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 July 2006 «On Personal Data» (hereinafter — the Personal Data Law) and defines the order of personal data processing and the measures taken to ensure the security of personal data by Limited Liability Company «APIK», OGRN 1235000017141 (hereinafter — the Operator).
1.1. The Operator considers compliance with the rights and freedoms of the individual when processing their personal data — including the protection of the right to privacy and to personal and family confidentiality — to be the most important goal and condition of its activities.
1.2. This policy of the Operator regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may receive about visitors of the website https://apeek.ru.
2. Key terms used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing facilities.
2.2. Blocking of personal data — temporary suspension of processing of personal data (except for cases when processing is required to clarify the personal data).
2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases, available on the Internet at https://apeek.ru.
2.4. Personal data information system — a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymisation of personal data — actions that make it impossible, without the use of additional information, to attribute personal data to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, organisation, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that, alone or jointly with others, organises and (or) processes personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly relating to a specific or identifiable User of the website https://apeek.ru.
2.9. Personal data permitted by the data subject for distribution — personal data to which access by an unlimited circle of persons has been granted by the data subject by giving consent to the processing of personal data permitted for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor of the website https://apeek.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or at familiarising an unlimited circle of persons with personal data, including disclosing personal data in mass media, posting them on information and telecommunication networks, or providing 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 the authorities of a foreign state, or to a foreign individual or legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data and the impossibility of further restoring the content of personal data in the personal data information system, and (or) destruction of the physical media of personal data.
3. Key rights and obligations of the Operator
3.1. The Operator is entitled to:
– receive from the data subject reliable information and (or) documents containing personal data;
– if the data subject withdraws consent to the processing of personal data, the Operator is entitled to continue processing the personal data without the data subject's consent if grounds specified in the Personal Data Law exist;
– independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law and the 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 data subject, upon request, with information concerning the processing of their personal data;
– organise the processing of personal data in the manner established by the current legislation of the Russian Federation;
– respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide, upon request, the authority for the protection of the rights of personal data subjects with the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise ensure unrestricted access to this Policy on personal data processing;
– take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision and distribution, as well as from other unlawful actions in relation to personal data;
– cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
– perform other obligations provided for by the Personal Data Law.
4. Key rights and obligations of personal data subjects
4.1. Personal data subjects are entitled 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 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;
– require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and to take legally provided measures to protect their rights;
– put forward a condition of prior consent when processing personal data for the purpose of promoting goods, work and services in the market;
– withdraw consent to the processing of personal data;
– appeal to the authority for the protection of the rights of personal data subjects, or in court, the unlawful actions or inaction of the Operator when processing their personal data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
– provide the Operator with reliable information about themselves;
– inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Year, month, date and place of birth.
5.5. Photographs.
5.6. Citizenship certificate.
5.7. Identity document details.
5.8. Address of actual residence and registration at the place of residence and (or) place of stay.
5.9. Information on education, profession, specialty and qualification, details of educational documents.
5.10. Information on family status and family composition.
5.11. Information on property status.
5.12. Income information.
5.13. Information on previously held positions and length of service, military duty, military registration. Including resumes for the recruitment and selection of job candidates.
5.14. Other information (the listed range may be reduced or expanded depending on the specific case and processing purposes).
5.15. The website also collects and processes anonymised data about visitors (including cookies) using internet statistics services (Yandex Metrica, Google Analytics and others).
5.16. The above data are hereinafter referred to in this Policy as Personal Data.
5.17. The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or sex life.
5.18. Processing of personal data permitted for distribution from among the special categories of personal data specified in Article 10(1) of the Personal Data Law is permitted if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are met.
5.19. The User's consent to the processing of personal data permitted for distribution is drawn up separately from other consents to the processing of their personal data. The conditions provided for, in particular, in Article 10.1 of the Personal Data Law shall be observed. Requirements for the content of such consent are set by the authority for the protection of the rights of personal data subjects.
5.19.1 The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
5.19.2 The Operator must, no later than three working days from the receipt of such consent, publish information about the conditions of processing and the prohibitions and conditions on the processing by an unlimited circle of persons of personal data permitted for distribution.
5.19.3 The transfer (distribution, provision, access) of personal data permitted by the data subject for distribution must be terminated at any time at the request of the data subject. Such request must include the last name, first name, patronymic (if any), contact information (phone number, email or postal address) of the data subject, as well as the list of personal data the processing of which is to be terminated. The personal data specified in such request may be processed only by the Operator to whom it has been sent.
5.19.4 Consent to the processing of personal data permitted for distribution terminates from the moment the Operator receives the request specified in clause 5.19.3 of this Policy on personal data processing.
6. Principles of personal data processing
6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. Personal data processing is limited to the achievement of specific, predefined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
6.3. The merging of databases containing personal data processed for purposes incompatible with each other is not permitted.
6.4. Only personal data that meet the purposes of processing are subject to processing.
6.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessiveness of personal data processed in relation to the stated purposes of their processing is not permitted.
6.6. When processing personal data, accuracy, sufficiency and, where necessary, relevance of personal data with respect to the purposes of processing are ensured. The Operator takes the necessary measures and (or) ensures that they are taken to remove or refine incomplete or inaccurate data.
6.7. Personal data are stored in a form that allows the data subject to be identified, no longer than is required for the purposes of processing, unless the storage period is established by federal law, or by a contract to which the data subject is a party, beneficiary or surety. Processed personal data are destroyed or anonymised upon reaching the purposes of processing or upon loss of the need to achieve these purposes, 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;
– conclusion, performance and termination of civil-law contracts;
– providing the User with access to the services, information and (or) materials contained on the website https://apeek.ru;
– personnel records management;
– providing personal data subjects with the Operator's services and information about the Operator's development of new products and services, including for advertising purposes;
– completing and submitting required reporting forms to executive authorities and other authorised organisations;
– performing other functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.2. The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User can always unsubscribe from informational messages by sending the Operator a letter to team@apeek.ru with the note «Opt-out from new products, services and special offer notifications».
7.3. Anonymised User data collected via internet statistics services are used to gather information about User actions on the website and to improve the quality of the website and its content.
8. Legal grounds for personal data processing
8.1. The legal grounds for personal data processing by the Operator are:
– contracts concluded between the Operator and the data subject;
– Federal Law No. 149-FZ of 27 July 2006 «On Information, Information Technologies and Information Protection»;
– federal laws and other regulatory legal acts in the field of personal data protection;
– consents of Users to the processing of their personal data, and to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only when they are filled in and (or) sent by the User on their own through the special forms located on the site https://apeek.ru, or sent to the Operator by email. By filling in the relevant forms and (or) sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymised data about the User if it is permitted in the User's browser settings (cookies storage and JavaScript are enabled).
8.4. The data subject independently makes the decision to provide their personal data and gives consent freely, by their own will and in their own interest.
9. Conditions of personal data processing
9.1. Personal data are processed with the consent of the data subject to the processing of their personal data.
9.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers and duties imposed by the legislation of the Russian Federation on the Operator.
9.3. Personal data processing is necessary for the administration of justice, the execution of a court act, an act of another body or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Personal data processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or surety, as well as for entering into a contract on the initiative of the data subject or a contract under which the data subject will be the beneficiary or surety.
9.5. Personal data processing is necessary for the exercise of the rights and lawful interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
9.6. Processing is performed of personal data to which an unlimited circle of persons has been granted access by the data subject or at their request (publicly accessible personal data).
9.7. Processing is performed of personal data subject to publication or mandatory disclosure in accordance with federal law.
10. Procedure for the collection, storage, transfer and other processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organisational and technical measures necessary for the full compliance 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 prevent access to personal data by unauthorised persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation, or where the data subject has consented to the Operator transferring data to a third party for the performance of obligations under a civil-law contract.
10.3. If inaccuracies are found in the personal data, the User can update them on their own by sending a notification to the Operator's email team@apeek.ru with the note «Personal data update».
10.4. The personal data processing period is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or by current legislation.
The User can withdraw their consent to personal data processing at any time by sending a notification to the Operator by email at team@apeek.ru with the note «Withdrawal of consent to personal data processing».
10.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and (or) the User is obliged to familiarise themselves with these documents in a timely manner. The Operator is not liable for the actions of third parties, including the service providers mentioned in this clause.
10.6. Prohibitions on transfer (other than provision of access), as well as on processing or processing conditions (other than obtaining access) of personal data permitted for distribution, established by the data subject, do not apply in cases of personal data processing in state, public and other public interests defined by the legislation of the Russian Federation.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows the data subject to be identified, no longer than the purposes of processing require, unless the storage period for personal data is established by federal law, or by a contract to which the data subject is a party, beneficiary or surety.
10.9. The condition for terminating personal data processing may be the achievement of the purposes of processing, the expiration of the data subject's consent, the withdrawal of consent by the data subject, or the detection of unlawful processing of personal data.
11. List of actions performed by the Operator with the personal data received
11.1. The Operator carries out collection, recording, organisation, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with or without the receipt and (or) transfer of the information received via information and telecommunication networks.
12. Cross-border transfer of personal data
12.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to which the personal data are to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent of the data subject to the cross-border transfer of their personal data and (or) for the performance of a contract to which the data subject is a party.
13. Confidentiality of personal data
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 data subject, unless otherwise provided by federal law.
14. Final provisions
14.1. The User can obtain any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator at team@apeek.ru.
14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available online at https://apeek.ru/privacy.