Personal Data Processing Policy
Privacy Policy
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by II Technologies LLC (hereinafter — the Operator).
1.1. The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data — including the protection of the right to privacy, personal and family confidentiality — to be its primary goal and a condition for carrying out its activities.
1.2. This Operator policy on personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://ii-tech.ru/eng
2. Key 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 where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases that make them accessible on the internet at https://ii-tech.ru/eng
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, whether personal data belongs to a specific User or other data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a government body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://ii-tech.ru/eng
2.9. Personal data authorized by the data subject for distribution — personal data to which the data subject has provided unrestricted public access by consenting to the processing of personal data authorized for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data authorized for distribution).
2.10. User — any visitor to the website https://ii-tech.ru/eng
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data accessible to an unlimited number of persons, including the publication of personal data in the media, posting on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is permanently destroyed with no possibility of restoring 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 accurate information and/or documents containing personal data from the data subject;
— in the event that the data subject withdraws consent to the processing of personal data or submits a request to cease processing, the Operator may continue processing personal data without the data subject's consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to fulfill the obligations stipulated by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— provide the data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
— respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— notify the authorized body for the protection of the rights of personal data subjects, upon request, of the necessary information within 10 days of receiving such a request;
— publish or otherwise ensure unrestricted access to this Policy on personal data processing;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and 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 regarding the processing of their personal data, except in cases provided for by federal laws. Such information is provided by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where 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;
— require the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take legally prescribed measures to protect their rights;
— set a condition of prior consent when their personal data is processed for the purpose of marketing goods, works, and services;
— withdraw consent to the processing of personal data and submit a request to cease processing;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obligated to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any updates (changes) to their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another data subject without that person's consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing that is incompatible with the purposes of personal data collection is not permitted.
5.3. Merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that is relevant to the purposes of processing shall be processed.
5.5. The content and volume of personal data processed corresponds to the stated processing purposes. Excess processing beyond those purposes is not permitted.
5.6. During the processing of personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the processing purposes is ensured. The Operator takes the necessary measures and/or ensures that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless a storage period is established by federal law or contract. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or when those purposes are no longer necessary, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: conclusion, performance, and termination of civil law agreements.
Personal data:
— Last name, first name, patronymic
— Email address
— Phone numbers
Legal grounds:
— Agreements concluded between the Operator and the data subject
Types of personal data processing:
— Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
— Sending informational emails to the provided email address
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the data subject.
7.2. Processing is necessary to achieve purposes stipulated by an international treaty of the Russian Federation or by law, and to fulfill the functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing is necessary for the administration of justice, enforcement of a judicial act, or act of another body or official, subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary, or guarantor, or to enter into a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the legitimate rights and interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out on personal data made publicly available by the data subject or at their request (publicly available personal data).
7.7. Processing is carried out on personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collection, Storage, Transfer, 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 fully comply with applicable personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all reasonable measures to prevent access by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except where required by applicable law or where the data subject has given consent to the transfer for the purposes of performing a civil law agreement.
8.3. If inaccuracies are identified in personal data, the User may update them independently by sending a notification to the Operator at clients@ii-tech.ru with the subject line "Personal Data Update".
8.4. The personal data processing period is determined by the achievement of the purposes for which the data was collected, unless a different period is stipulated by contract or applicable law. The User may withdraw consent to personal data processing at any time by sending a notification to clients@ii-tech.ru with the subject line "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communications providers, and other service providers, is stored and processed by those parties in accordance with their own User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties, including service providers referenced in this clause.
8.6. Restrictions on transfer or processing of personal data authorized for distribution that are set by the data subject do not apply in cases where personal data is processed in the state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless a storage period is established by federal law or contract.
8.9. Processing may be terminated upon achievement of the processing purposes, expiration of the data subject's consent, withdrawal of consent, a request to cease processing, or identification of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with or without transmission of the received information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to initiating cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and any other persons who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise required by federal law.
12. Final Provisions
12.1. The User may obtain clarification on any questions regarding the processing of their personal data by contacting the Operator at clients@ii-tech.ru.
12.2. Any changes to the 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 publicly available on the Internet at https://ii-tech.ru/privacy-eng.