Privacy Policy

Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the personal data processing procedure and measures to ensure the security of personal data taken by Dmitry Maksimovich Levchenko, Individual Entrepreneur (hereinafter referred to as the Operator).

1.1. The Operator’s primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of privacy, personal and family secrets.

1.2. This Operator’s personal data processing policy (hereinafter referred to as the Policy) applies to all information the Operator may receive about visitors to the https://promadein.com/ website.

2. Key Concepts Used in the Policy

2.1. Automated Processing of Personal Data — the processing of personal data using computer technology.

2.2. Blocking of Personal Data — the temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the address https://promadein.com/.

2.4. Personal Data Information System — the collection of personal data contained in databases and the information technologies and technical means that enable their processing.

2.5. Anonymization of Personal Data — actions that make it impossible to determine the attribution of personal data to a specific User or another personal data subject without the use of additional information.

2.6. Personal data processing means any action (operation) or set of actions (operations) performed with or without the use of automated means with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.

2.7. Operator means a government agency, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://promadein.com/.

2.9. Personal data permitted for distribution by the personal data subject means personal data, access to which by the general public is granted by the personal data subject by consenting to the processing of the personal data, permitted for distribution by the personal data subject in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).

2.10. User — any visitor to the website https://promadein.com/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an indefinite number of persons, including publishing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to a foreign government agency, foreign individual, or foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the contents of the personal data in the personal data information system, and/or the destruction of tangible storage media for the personal data.

3. Main 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, as well as sends an appeal with a request to stop 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 Personal Data Law and 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 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 accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries from 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 at the request of such body of the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unlimited 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 transferring (distributing, providing, accessing) 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 concerning the processing of their personal data, with the exception of 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, with the exception of cases when 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;
— require the operator to clarify his personal data, 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 also take measures provided by law to protect his 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, as well as to send a request to stop processing 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 for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:
— provide the Operator with reliable information about themselves;
— notify 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 subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data is processed on a legal and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined and legal purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. Excessive amounts of processed personal data in relation to the stated purposes of their processing are not allowed.

5.6. 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 that they are taken no deletion or rectification of 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 for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized once the processing purposes have been achieved or when the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of Processing:

Informing the User via Email

Personal Data:

• Last Name, First Name, Patronymic
• Email Address
• Telephone Numbers

Legal Basis:

• Federal Law “On Information, Information Technologies, and the Protection of Information” dated July 27, 2006, No. 149-FZ

Types of Personal Data Processing:

• Collection, Recording, Systematization, Accumulation, Storage, Destruction, and Anonymization of Personal Data
• Sending Informational Emails to an Email Address 7. Terms of Personal Data Processing

7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

7.2. Personal data processing is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, or to perform the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or the execution of an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. 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 the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. 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 goals, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. The processing of personal data is carried out if access to it by the personal data subject to an unlimited number of persons is granted by the personal data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for the Collection, Storage, Transfer, and Other Processing of 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 current legislation on personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has consented to the Operator transferring the data to a third party for the fulfillment of obligations under a civil law contract.

8.3. If any inaccuracies in personal data are discovered, the User may update them independently by sending a notification to the Operator’s email address project@promadein.com with the subject line “Personal Data Update.”

8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to project@promadein.com with the subject line “Revocation of consent to the processing of personal data.”

8.5. 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 with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Prohibitions on transfer (except for providing access), as well as on processing or processing conditions (except for access rights (for personal data permitted for distribution) do not apply in cases where personal data is processed in state, public, or other public interests defined by Russian Federation law.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required for the purposes of processing the 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.

8.9. Termination of personal data processing may be conditional upon the achievement of the personal data processing purposes, expiration of the personal data subject’s consent, revocation of consent by the personal data subject, or a request to cease processing the personal data, as well as the detection of unlawful processing of personal data.

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

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the received information via information and telecommunications networks.

12. Confidentiality of Personal Data

The Operator and 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 personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator via email at project@promadein.com.

12.2. This document will reflect any changes to the Operator’s personal data processing policy. This policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available online at https://promadein.com/privacy-policy/.

12.1. Пользователь может получить любые разъяснения по интересующим вопросам, касающимся обработки его персональных данных, обратившись к Оператору с помощью электронной почты project@promadein.com.

12.2. В данном документе будут отражены любые изменения политики обработки персональных данных Оператором. Политика действует бессрочно до замены ее новой версией.

12.3. Актуальная версия Политики в свободном доступе расположена в сети Интернет по адресу https://promadein.com/privacy-policy/.