Policy on the processing of personal data
1 General provisions
This policy on processing of personal data is prepared in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Elfuturis (hereinafter - the "Operator").
1.1 The operator's most important objective and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including protection of their rights to privacy, personal and family secrets.
1.2 This Operator's Personal Data Processing Policy (the "Policy") applies to all information that the Operator may receive about visitors to the https://elfuturis.com/ website.
2 Basic concepts used in the Policy
2.1 Automated processing of personal data - processing of personal data by means of computer technology.
2.2 Blocking of personal data means temporary stopping of processing of personal data (unless the processing is necessary to clarify the personal data)
2.3 Website means a set of graphical and information materials, as well as computer programs and databases, ensuring their availability on the Internet at https://elfuturis.com/ network address.
2.4 Personal data information system is an aggregate of personal data contained in databases and information technologies and technical means ensuring processing of personal data.
2.5 Impersonalization of personal data - actions, as a result of which it is impossible to determine, without using additional information, whether personal data belongs to a particular User or another subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7 Operator - a state body, municipal authority, legal entity or individual, independently or together with other persons, arranging and/or carrying out processing of personal data, as well as determining the purpose of personal data processing, composition of personal data to be processed, actions (operations) performed with personal data.
2.8 Personal data - any information relating directly or indirectly to a particular or definable User of the https://elfuturis.com/ website.
2.9. Personal data, allowed by the subject of personal data for distribution - personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, allowed the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, allowed for distribution).
2.10. User - any visitor to https://elfuturis.com/.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Distribution of personal data - any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize an unlimited number of persons with personal data, including publication of personal data in the media, posting 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, foreign natural person or foreign legal entity.
2.14. Destruction of personal data - any action, in consequence of which personal data is irretrievably destroyed with impossibility to further restore the content of personal data in the information system of personal data and/or destruction of material media of personal data.
3. the basic rights and obligations of the operator
3.1 The operator has the right:
- to obtain from the subject of personal data reliable information and/or documents containing personal data;
- In case the personal data subject withdraws consent to the processing of personal data, as well as in case of sending a request to terminate the processing of personal data, the operator has the right to 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 the obligations provided by the Personal Data Law and the regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2 The operator shall:
- provide the personal 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 the manner prescribed by applicable laws of the Russian Federation;
- respond to requests and enquiries of personal data subjects and their legal representatives, in accordance with the requirements of the Personal Data Law
- Notify the authority responsible for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 10 days from the date of receipt of such request
- publish or otherwise ensure unrestricted access to this Policy on personal data processing
- To take legal, organizational and technical measures for protection of personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful acts in relation to personal data
- Cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law
- Perform other duties provided by 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 their personal data, except in the cases provided for by federal laws. The information is provided to the subject of personal data by the operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are set out in the Personal Data Act;
- To require the operator to clarify his personal data, to block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and to take statutory measures to protect his rights;
- to condition prior consent when processing personal data for the purpose of promoting goods, works and services on the market
- to withdraw the consent to the processing of personal data, as well as to request the termination of personal data processing
- complain to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the operator in the processing of his personal data
- To exercise other rights provided by the legislation of the Russian Federation.
4.2 Personal data subjects shall
- Provide the Operator with accurate data about themselves;
- Inform the operator of the clarification (updating, modification) of their personal data.
4.3 Persons who provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Russian Federation. 5.
5. Principles of personal data processing
5.1 Processing of personal data shall be carried out on a lawful and fair basis.
5.2 Processing of personal data shall be limited to achieving specific, predetermined and legitimate objectives. No processing of personal data which is incompatible with the purposes for which the personal data is collected shall be permitted.
5.3 Databases containing personal data that are processed for purposes that are incompatible with each other shall not be combined.
5.4 Only personal data that meets the purposes for which it is being processed shall be processed.
5.5 The content and extent of the personal data processed shall be consistent with the stated processing purposes. No excessive processing of personal data in relation to the stated processing purposes shall be permitted.
5.6 When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance in relation to the purpose of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that incomplete or inaccurate data is removed or clarified.
5.7 Personal data shall be stored in a form that allows for the identification of the personal data subject for no longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalised upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.
6. Purposes of personal data processing
Purpose of the processing Informing the user by sending e-mails
Personal data
e-mail address
Legal grounds
Contracts entered into between the data controller and the data subject
Type of processing of personal data
Sending of information letters to an e-mail address
7. Terms of processing of personal data
7.1 Processing of personal data shall be subject to the consent of the subject of personal data to the processing of their personal data.
7.2 Processing of personal data is necessary for achievement of the objectives envisaged by the international treaty of the Russian Federation or the law, for performance of the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
7.3 Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4 Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which the personal data subject is a party, as well as for conclusion of an agreement on the initiative of the personal data subject or an agreement, under which the personal data subject will be a beneficiary or guarantor.
7.5 Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially important objectives, provided that this does not violate the rights and freedoms of the personal data subject.
7.6 Processing of personal data, to which access has been granted to an unlimited number of persons by or at the request of the personal data subject (hereinafter "publicly available personal data").
7.7 Processing of personal data subject to publication or compulsory disclosure in accordance with federal law.
8. Procedure for collection, storage, transfer and other processing of personal data
The security of personal data processed by the Operator shall be ensured by implementing legal, organisational and technical measures necessary to comply fully with the requirements of current legislation in the area of personal data protection.
8.1 The operator shall ensure security of personal data and take all possible measures to exclude access to personal data by unauthorised persons.
8.2 The personal data of the User will never, under no circumstances be transferred to third parties, except in cases connected with the execution of the current legislation, or if the personal data subject has given their consent to the Operator for the transfer of data to a third party to fulfil obligations under a civil law contract.
8.3 In case of identification of inaccuracies in the personal data, the User may update them themselves, by sending a notification to the Operator's e-mail address elfuturis@gmail.com, marked "Updating of personal data".
8.4 The time period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different time period is stipulated by the contract or applicable law.
The user may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via email to the Operator's email address elfuturis@gmail.com, marked "Withdrawal of consent to the processing of personal data".
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 the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or with the said documents. 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 gaining access) of personal data permitted for dissemination shall not apply in cases of processing of personal data for state, public and other public interests as defined by Russian law.
8.7. The Operator shall ensure the confidentiality of personal data when processing personal data.
8.8. The operator shall store personal data in a form that allows the personal data subject to be identified, for no longer than is required by the objectives of personal data processing, unless the period of storage of personal data is set by federal law, the contract, a party to which, a beneficiary or a guarantor under which the subject of personal data is a party.
8.9 A condition for termination of personal data processing may be the attainment of personal data processing objectives, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject or a requirement to terminate personal data processing, as well as the discovery of unlawful personal data processing.
9. List of actions performed by the operator with personal data received
9.1 The operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), anonymises, blocks, deletes and destroys personal data.
9.2 The operator carries out automated processing of personal data with or without receipt and/or transmission of received information via information and telecommunications networks.
10. Cross-border transfer of personal data
10.1 The operator is obliged to notify the competent authority for personal data protection of its intention to transfer personal data across borders (such notification is sent separately from the notification of the intention to process personal data) before starting the cross-border transfer of personal data.
10.2 The operator shall, prior to submitting the above notification, obtain relevant information from the foreign authorities, foreign natural persons, foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality 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 may obtain any clarification on questions of interest regarding the processing of their personal data by contacting the Operator by e-mail at elfuturis@gmail.com.
12.2 This document will reflect any changes to the personal data processing policy of the Operator. 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://elfuturis.com/privacy.