subjects.


11. Privacy of personal data

The Operator and other persons who have 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 can receive any clarifications on questions of interest regarding the processing of
their personal data by contacting the Operator via e-mail maxim.laptev@telecomcare.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://telecomcare.ru/privacy.
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