1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by the Limited Liability Company "Promotion Group" (hereinafter referred to as the "Operator").
1.1. The Operator sets as its most important goal and condition implementation of its activities, observance of the rights and freedoms of man and citizen when processing his personal data, including protection of the rights to privacy, personal and family secrets.
1.2. This policy of the Operator in relation to processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://www.10-top.ru.
2. Basic concepts , 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 cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and information materials, as well as programs for Computers and databases that ensure their availability on the Internet at the network address https://www.10-top.ru.
2.4. Personal data information system is a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data is actions that make it impossible to determine without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed using the means automation or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data .
2.7. Operator – a state body, a municipal body, a legal entity or an individual, independently or jointly with other persons, organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://www.10-top.ru.
2.9. Personal data permitted by the subject of personal data for processing are personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for processing in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for processing).
2.10. User - any visitor to the website https://www. 10-top.ru who left their personal data in the form posted on the website.
2.11. Provision of personal data - actions aimed at processing, disclosure of personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including disclosing personal data in the media, posting on 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 government body of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the destruction of tangible media of personal data.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right:
– to receive reliable information and/or documents containing personal data from the personal data subject;
– if the personal data subject revokes consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator is obliged to:
– provide the personal data subject, at his request, with information regarding the processing of his personal data;
– organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
– respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
– notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 30 days from the date of receipt of such request;
– publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
– stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
– fulfill other obligations stipulated by the Law on Personal Data.
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 for cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except for cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
– demand that the operator clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
– put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
– to revoke consent to the processing of personal data;
– to appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing his personal data;
– to exercise other rights provided by law by the Russian Federation.
4.2. Personal data subjects are obliged to:
– provide the Operator with reliable information about themselves;
- be adults;
– inform the Operator about clarification (update, change) of their personal data.
4.3. Persons who have transferred to the Operator false information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.
5. The Operator processes the following personal data of the User
5.1. Purpose: registration on the website.
5.1.1. Subject category: website users.
5.1.2. Processed data: last name, first name, patronymic, date of birth, telephone number, email.
5.1.3. Data category: general personal data.
5.1.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use.
5.1.5. Processing period: within 3 years from the date of the last activity on the website or until the personal data is revoked by the personal data subject.
5.1.6. Personal data are destroyed by erasing from the personal data operator's servers.
5.2. Purpose: employment (filling out an application form).
5.2.1. Subject category: job candidates.
5.2.2. Processed data: last name, first name, patronymic, date of birth, phone number, email, education, gender, age, profession.
5.2.3. Data category: general personal data.
5.2.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use.
5.2.5. Processing period: within 3 years from the date of the last activity on the site or until the personal data is revoked by the personal data subject.
5.2.6. Personal data are destroyed by erasing from the personal data operator's servers.
5.3. Purpose: order a call back.
5.3.1. Subject category: website users.
5.3.2. Processed data: last name, first name, patronymic, phone number.
5.3.3. Data category: general personal data.
5.3.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use.
5.3.5. Processing period: within 3 years from the date of the last activity on the website or until the personal data is revoked by the personal data subject.
5.3.6. Personal data are destroyed by erasing from the personal data operator's servers.
5.4. Purpose: ordering a commercial offer.
5.4.1. Subject category: website users.
5.4.2. Processed data: last name, first name, patronymic, phone number, email.
5.4.3. Data category: general personal data.
5.4.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use.
5.4.5. Processing period: within 3 years from the date of the last activity on the website or until the personal data is revoked by the personal data subject.
5.4.6. Personal data are destroyed by erasing from the personal data operator's servers.
5.5. Purpose: attracting attention with a form
5.5.1. Subject category: website users.
5.5.2. Processed data: name, phone number.
5.5.3. Data category: general personal data.
5.5.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use.
5.5.5. Processing period: within 3 years from the date of the last activity on the website or until the personal data is revoked by the personal data subject.
5.5.6. Personal data are destroyed by erasing from the personal data operator's servers
5.6. Purpose: providing a free website audit to the subject of personal data (in the callback header or on the first screen)
5.6.1. Subject category: website users.
5.6.2. Processed data: name, phone number.
5.6.3. Data category: general personal data.
5.6.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updated)
5.6.5. Processing period: within 3 years from the date of the last activity on the site or until the personal data is revoked by the personal data subject.
5.6.6. Personal data are destroyed by erasing from the personal data operator's servers
5.7. Purpose: providing an expert audit
5.7.1. Subject category: site users.
5.7.2. Processed data: name, phone number.
5.7.3. Data category: general personal data.
5.7.4. Method of personal data processing: automated collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use.
5.7.5. Processing period: within 3 years from the date of the last activity on the site or until the personal data is revoked by the personal data subject.
5.7.6. Personal data are destroyed by erasing from the personal data operator's servers
5.8. Purpose: providing a calculation of the cost of services.
5.8.1. Subject category: site users.
5.8.2. Processed data: name, phone number.
5.8.3. Data category: general personal data.
5.8.4. Method of personal data processing: automated collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use.
5.8.5. Processing period: within 3 years from the date of the last activity on the site or until the personal data is revoked by the personal data subject.
5.8.6. Personal data are destroyed by erasing from the personal data operator's servers
5.9. Purpose: offering a discount in a pop-up window.
5.9.1. Subject category: site users.
5.9.2. Processed data: name, phone number.
5.9.3. Data category: general personal data.
5.9.4. Method of personal data processing: automated collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use.
5.9.5. Processing period: within 3 years from the date of the last activity on the site or until the personal data is revoked by the personal data subject.
5.9.6. Personal data are destroyed by erasing from the personal data operator's servers.
5.10. Purpose: cost calculation using the calculator (site calculator).
5.10.1. Subject category: site users.
5.10.2. Processed data: site address, city of promotion. list of key queries. in which search engines the site should be promoted, email or phone.
5.10.3. Data category: general personal data.
5.10.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use.
5.10.5. Processing period: within 3 years from the date of the last activity on the site or until the personal data is revoked by the personal data subject.
5.10.6. Personal data are destroyed by erasing from the personal data operator's servers.
5.11. Purpose: providing some kind of discount or bonus in the form of a game:
5.11.1. Subject category: website users.
5.11.2. Processed data: website address, phone number.
5.11.3. Data category: general personal data.
5.11.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use.
5.11.5. Processing period: within 3 years from the date of the last activity on the site or until the personal data is revoked by the personal data subject.
5.11.6. Personal data are destroyed by erasing from the personal data operator's servers.
5.12. Purpose: subscription to the newsletter.
5.12.1. Subject category: site users.
5.12.2. Processed data: e-mail.
5.12.3. Data category: general personal data.
5.12.4. Method of personal data processing: automated collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use.
5.12.5. Processing period: within 3 years from the date of the last activity on the site or until the personal data subject revokes the personal data or refuses to send the data.
5.12.6. Personal data are destroyed by erasing from the personal data operator's servers
5.13. Purpose: filling out the contact form with a specific manager.
5.13.1. Subject category: website users.
5.13.2. Processed data: telephone.
5.13.3. Data category: general personal data.
5.13.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use.
5.13.5. Processing period: within 3 years from the date of the last activity on the website or until the personal data is revoked by the personal data subject.
5.13.6. Personal data are destroyed by erasing from the personal data operator's servers.
5.14. Purpose: Registration for a webinar.
5.14.1. Subject category: website users.
5.14.2. Processed data: first name, last name, email, phone, position, company name.
5.14.3. Data category: general personal data.
5.14.4. Personal data processing method: automated collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use.
5.14.5. Processing period: within 3 years from the date of the last activity on the website or until the personal data is revoked by the personal data subject.
5.14.6. Personal data are destroyed by deleting the personal data from the operator's servers.
5.15. The website also collects and processes anonymized data about visitors (including cookies and using Internet statistics and web analytics services).
5.16. The above data are hereinafter referred to in the text of the Policy as Personal Data.
5.17. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.18. The processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is permitted if the prohibitions and conditions stipulated by Article 10.1 of the Law on Personal Data are observed.
5.19. The User's consent to the processing of personal data permitted for distribution is drawn up separately from other consents to the processing of his personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent shall be established by the authorized body for the protection of the rights of personal data subjects.
5.19.1 The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
5.19.2 The Operator is obliged, no later than three business days from the date of receipt of the User's consent, to publish information on the terms of processing, the existence of prohibitions and conditions for the processing of personal data permitted for distribution by an unlimited number of persons.
5.19.3 The transfer (distribution, provision, access) of personal data permitted for distribution by the personal data subject must be terminated at any time at the request of the personal data subject. This requirement must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is sent.
5.19.4 Consent to the processing of personal data permitted for distribution shall cease to be valid from the moment the Operator receives the request specified in clause 5.19.3 of this Policy regarding the processing of personal data.
5.20. The Operator protects personal data from unauthorized or accidental access.
5.21. The subject of personal data may change or clarify personal data by contacting the Operator's support service, and the Operator is obliged to update them within 7 business days.
5.22. The subject of personal data may request the Operator to provide information about the personal data used or ask to review them. The Operator is obliged to provide it within 10 business days. This period may be extended after notification of the Personal Data Subject, but not more than by 5 working days.
5.23. If the Operator refuses to provide information about the availability of personal data, the Operator is obliged to provide the Personal Data Subject with a reasoned refusal within 10 working days. This period may be extended upon notification of the Personal Data Subject, but not more than by 5 working days.
6. Principles of personal data processing
6.1. Personal data shall be processed in a lawful and fair manner.
6.2. Personal data shall be processed limited to achieving specific, predetermined and legitimate purposes. Personal data may not be processed in a manner that is incompatible with the purposes for which the personal data was collected.
6.3. Databases containing personal data processed for purposes that are incompatible with each other shall not be combined.
6.4. Only personal data that meets the purposes for which they are processed shall be processed.
6.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data are stored in a form that allows identifying the subject of personal data, for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in the event of loss of need to achieve these purposes, unless otherwise provided by federal law.
7. Legal grounds for processing personal data
7.1. The legal grounds for processing personal data by the Operator are:
– Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 N 149-FZ;
– Federal Law "On Advertising" dated March 13, 2006 N 38-FZ;
– the Operator's statutory documents;
– agreements concluded between the operator and the subject of personal data;
– federal laws, other regulatory legal acts in the field of personal data protection;
– Users' consent to the processing of their personal data, to the processing of personal data permitted for distribution.
7.2. The Operator processes the User's personal data only if the User fills it in and/or sends it independently through special forms located on the website https://www.10-top.ru or sent to the Operator by e-mail. By filling in 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 anonymized data about the User if this is permitted in the User's browser settings (saving cookies and using JavaScript technology are enabled).
7.4. The User independently decides to provide their personal data and gives consent freely, of their own free will and in their own interests.
8. Terms of personal data processing
8.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.
8.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
8.3. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding 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.
8.4. 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 goals, provided that the rights and freedoms of the personal data subject are not violated.
8.5. The processing of personal data is carried out, access to which is provided to an unlimited number of persons by the subject of personal data or at his request (hereinafter - publicly available personal data).
8.6. The processing of personal data is carried out that is subject to publication or mandatory disclosure in accordance with federal law.
9. The procedure for collecting, storing, transferring and other types of processing personal data
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the 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 unauthorized persons from accessing personal data. Personal data is stored on the server of the 1vds.ru provider, located on the territory of the Russian Federation.
9.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given the Operator's consent to transfer the data to a third party to fulfill obligations under a civil law contract.
9.3. In the event that inaccuracies are detected in the personal data, the User can update them independently by sending the Operator a notification to the Operator's email address info@10-top.ru marked “Update of personal data”.
9.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or applicable law. The User may at any time revoke their consent to the processing of personal data by sending the Operator a notice by e-mail to the Operator's e-mail address info@10-top.ru marked "Revocation of consent to the processing of personal data".
9.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
9.6. The prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in the state, public and other public interests determined by the legislation of the Russian Federation.
9.7. When processing personal data, the operator ensures the confidentiality of personal data.
9.8. The operator stores personal data in a form that allows identifying the personal data subject for no longer than required for the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
9.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.
10. List of actions performed by the Operator with the received personal data
10.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
10.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.
11. Cross-border transfer of personal data
11.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is supposed to be transferred ensures reliable protection of the rights of personal data subjects.
11.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent from the subject of personal data to the cross-border transfer of his personal data and/or execution of an agreement to which the subject of personal data is a party.data.
11.3. The Operator does not carry out cross-border data transfer.
12. Confidentiality of personal data
12.1 The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
13. Final provisions
13.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail info@10-top.ru
13.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version without prior notice to the User.
13.3. The current version of the Policy is freely available on the Internet at https://www.10-top.ru/eng/