Personal data processing and security policy of LLC “3data DC”
LLC “3data DC” with its registered office at Room 2, Floor 1, Building 1, Novoryazanskaya str. 26-28, Moscow, 105066, INN 9701059753, OGRN 5167746483427 (hereinafter referred to as the Operator) highly values confidentiality of personal data. The Operator shall ensure legitimacy of personal data processing and adequate security level of processed personal data for compliance with the requirements of the Constitution of the Russian Federation, international agreements of the Russian Federation in personal data protection, Federal Law No 152-FZ of 27.07.2006 “On personal data” and its subordinate legislation.
1. General provisions
This policy related to personal data processing (hereinafter the Policy) shall define the position of the Operator related to the collection, processing and protection of personal data received including on the internet, observance of human and citizen’s rights and freedom when processing his personal data including the rights of privacy, personal and family secret. This Policy shall be applicable to the websites 3data.ru, cp.3data.ru and the Operator’s documents, which refer or which contains a reference to this Policy.
2. Basic concepts
Personal data means any information related directly or indirectly to a specific or designated individual.
Operator means LLC “3data DC”, independently or jointly with other persons organizing and/or carrying out personal data processing and determining the objectives of processing personal data, scope of personal data subject to processing, actions (operations) made with personal data.
Data processing means any action (operation) or cumulative actions (operations) made using automation means or without using such means with personal data, including the collection, record, systematization, accumulation, storage, elaboration (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data.
3. Processed Personal data and purposes of Personal data processing
The Operator may get your personal data as the representative of a legal entity – counterparty of the Operator under the holding of negotiations, execution or implementation of agreements in which personal data of such a legal entity as well as your personal data as an individual – counterparty of the Operator are provided for such purposes as, including but not limited to the execution, implementation of agreements on various lines of business of the Operator, holding of negotiations, creating an account on the website, analysis of the quality of service rendered by the Operator and improving the quality of service of the Operator’s counterparties. You can provide following Personal data to the Operator for the purposes specified above:
- User name;
- Email address (e-mail);;
By furnishing your Personal data you provide your consent to the Operator and permit the Operator to process your Personal data for the purposes specified above.
The Operator may assign the processing of your personal data for the purposes specified above to third parties – counterparties of the Operator (hereinafter the Counterparties of the Operator).
4. Personal data processing
The Operator shall process personal data on a legal and equitable basis and it is limited by the achievement of specific, predetermined and legitimate purposes.
Only personal data which serves the purposes of their processing shall be subject to processing. The content and scope of personal data processed by the Operator conform to the declared purposes of processing and may not be excessive with respect to the declared purposes of their processing.
Personal data shall be processed with the consent of the personal data subject for processing his personal data, as well as based on other legitimate grounds.
The Operator when processing personal data shall take the required legal, organizational and technical measures for personal data protection against illegal or accidental access to them, destruction, change, blocking, copying, provision, distribution of personal data, as well as against other illegal actions with respect to personal data.
The Operator shall undertake to not disclose to third parties and not distribute your Personal data without your approval excluding the cases requiring disclosure of personal data on request by the authorized state bodies, in the Russian Federation legislation and cases directly stipulated in this Policy.
The persons processing Personal data based on the agreement executed with the Operator shall undertake to maintain confidentiality, principles and rules for processing and protection of personal data, as well as assure security of personal data.
The Operator may in the course of its operation carry out cross-border transfer of personal data to legal entities or individuals on the territory of foreign states. Moreover, the issues of providing adequate protection of the rights of the personal data subjects and security assurance of their personal data during cross-border transfer are the highest priority for the company, resolution thereof shall be implemented in compliance with the law of the Russian Federation in personal data processing. You hereby give your consent for cross-border transfer of your personal data.
You express your consent and allow the Operator and Counteragent of the Operator to process your personal data using automated database management systems as well as other software and hardware.
The Operator shall have the right to independently determine the used methods of processing personal data (including but not limited to): automatic reconciliation checks of postal codes with the database of codes/indices, automatic check of writing the names of streets, settlements, segmentation of database by the given criteria etc. Your personal data shall be elaborated by telephone or by communicating through the internet (by email).
You acknowledge and agree that the Operator or Counterparties of the Operator shall have the right to interact with you by making direct contacts using various means of communication including but not limited to postal mailing, electronic mail, internet network etc. on condition of the Operator or such third parties complying with the Russian Federation laws in force.
5. Storage of personal data
The Operator company shall store personal data in the form allowing determine the personal data subject.
Personal data shall be stored no longer than it is required for the purposes of processing, if the storage period of personal data is not stipulated by the Federal law, agreement, a party thereof, beneficiary or guarantor for which is the personal data subject.
After achieving the purposes of processing personal data or in case of no further need in achieving these purposes, personal data shall be subject to destruction or anonymization.
Integration of database containing personal data is not permitted, the processing thereof is made for the purposes incompatible with one another.
Processed personal data shall be subject to destruction or anonymization upon achieving the purposes of processing or in case there is no further need in achieving these purposes, if not stipulated otherwise by the Federal law.
6. Rights of the personal data subjects
By providing your Personal data, you as the personal data subject shall to the extent allowed by law have the right to get information related to processing of your Personal data including the following:
- Confirmation of the fact of processing of personal data by the operator;
- Legal basis and purposes of processing personal data;
- Purposes and methods of processing personal data used by the operator;
- Name and location of the operator, information on the persons (excluding the operator’s employees), who have access to personal data or to whom personal data may be disclosed based on the agreement with the operator or on the basis of the Federal law;
- Processed personal data related to the relevant personal data subject, source of their receipt, if not stipulated otherwise by the Federal law;
- Periods of processing personal data including their storage periods;
- Procedure for the personal data subject exercising the rights;
- Information on carried out or on assumed cross-border data transfer;
- Name or surname, first name and patronymic and address of the person processing personal data by order of the operator if processing is assigned or shall be assigned to such a person;
- Other information stipulated by laws of the Russian Federation.
The personal data subject shall have the right to demand elaboration of his personal data, their blocking or erasure if personal data are incomplete, obsolete, incorrect, illegally received or not needed for the declared purpose of processing, and take the measures stipulated by law for protection of his rights.
The personal data subject shall also have the right to:
- Withdraw his consent for processing Data at any time;
- Demand correction of misconducts by the Operator with respect to his personal data;
- Appeal against the actions or inaction of the Operator to the Federal Service for Supervision in the Sphere of Communications, Information Technology and Mass Communications (Roskomnadzor) or by judicial means if the personal data subject considers that the Operator processes his personal data with breach of the requirements of law or otherwise infringes upon his rights and freedom;
- Protect his rights and legal interests including for compensation of the losses and/or compensation for moral injury through legal proceedings.
The personal data subjects may get explanations on issues of processing their personal data by approaching the Operator in person or by sending the relevant request in writing to the Operator’s registered office address::
Building 1, Novoryazanskaya st. 26, Moscow, 105066
It is required to specify the following if an official request is sent to the Operator:
- Surname, first name, patronymic of the Personal data subject or his representative;
- Number of the main document certifying the identity of the personal data subject or his representative, information on the date of issue of the specified document and the authority issuing it;
- Information confirming that the personal data subject has relation with the Operator;
- Feedback information for the purpose of the Operator sending a reply to the request;
- Signature of the personal data subject (or his representative). If the request is sent in the form of an electronic document, it must be signed and executed in the form of an electronic document and signed with electronic signature in compliance with the law of the Russian Federation.
7. Special conditions
The Operator shall take the required legal, organizational and technical measures for protection of Personal data against illegal and/or unauthorized access to them, destruction, change, blocking, copying, provision, distribution of personal data, as well as against other illegal actions with respect to personal data when processing Personal data. Such measures shall include (without limitation) physical, technical and design measures for protection of your personal data against unauthorized use, disclosure, change, damage or loss. For example, technically the Operator uses anti-virus software, encoding, system monitoring functions and protection of its data processing centers against attack; Operator shall determine the control measures of website traffic, only those persons who require this information for work shall get permission for access; in terms of design the Operator shall guarantee that its employees understand the importance of private data protection, for this purpose the Operator shall conduct the relevant workshops on issues of confidential information and personal data protection, and assure security of personal data.
The Senior Management of the Operator realizes the value and need for security assurance of personal data and promotes the regular improvement of the protection system of personal data processed under the performance of the company’s core activity.
The Operator shall familiarize each employee directly processing personal data with the requirements of the law of the Russian Federation for processing and security assurance of personal data with this Policy and other local acts of the company on issues of processing and security assurance of personal data.
The Policy shall be applicable on Personal data received by the Operator both before and after the implementation of this Policy.
The periods for processing (storing) personal data shall be determined based on the purposes for processing personal data in accordance with the validity of the agreement with the personal data subject, requirements of the Federal laws, basic rules of operation of the archives of organizations, limitation periods.
If the period for processing (storing) personal data has expired it shall be subject to destruction if not stipulated otherwise by the Federal Law.
8. Third-party service providers
The Operator’s websites may contain content and hyperlinks to the websites of third-party organizations. You may click these hyperlinks or read this content, as well as make use of the services or products of the specified third-party manufacturers, but please remember that the Operator does not control the specified third-party manufacturers. The Operator does not control the measures of third-party manufactures for protection of private, personal and confidential data. The provisions of this Policy shall not be applicable for the specified measures of third-party manufacturers, as well as on the information which you had decided yourselves to provide to the third-party manufacturers. It is recommended to get familiarized with the policies of third-party organizations for protection of private, personal and confidential information when personal data shall be provided by the Operator.
9. Update of information contained in this confidentiality policy
This Policy is in the public domain. The general availability of this Policy is provided by publishing it on the Operator’s website.
The Operator may periodically make changes to this Policy. In addition, the Operator shall make all efforts to post these changes on the Operator’s website.
Please send all the questions, comments or suggestions to the Operator’s address specified above.
By providing your Personal data to the Operator you confirm that you are familiar with this Policy, voluntarily and explicitly accept the terms and provisions of this Policy and agree for processing your Personal data in accordance with the Confidentiality Policy.
This Policy shall apply to the extent permitted by the applicable law of the RF.