Personal Data Processing Policy- General Provisions
This Personal Data Processing Policy was elaborated under the requirements of the Federal Law dated July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the "Law on Protection of Personal Data") and determines the order of processing personal data and measures to ensure the security of personal data taken by Solar Flow LLC (hereinafter referred to as the "Operator:).
1.1. The Operator sets as its most important goal, and a precondition for the implementation of its activities, the observance of human and civil rights and freedoms in the processing of his/her personal data including the protection of the rights to privacy and 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 the Operator may receive about visitors to https://solarflow.ru/eng.
2. General Terms and Its Definitions Applied in the Policy
2.1. "Automated personal data processing" means the processing of personal data using computer equipment.
2.2. "Personal data blocking" means temporary suspension of personal data processing (unless the processing is necessary to clarify personal data).
2.3. "Website" means a set of graphic and information materials, as well as programs for computers and databases that ensure their accessibility on the Internet at the network address https://solarflow.ru/eng.
2.4. "Personal data information system" means a set of personal data contained in databases, as well as information technologies and technical means of ensuring their processing.
2.5. "Depersonalization of personal data" means actions resulting in the impossibility to determine, without additional information, whether personal data belongs to a specific personal data subject.
2.6. "Personal data processing" means any action (operation) or a set of actions (operations) performed using automation tools or, without using such tools, with personal data including collection, recording, systematization, accumulation, storage, clarification (updating and modification), retrieval, use, transfer (distribution, provision, and access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. "Operator" means a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of personal data processing, the content of personal data to be processed, and actions (operations) performed with personal data.
2.8. "Personal data" means any information directly or indirectly relating to a specific or specified User of the website https://solarflow.ru/eng.
2.9. "Personal data allowed by the personal data subject for distribution" means personal data, access of an unlimited number of persons to whom is provided by the personal data subject by giving consent to personal data processing allowed by the personal data subject for distribution in the manner prescribed by the Law on Protection of Personal Data (hereinafter referred to as the "personal data allowed for distribution").
2.10. "User" means any visitor to the website https://solarflow.ru/eng.
2.11. "Provision of personal data" means actions aimed at disclosing personal data to a certain person or a certain set of persons.
2.12. "Distribution of personal data" means actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making an unlimited group of persons familiar with personal data including publication of personal data in mass media and information or telecommunications networks or otherwise granting access to personal data.
2.13. "Cross-border transfer of personal data" means the transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. "Destruction of personal data" means actions resulting in the impossibility to restore the contents of personal data in the personal data information system and (or) in the destruction of personal data storage media.
3. Operator's basic rights and obligations
3.1. The Operator shall be entitled to:
— receive from the personal data subject reliable information and/or documents containing personal data;
– if the personal data subject withdraws consent to personal data processing, as well as sending a request to terminate the processing of personal data, the Operator shall be entitled to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Protection of Personal Data;
— independently determine the set and list of measures necessary and sufficient to ensure the fulfilment of obligations stipulated by the Law on Protection of Personal Data and regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Law on Protection of Personal Data or other federal laws;
3.2. The Operator shall be obliged to:
— provide the personal data subject, at his/her request, with information relating to the processing of his/her personal data;
— organize the personal data processing in the manner prescribed by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the Law on Personal Data;
— report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Law on Personal Data;
— perform other duties provided for by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects shall have the right to:
— receive information regarding the processing of his personal data, with the exception of cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it shall not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
— demand that the Operator clarify his/her personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures prescribed by law to protect his/her rights;
— put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
— withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of his 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 data about him/herself;
— inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have transferred false information about themselves to the Operator, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. Personal data processing is restricted by achieving specific, predetermined and legitimate goals. Personal data processing incompatible with the purposes of collecting personal data is prohibited.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed corresponds to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance to the purposes of personal data processing are ensured. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows determining the personal data subject no longer than the purposes of personal data processing requires, unless the period of personal data storage is established by federal law, a contract to which the personal data subject is a party, a beneficiary or a guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing goals, or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
6. Purpose of personal data processing
- The purpose of processing is to inform the User by sending emails
- Personal data: surname, name, patronymic
- email
- phone numbers
- Legal grounds: Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" dated July 27, 2006
- Types of personal data processing
- Sending newsletters to email address
7. Terms of personal data processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. The personal data processing is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The personal data processing is necessary for the performance of an agreement, to which the subject of the personal data is either a party or a beneficiary or a guarantor, as well as for concluding an agreement on the initiative of the subject of personal data, or an agreement under which the subject of personal data will be a beneficiary or guarantor.
7.5. The personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. The personal data is processed with the access to it of an unlimited number of persons provided by the personal data subject, or at his/her request (hereinafter referred to as the publicly available personal data).
7.7. The personal data is processed subject to publication or mandatory disclosure in accordance with federal law of the Russian Federation.
8. Procedure for collection, storage, and other types of personal data processing
The security of the personal data to be processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure compliance with requirements of applicable regulatory framework in the area of the personal data protection.
8.1. The Operator shall ensure the security of personal data and undertake all reasonable actions to prevent any unauthorized access to these data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or if the personal 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.
8.3. In case of inaccuracies in the personal data, the User may update this data independently by sending a notification to the Operator's email address at info@solarflow.ru, with the note "Updating the personal data".
8.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless otherwise provided by the contract or the current legislation.
At any time, the User may revoke his/her consent to personal data processing by sending a notification to the Operator via email to the Operator’s email at info@solarflow.ru with the subject “Revocation of consent to personal data processing”.
8.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. 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 of processing (except for access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public and other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The operator shall store personal data in a form that allows determining the personal data subject no longer than the purposes of personal data processing requires, unless the period of personal data storage is established by federal law, a contract to which the personal data subject is a party, a beneficiary or a guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or the requirement to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator shall carry out collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator shall carry out automated processing of personal data with or without receiving and/or transmitting the received information over information and telecommunication networks.
10. Cross-border personal data transfers
10.1. Prior to the commencement of activities on cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notice, the Operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Personal data confidentiality
The Operator and other persons who have gained access to personal data shall not disclose it to third parties and shall not distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User can receive any clarifications on issues of interest relating to his/her personal data processing by contacting the Operator via email: info@solarflow.ru
12.2. This document will reflect any changes to the Personal Data Processing Policy applied by the Operator. The Policy is valid indefinitely until its replacement with a new revision.
12.3. The current version of the Policy is freely available on the Internet at https://solarflow.ru/politika-eng.