1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Posline Limited Liability Company (TIN: 1615014722, PSRN: 1191690058966) (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms in the processing of their personal data.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://demo.wannasay.org/
2. Basic Terms
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (unless 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 network address https://demo.wannasay.org/
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions resulting in the impossibility of determining, without the use of additional information, the ownership of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — Posline LLC (TIN: 1615014722, PSRN: 1191690058966), independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and 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://demo.wannasay.org/
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User/Subject of personal data — any visitor to the website https://demo.wannasay.org/
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 circle of persons (transfer of personal data) or providing access to personal data to an unlimited number of persons, including the publication of personal data in the mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Destruction of personal data — any actions resulting in personal data being irreversibly destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or the physical media of personal data being destroyed.
2.14. All other terms and definitions used in this text shall be interpreted by the Parties in accordance with the legislation of the Russian Federation and the generally accepted rules of interpretation of the relevant terms on the Internet.
3. 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 subject of personal data;
– in case the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 the obligations provided for 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 subject of personal data, at their request, with information regarding the processing of their personal data;
– organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
– respond to appeals and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
– publish or otherwise ensure 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, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions concerning personal data;
– stop 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 duties provided for by the Personal Data Law.
4. Rights and Obligations of the Subjects of Personal Data
4.1. Subjects of personal data have the right to:
– receive information regarding the processing of their personal data, except in 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 related to other subjects of personal data, except in 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 Personal Data Law;
– 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, as well as take statutory measures to protect their rights;
– withdraw consent to the processing of personal data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
– provide the Operator with accurate data about themselves;
– notify the Operator of the clarification (update, modification) of their personal data.
4.3. Persons who have transferred to the Operator unreliable information about themselves or information about another subject of personal data without the latter's consent shall be liable in accordance with the legislation of the Russian Federation.
5. User's Personal Data Subject to Processing
5.1. The Operator may process the following personal data of the User:
surname, first name, patronymic, gender, citizenship, year of birth, month of birth, date of birth, place of birth, name and details of the identity document (series and number, date of issue, and name of the issuing authority);
residential address, registration address, mobile phone numbers, landline phone numbers, email addresses; user data (location information; type, version, and language of the operating system; type, version, and language of the browser; device type and its screen resolution; the source from which the User came to the website; information about the User's actions on the website, visited pages; IP address, information about messengers); and other information additionally provided by the User.
5.2. The User provides consent for the processing of personal data permitted for distribution directly to the Operator.
5.3. The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution must be stopped at any time at the request of the subject of personal data. This request must include the surname, first name, patronymic (if any), contact information (phone number, email address) of the subject of personal data, as well as a list of personal data whose processing is to be terminated.
5.4. Consent to the processing of personal data permitted for distribution shall expire upon the Operator's receipt of the request referred to in Clause 5.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
6.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data that meets the purposes of its processing shall be processed.
6.5. The content and volume of the processed personal data comply with the stated processing purposes. Redundancy of the processed 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, its sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored 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 storage period for 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 shall be destroyed or anonymized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6.8. The Operator does not intentionally process the personal data of minors. Responsibility for the actions of minors, including their purchase of services on the Website, lies with the legal representatives of the minors. All visitors under the age of 18 must obtain the permission of their legal representatives before providing any personal information about themselves. If the Operator becomes aware that it has received personal information about a minor without the consent of legal representatives, such information will be deleted as soon as possible.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data:
– informing the User by sending emails;
– concluding, executing, and terminating civil law contracts;
- identifying the User registered on the Website;
- providing the User with access to personalized resources of the Website;
- assisting the User in obtaining the necessary information to subsequently make a decision on concluding a contract;
- creating data information systems, analysis, modeling, forecasting, building mathematical models, analysis of aggregated and anonymous data, statistical and research purposes;
- maintaining and updating the User database;
- establishing feedback with the User, including sending notifications, requests concerning the use of the Website, rendering services, processing requests and applications from the User;
- determining the User's location to ensure security and prevent fraud;
- confirming the accuracy and completeness of the personal data provided by the User;
- providing the User with effective customer and technical support when problems related to the use of the Website arise.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending an email to the Operator at help@wannasay.org marked "Opt-out of notifications about new products, services, and special offers".
7.3. Anonymized data of Users collected using Internet statistics services serve to collect information about the actions of Users on the website, improve the quality of the website and its content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for the processing of personal data by the Operator are:
– federal laws, other regulatory legal acts in the field of personal data protection;
– User consents to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the Website or sent to the Operator via email. By filling out the appropriate forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The subject of personal data independently makes a decision to provide their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions of Personal Data Processing
9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
9.5. 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 subject of personal data are not violated.
9.6. Processing is carried out on personal data to which access of an unlimited number of persons is provided by the subject of personal data or at their request (hereinafter — publicly available personal data).
9.7. Processing is carried out on personal data subject to publication or mandatory disclosure in accordance with federal law.
10. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
10.1. 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 the requirements of current legislation in the field of personal data protection.
10.2. The Operator ensures the safekeeping of personal data and takes all possible measures to preclude access to personal data by unauthorized persons.
10.3. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer the data to a third party.
10.4. In case of detecting inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address help@wannasay.org marked "Updating personal data".
10.5. The term for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different term is provided by the contract, current legislation, or the User's consent to process personal data.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address help@wannasay.org marked "Withdrawal of consent to the processing of personal data". Upon receipt of a notification from the User regarding the withdrawal of consent to the processing of personal data, the Operator shall stop processing the User's personal data within a period not exceeding 10 business days from the date of receipt.
10.6. All information collected by third-party services, communication tools, and other service providers is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves with these documents independently and in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.7. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public, and other public interests defined by the legislation of the Russian Federation.
10.8. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with the Received Personal Data
11.1. The Operator collects, receives, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), anonymizes, blocks, encrypts, deletes, and destroys personal data.
11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
12. Confidentiality of Personal Data
12. The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to 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 obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at help@wannasay.org.
13.2. This document will reflect any changes to the personal data processing policy by the Operator. The Policy is valid indefinitely until replaced by a new version.
13.3. The current version of the Policy is freely available on the Internet at https://demo.wannasay.org/
13.4. In case of loss or disclosure of personal data, the Operator shall not be liable if the specified information became public prior to its loss or disclosure and/or was obtained from a third party prior to its receipt by the Operator and/or was disclosed with the User's consent.
14. Operator's Details
Posline LLC
TIN: 1615014722, PSRN: 1191690058966
Registered address: 7 Universitetskaya St., premises No. 216/4, Innopolis, Verkhneuslonsky District, Republic of Tatarstan, 420500