Personal data processing policy

1. General provisions

This personal data processing policy is drawn up by 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 defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "A-Platform" (hereinafter referred to as the Operator).
1.1. The operator sets its most important goal and condition for the implementation of its activities to respect the rights and freedoms of man and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the 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://webflow.aggregion.com.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer equipment.
2.2. Blocking of personal data - temporary termination of personal data processing (except if the processing is necessary to clarify personal data).
2.3. Website - a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at https://webflow.aggregion.com.
2.4. Personal data information system is a set of personal data contained in databases and ensuring their processing of information technologies and technical means.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subjects of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with 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, municipal body, legal entity, or individual, 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, actions (operations) performed with personal data.
2.8. Personal data - any information related directly or indirectly to a certain or identifiable User of the website https://webflow.aggregion.com.
2.9. Personal data permitted by the subject of personal data for distribution are personal data, access to which is provided by the subject of personal data by consenting to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.10. User - any visitor to the website https://webflow.aggregion.com.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle 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 at familiarization with personal data of an unlimited number of persons, including disclosure of personal data in the media, placement in information and telecommunication networks or provision of 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, 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 irretrievably with the impossibility of further restoring the content of personal data in the personal data information system and (or) destruction of material carriers 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 subject of personal data;- in case of withdrawal by the subject of personal data of 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 Law on Personal Data;- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted by 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 his request with information regarding the processing of his personal data;
- organize the processing of personal data by the procedure established by the current legislation of the Russian Federation;
- respond to appeals and requests from personal data subjects and their legal representatives by the requirements of the Personal Data Act;
- to inform the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request;
- publish or otherwise provide unlimited access to this Personal Data Processing Policy;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions concerning personal data;
- stop transferring (distributing, providing, accessing) personal data, stop processing and destroying personal data in the manner and cases provided for by the Personal Data Law;
- perform other duties provided for in the Personal Data Act.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:
- receive information regarding the processing of his personal data, except as provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except 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 Act;
- to require the operator to clarify his personal data, block them or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
- put forward a condition of prior consent when processing personal data to promote goods, works, and services on the market;
- to withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator in the processing of his personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- to provide the Operator with reliable data about himself;
- inform the Operator about the clarification (updating, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter are liable by the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Surname, first name, patronymic.
5.2. E-mail address.
5.3. Phone numbers.
5.4. The site also collects and processes anonymized visitor data (including cookies) using Internet statistics services (Yandex Metrics and Google Analytics and others).
5.5. The above data are further united by the general concept of Personal Data.
5.6. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Personal Data Act is allowed if the prohibitions and conditions are provided for in Art. 10.1 of the Personal Data Act.
5.8. The User's consent to the processing of personal data allowed for distribution is formalized separately from other consents to the processing of his personal data. At the same time, the conditions provided, in particular, for in Art. 10.1 of the Personal Data Act. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 The User grants consent to the processing of personal data permitted for distribution to the Operator directly.
5.8.2 The Operator is obliged to publish information on the processing conditions, prohibitions, and conditions for the processing by an unlimited number of persons of personal data permitted for distribution no later than three working days from the date of obtaining the User's consent.
5.8.3 The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution shall be terminated at any time at the request of the subject of personal data. This requirement should include the surname, first name, patronymic (if any), contact information (phone number, e-mail address, or postal address) of the subject of personal data, as well as a list of personal data to be terminated. The personal data specified in this requirement may be processed only by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data permitted for distribution shall cease to apply from the moment the Operator receives the requirement specified in paragraph 5.8.3 of this Personal Data Processing Policy.

6. Principles of personal data processing

6.1. The processing of personal data is carried out on a legal and fair basis
6.2. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate goals. It is not allowed to process personal data that is incompatible to collect personal data.
6.3. It is not allowed to combine databases containing personal data processed for purposes incompatible with each other.
6.4. Only personal data that meet the purposes of their processing are subject to processing.
6.5. The content and volume of personal data processed correspond to the stated purposes of the processing. Redundancy of processed personal data concerning the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of personal data processing are ensured. The operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows you to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of the need to achieve these goals unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. The purpose of processing the User's personal data:
- informing the User by sending emails.
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive information messages by sending an email to the Operator at info@aggregion.com marked "Opt-out of notifications about new products and services and special offers".
7.3. Anonymous User data collected through Internet statistics services serves to collect information about Users' actions on the site, improve the quality of the site 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:
- the consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution;
- federal laws, other regulations in the field of personal data protection;
- the consent of Users to the processing of their personal data, to the processing of personal data allowed 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 https://webflow.aggregion.com or sent to the Operator by e-mail. By filling out the relevant forms and/or sending your personal data to the Operator, the User agrees to this Policy.
8.3. The Operator processes anonymized data about the User if allowed in the User's browser settings (cookies are stored and JavaScript technology are enabled).
8.4. The subject of personal data independently decides to provide his personal data and gives consent freely, by his own will, and in his interest.

9. Terms of personal data processing

9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for in an international treaty of the Russian Federation or law, to carry out the functions, powers, and obligations assigned to the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be executed by the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which either the beneficiary or guarantor is the subject of personal data, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
9.5. 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 the rights and freedoms of the personal data subject are not violated.
9.6. Personal data is processed, access to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data) is carried out.
9.7. Personal data subject to publication or mandatory disclosure by federal law is processed.

10. Procedure for collection, storage, transfer, and other types of personal data processing

The security of personal data processed by the Operator is ensured by implementing the legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
10.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to the personal data of unauthorized persons.
10.2. 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 data to a third party to fulfill obligations under a civil law contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's e-mail address info@aggregion.com marked "Updating personal data".
10.4. The period of personal data processing is determined by the achievement of the purposes for which personal data were collected unless otherwise provided for by the contract or current legislation.
The User may withdraw his consent to the processing of personal data at any time by sending an e-mail notification to the Operator's e-mail address info@aggregion.com marked "Withdrawal of consent to the processing of personal data".
10.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by these persons (Operators) by their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize himself with these documents on time. The operator is not responsible for the actions of third parties, including those specified in this paragraph.
10.6. The prohibitions established by the subject of personal data on the transfer (except for the provision of access), as well as on the processing or conditions for processing (except for access) of personal data allowed 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.
10.7. The operator ensures the confidentiality of personal data when processing personal data.
10.8. The operator stores personal data in a form that allows you to determine the subject of personal data, no longer than the purposes of processing personal data require, unless the period of storage of personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.
10.9. The condition for terminating the processing of personal data may be to achieve the goals of personal data processing, 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 illegal processing of personal data.

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

11.1. The operator collects, records, systematizes, accumulates, stores, refines (updates, changes), extracts, uses, transfers (distribution, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The operator carries out automated processing of personal data with or without receiving and/or transferring the received information on information and telecommunication networks.

12. Cross-border transfer of personal data

12.1. Before the start of cross-border transfer of personal data, the operator is obliged to make sure that the foreign state to which the transfer of personal data is supposed to be transferred ensures reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent of the subject of personal data to the cross-border transfer of his personal data and/or execution of the contract to which the subject of personal data is a party.

13. Privacy of personal data

The operator and other persons who have 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.

14. Final provisions

14.1. The User can get any clarifications on issues of interest related to the processing of his personal data by contacting the Operator by e-mail at info@aggregion.com.
14.2. This document will reflect any changes in the personal data processing policy of the Operator. The policy is valid indefinitely until it is replaced with a new version.
14.3. The current version of the Policy is freely available on the Internet at https://webflow.aggregion.com.

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