Personal data processing 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 sets out the procedure for processing personal data and the measures taken by VET FAKTOR LLC (hereinafter, the Operator) to ensure the security of personal data.
1.1. The operator is committed to respecting human and civil rights and freedoms in the processing of personal data, including the protection of privacy, personal and family privacy.
1.2. The Operator ' s present personal data processing policy (hereinafter – Policy) applies to all information the Operator can obtain about website visitors https://www.vetfaktor.ru/.

2. Basic concepts used in the Policy

2.1. Automated personal data processing – Computer-based processing of personal data.
2.2. Personal Data Locking - Temporary Disruption of Personal Data Processing (except where processing is necessary to refine personal data).
2.3. Web site: a set of graphics and information materials, as well as computer software and databases that make them available on the Internet via an online address https://www.vetfaktor.ru/.
2.4. The Personal Data Information System is a combination of personal data contained in databases and processes information technologies and technology.
2.5. Personal data disfigurement is an act that cannot be determined without the use of additional information to determine the identity of a particular user or other subject of personal data.
2.6. Personal data processing means any act (operation) or set of actions (operations) carried out with or without automation means, including collection, recording, systematization, stockpiling, storage, clarification (updating, modification), recovery, use, transfer (proliferation, provision, access), impersonalization, blocking, disposal, destruction of personal data.
2.7. The operator is a public authority, a municipal body, a legal or natural person, whether by itself or in association with other persons, who organizes and/or processes personal data, as well as defining the purposes of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.
2.8. Personal data - any information that relates directly or indirectly to a certain or identified website user https://www.vetfaktor.ru/.
2.9. Personal data authorized by the subject of personal data for dissemination are personal data, which are accessible to an unlimited number of persons who are provided by the subject of personal data by consenting to the processing of personal data authorized by the subject of personal data for dissemination in accordance with the procedure provided for in the Personal Data Act (hereinafter referred to as personal data permitted for dissemination).
2.10. User – any visitor to the website https://www.vetfaktor.ru/.
2.11. Personal data are actions aimed at disclosing personal data to a particular person or group of persons.
2.12. The dissemination of personal data is any action aimed at exposing personal data to an uncertain range of persons (transmittal of personal data) or at familiarizing with personal data of an unlimited number of individuals, including the publication of personal data in the media, placing on information and telecommunications networks or providing access to personal data in any other way.
2.13. Cross-border transmission of personal data is the transfer of personal data to a foreign State authority, to a foreign natural or foreign legal person.
2.14. Personal data destruction is any action that results in personal data being destroyed irrecoverably, with no further restoration of personal data content in the Personal Data Information System and (or) the destruction of physical personal data media.

3. Basic rights and obligations of the Operator

3.1. The operator shall have the right:
- To obtain from the subject of personal data reliable information and/or documents containing personal data;
- If the subject of personal data withdraws consent to the processing of personal data, the Operator is entitled to continue the processing of personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Act;
- To determine independently the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations under the Personal Data Act and its implementing legislation, unless otherwise provided for in the Personal Data Act or other federal laws.
3.2. The operator shall:
- To provide the subject of personal data, upon request, with information relating to the processing of his personal data;
- To organize the processing of personal data in accordance with the procedure established by the legislation in force;
- To respond to requests and requests from personal data entities and their legal representatives in accordance with the requirements of the Personal Data Act;
- To communicate to the authorized body for the protection of the rights of personal data entities, at the request of that body, the necessary information within 30 days of the receipt of such a request;
- Publish or otherwise provide unrestricted access to the present Personal Data Processing Policy;
- Take legal, organizational and technical measures to protect personal data from undue or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, and other unlawful acts against personal data;
- Stop the transmission (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Personal Data Act;
- To perform other duties under the Personal Data Act.

4. Basic rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right:
- To receive information relating to the processing of his personal data, except as provided by federal laws; information shall be made available to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data entities, unless there are legitimate grounds for disclosure of such personal data; a list of information and the procedure for obtaining it shall be established by the Personal Data Act;
- Require the operator to specify, block or destroy his personal data if the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated processing purpose, and to take the measures required by law to protect his or her rights;
- To require prior consent in the processing of personal data for the promotion of goods, works and services;
- To withdraw consent to personal data processing;
- To appeal to the authorized body for the protection of the rights of personal data subjects or, by judicial means, to the operator's unlawful acts or omissions in the processing of his personal data;
- The exercise of other rights provided for in Russian legislation.
4.2. Personal data subjects are required to:
- To provide the Operator with reliable self-intelligence;
- To inform the Operator of the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves or information about another subject of personal data without the latter ' s consent are liable under Russian law.

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

5.1. Last name, first name and patronymic.
5.2. Electronic address.
5.3. Telephone numbers.

5.4. The site also collects and processes unnamed visitor data (including cookie files) through Internet statistics services (Yandex.Metrick et al.).

5.5. The above data are further combined into the general concept of Personal Data in the Policy.
5.6. No specific categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, intimate life are processed by the Operator.
5.7. Processing of personal data authorised for dissemination that falls within the special categories specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions in Article 10.1 of that law are observed.
5.8. The user ' s consent to the processing of personal data authorized for dissemination is treated separately from others, and the conditions laid down in article 10.1 of the Personal Data Act are met and the content of such consent is set by the authorized body for the protection of the rights of the subjects of personal data.
5.8.1 The user shall provide the Operator directly with consent to the processing of personal data authorized for distribution.
5.8.2 The operator shall publish, within three working days of receipt of the user ' s said consent, information on the conditions for processing, prohibitions and conditions for handling, without restriction, personal data authorized for distribution.
5.8.3 The transmission (distribution, provision, access) of personal data authorized by the subject of personal data for dissemination shall be discontinued at any time at the request of the subject of personal data; this requirement shall include the name, name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data to be stopped from processing; the personal data referred to in this requirement may only be processed by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data authorized for distribution shall cease to apply upon receipt by the Operator of the requirement specified in paragraph 5.8.3 of this Policy for the processing of personal data.

6. Principles for the processing of personal data

6.1. Personal data are processed in a lawful and fair manner.
6.2. Personal data processing is limited to specific, pre-defined and legitimate purposes, and personal data processing incompatible with the purposes of personal data collection is not permitted.
6.3. The consolidation of databases containing personal data, which are processed for purposes incompatible with each other, is not permitted.
6.4. Only personal data that are suitable for processing purposes are processed.
6.5. The content and volume of personal data processed are consistent with the stated processing purposes and the processing of personal data is not allowed to be redundant with the stated processing objectives.
6.6. The processing of personal data ensures the accuracy of personal data, its sufficiency and, where necessary, its relevance to the purposes of personal data processing; the operator shall take the necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows the identification of a personal data subject no longer than is required by the purposes of personal data processing if the period of time for which personal data are stored is not prescribed by federal law, a contract to which the beneficiary or guarantor of which the personal data entity is a party, the personal data being processed shall be destroyed or impersonalized when the processing objectives have been achieved, or if the need to achieve these objectives has been lost, unless otherwise provided by federal law.

7. Personal data processing objectives

7.1. Purpose of personal data processing of the User:
- Informing the User by sending e-mails;
- The conclusion, execution and termination of civil contracts;
- Access to services, information and/or content on the website https://www.vetfaktor.ru/.

7.2. The Operator also has the right to notify the User of new products and services, special offers and events. The user may always refuse to receive information messages by sending an e-mail to the Operator vet@faktor.ru with the indication "Refrain from notification of new products and services and special offers".
7.3. The user ' s personalized data collected through Internet statistics services are used to collect information on user actions on the website, to improve the quality of the site and its content.

8. Legal basis for processing personal data

8.1. The legal basis for the processing of personal data by the Operator is:
- Operator's statutes;
- Contracts between operator and subject of personal data;
- Federal laws and other regulations in the field of personal data protection;
- User consent to processing their personal data, processing the personal data allowed for dissemination.
8.2. The operator only handles the user ' s personal data if they are filled in and/or sent by the User on his/her own via special forms posted on the website https://www.vetfaktor.ru/ By filling in the relevant forms and/or sending its personal information to the Operator, the user agrees with the Policy.
8.3. The operator handles the user ' s identity data if permitted in the User browser settings (includes retention of cookie files and the use of JavaScript).
8.4. The subject of personal data shall decide on his or her own personal data and give consent freely, voluntarily and in his or her interest.

9. Conditions for processing personal data

9.1. Personal data shall be processed with the consent of the subject of personal data for the processing of his or her personal data.
9.2. Processing of personal data is necessary to achieve the objectives set out in an international treaty of the Russian Federation or by law in order to carry out the functions, powers and duties assigned by the legislation of the Russian Federation to the operator.
9.3. 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 in accordance with the law of the Russian Federation on execution proceedings.
9.4. Personal data processing is necessary for the performance of a contract for which either the beneficiary or guarantor of the identity entity is a party, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract for which the personal data entity will be the beneficiary or guarantor.
9.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of public objectives, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Personal data are processed and made available to an unlimited number of persons who have been provided by or at the request of the subject of personal data (hereinafter, publicly available personal data).
9.7. Personal data are processed for publication or mandatory disclosure under federal law.

10. Procedures for the collection, storage, transfer and other processing of personal data

The security of personal data that is processed by the Operator is ensured through the legal, organizational and technical measures necessary to fully comply with the requirements of existing legislation in the area of personal data protection.
10.1. The operator shall protect personal data and take all possible measures to prevent 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 enforcement of existing legislation or where the subject of personal data has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil contract.
10.3. If personal data are found to be inaccurate, the user can update them by notifying the Operator of the operator ' s e-mail address. vet@faktor.ru with the entry "Informatization of personal data".
10.4. The processing time for personal data is determined by the achievement of the purposes for which the personal data were collected, unless otherwise provided for in the contract or in the legislation in force.
The user may at any time withdraw his or her consent to the processing of personal data by notifying the Operator by e-mail to the Operator ' s electronic address vet@faktor.ru with "Recall for personal data processing".
10.5. All information that is collected by outsiders, including payment systems, communications and other service providers, shall be stored and processed by the designated persons (operators) in accordance with their user agreement and the Confidentiality Policy; the individual and/or user shall be obliged to consult the documents in a timely manner; the operator shall not be liable for the actions of third parties, including those of service providers referred to in this paragraph.
10.6. The individual ' s prohibitions on the transfer (other than access) of personal data, as well as on the processing or processing conditions (other than access) of personal data authorized for dissemination, do not apply in cases where personal data are processed in the public, public and other public interests defined by Russian legislation.
10.7. The operator shall ensure the confidentiality of personal data in the processing of personal data.
10.8. The operator shall keep personal data in a form that allows the identification of the subject of personal data no longer than the purpose of processing personal data requires if the duration of the storage of personal data is not specified by federal law, a contract to which the beneficiary or guarantor of which the subject of personal data is a beneficiary.
10.9. The condition for the termination of personal data processing may be that the objectives of personal data processing are fulfilled, that the consent of the subject of personal data is terminated or that the individual data is withdrawn, and that the identity data is detected as being improperly processed.

11. List of actions taken by the Operator with personal data

11.1. The operator shall collect, record, systematize, accumulate, store, clarify (update, change), recover, use, transfer (proliferation, provision, access), impersonalization, blocking, disposal and destruction of personal data.
11.2. The operator will process personal data automatically, receiving and/or transmitting the information received on or without information and telecommunications networks.

12. Cross-border transmission of personal data

12.1. The operator must ensure, prior to the commencement of cross-border transmission of personal data, that the foreign State to which the transfer of personal data is to take place is assured of the secure protection of the rights of the subjects of personal data.
12.2. Cross-border transmission of personal data on the territory of foreign States that do not meet the above requirements may take place only if the individual data subject consents in writing to cross-border transmission of his or her personal data and/or performance of the contract to which the personal data entity is a party.

13. Confidentiality of personal data

The operator and other persons who have access to personal data are required not to disclose to third parties or to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

14. Final provisions

14.1. The user may obtain any clarification on matters of interest relating to the processing of his personal data by contacting the Operator via e-mail. vet@faktor.ru.
14.2. This document will reflect any changes to the Personal Data Processing Policy of the Operator, which is open-ended until its replacement by a new version.
14.3. An up-to-date version of the Free Access Policy is available on the Internet at https://www.vetfaktor.ru/privacy/.