[ INVIAN ]
Privacy Policy on the Processing of Personal Data
- General Provisions
- This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152‑FZ of July 27 2006 “On Personal Data” (hereinafter the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure personal data security undertaken by LLC “Интеллектуальная видеоаналитика” (hereinafter the Operator). The Operator’s paramount goal and condition for carrying out its activities is the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of privacy, personal and family secrets. This Operator policy on personal data processing (hereinafter the Policy) applies to all information that the Operator may obtain about visitors of the website https://invian.ru.
- Key Concepts Used in the Policy
- Automated personal data processing – processing of personal data using computer technology.
- Blocking of personal data – temporary suspension of processing of personal data (except where processing is necessary to clarify the personal data).
- Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://invian.ru.
- Personal data information system – the collection of personal data contained in databases together with the information technologies and technical means that ensure their processing.
- Anonymization of personal data – actions that make it impossible to determine, without additional information, the belonging of personal data to a specific User or another data subject.
- Processing of personal data – any action (operation) or set of actions (operations) performed with the use of automation tools or without such tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
- Operator – a state body, municipal body, legal or natural person who, independently or jointly with others, organizes and/or carries out personal data processing, as well as determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed on the data.
- Personal data – any information directly or indirectly relating to a specific or identifiable User of the website https://invian.ru.
- Personal data permitted by the data subject for dissemination – personal data whose access is granted to an unlimited circle of persons by the data subject through consent to the processing of personal data, permitted for dissemination in the manner provided by the Personal Data Law (hereinafter personal data permitted for dissemination).
- User – any visitor of the website https://invian.ru.
- Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
- Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publication in the mass media, placement in information‑telecommunication networks, or providing access to personal data by any other means.
- Cross‑border transfer of personal data – transfer of personal data to the territory of a foreign state, to a foreign government body, foreign natural person or foreign legal entity.
- Destruction of personal data – any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoring its content in the personal data information system and/or the destruction of the material carriers of personal data.
- Main Rights and Obligations of the Operator
- The Operator has the right to:
- — receive from the data subject reliable information and/or documents containing personal data;
- —, in case the data subject withdraws consent to personal data processing or submits a request to terminate processing, continue processing personal data without the data subject’s consent if the grounds specified in the Personal Data Law are present;
- — independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and the normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
- The Operator is obliged to:
- — provide the data subject, upon request, information concerning the processing of his/her personal data;
- — organize personal data processing in the manner established by current Russian legislation;
- — respond to appeals and requests of data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- — report to the authorized body for the protection of data subjects’ rights, upon its request, the necessary information within 10 days from the receipt of such request;
- — publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
- — adopt legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions concerning personal data;
- — cease transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the cases and manner provided by the Personal Data Law;
- — fulfil any other obligations stipulated by the Personal Data Law.
- Main Rights and Obligations of Data Subjects
- Data subjects have the right to:
- — receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form, and it must not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
- — to require the operator to clarify his personal data, to block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the declared purpose of processing, and also to take measures provided by law to protect his rights;
- — to impose a condition of prior consent when processing personal data for the purpose of market promotion of goods, works and services;
- — to withdraw consent to the processing of personal data, as well as to send a request to cease processing personal data;
- — to appeal to the authorized body for the protection of data subjects' rights or to the court against unlawful actions or omissions of the Operator in processing his personal data;
- — to exercise other rights provided by the legislation of the Russian Federation.
- Data subjects are obliged to:
- — provide the Operator with accurate data about themselves;
- — inform the Operator about any clarification (update, change) of their personal data. Persons who provide the Operator with inaccurate information about themselves, or information about another data subject without that person's consent, are liable in accordance with Russian legislation.
- Principles of personal data processing
- Processing of personal data is carried out on a lawful and fair basis. Processing of personal data is limited to achieving specific, predetermined and lawful goals. Processing of personal data incompatible with the purposes of collection is not allowed. Merging of databases containing personal data whose processing is carried out for purposes that are incompatible with each other is prohibited. Only personal data that correspond to the purposes of their processing are subject to processing. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of processing is not permitted. When processing personal data, accuracy, adequacy and, where necessary, relevance of personal data with respect to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or correct incomplete or inaccurate data. Storage of personal data is carried out in a form that allows identification of the data subject, no longer than required by the purposes of processing, if the retention period is not set by a federal law, a contract, a party whose beneficiary or guarantor is the data subject. Processed personal data are destroyed or anonymized upon achievement of the processing purposes or when the need to achieve those purposes ceases, unless otherwise provided by federal law.
- Purposes of personal data processing
- Purpose of processing: informing the User by sending e‑mail messages.
- Personal data
- surname, given name, patronymic
- e‑mail address
- phone numbers
- Company name
- Legal basis
- Federal Law “On Information, Information Technologies and Information Protection” of 27 July 2006 No. 149‑FZ
- Types of personal data processing
- Transfer of personal data
- Conditions of personal data processing
- Processing of personal data is carried out with the consent of the data subject to the processing of his personal data. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers and responsibilities imposed on the operator by the legislation of the Russian Federation. Processing of personal data is necessary for the administration of justice, the execution of a court order, an act of another authority or official, to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings. Processing of personal data is necessary for the performance of a contract, a party to which or a beneficiary or guarantor of which is the data subject, as well as for concluding a contract at the initiative of the data subject or a contract under which the data subject will be the beneficiary or guarantor. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the data subject are not violated. Processing of personal data is carried out when access is provided to an unrestricted circle of persons by the data subject himself or at his request (hereinafter – publicly available personal data). Processing of personal data subject to publication or mandatory disclosure in accordance with a federal law is carried out. Procedure for collection, storage, transfer and other forms of processing of personal data.
- 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. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data. 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 when the data subject has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil‑law contract. In case inaccuracies are found in personal data, the User may update them himself by sending a notification to the Operator at the e‑mail address info@invian.ru with the note “Personal data update”. The processing period of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is stipulated by a contract or applicable law. The User may at any time withdraw his consent to the processing of personal data by sending the Operator a notification by e‑mail to info@invian.ru with the note “Withdrawal of consent to personal data processing”. All information that is collected by third‑party services, including payment systems, communication means, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy of the Data Subject and/or the specified documents. The Operator does not bear responsibility for the actions of third parties, including the service providers mentioned in this clause. Prohibitions established by the data subject on transfer (except providing access), as well as on processing or processing conditions (except obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation. When processing personal data, the Operator ensures the confidentiality of personal data. The Operator stores personal data in a form that allows identification of the data subject no longer than required by the purposes of processing, if the retention period is not stipulated by federal law, a contract, where the data subject is the party, beneficiary, or guarantor. A condition for terminating the processing of personal data may be the achievement of the processing purposes, expiration of the data subject's consent, withdrawal of consent by the data subject, a request to cease processing, as well as detection of unlawful processing of personal data. List of actions performed by the Operator with the obtained personal data: the Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, accesses), anonymizes, blocks, deletes, and destroys personal data. The Operator carries out automated processing of personal data with receipt and/or transmission of the obtained information via information‑telecommunication networks or without them. Cross‑border transfer of personal data: before commencing activities related to cross‑border transfer of personal data, the Operator must notify the authorized body for protection of data subjects' rights of its intention to carry out such transfer (such notification is sent separately from the notification of intention to process personal data). Before submitting the aforementioned notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross‑border transfer is planned, the relevant information. Confidentiality 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 disseminate personal data without the consent of the data subject, unless otherwise provided by federal law. Final provisions: the user may obtain any explanations on issues concerning the processing of his personal data by contacting the Operator via email info@invian.ru. This document will reflect any changes to the personal data processing policy by the Operator. The policy is effective indefinitely until replaced by a new version. The current version of the policy is freely available on the Internet at https://invian.ru/privacy
