Personal Data Processing Policy
Privacy PolicyPersonal Data Processing Policy
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and establishes the procedure for processing personal data and the measures taken to ensure the security of personal data by EXOARI L (hereinafter referred to as the “Operator”).
1. General Provisions
1.1. The Operator considers the protection of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy and personal and family confidentiality, to be one of the most important objectives and conditions of its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the Website https://exoaril.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where such processing is necessary to clarify the personal data.
2.3. Website means a collection of graphic and informational materials, computer programs and databases ensuring their availability online at https://exoaril.com.
2.4. Personal data information system means a set of personal data contained in databases and information technologies and technical means used for their processing.
2.5. Depersonalization of personal data means actions resulting in the impossibility of determining, without the use of additional information, the identity of the personal data to a specific User or other personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automated means in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.
2.7. Operator means a state or municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the scope of personal data to be processed, and the actions performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the Website https://exoaril.com.
2.9. Personal data made publicly available by the data subject means personal data to which an unlimited number of persons has been granted access by the data subject through consent to the processing of such personal data in accordance with the procedure established by the Personal Data Law.
2.10. User means any visitor to the Website https://exoaril.com.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons, including publication in the mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a governmental authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore its contents in a personal data information system and/or resulting in the destruction of physical media containing personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
4.1. Personal data subjects have the right to:
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Processing of personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which the data were collected is not permitted.
5.3. Databases containing personal data processed for purposes that are incompatible with one another shall not be combined.
5.4. Only personal data that correspond to the purposes of their processing shall be processed.
5.5. The content and scope of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. The accuracy, sufficiency and, where necessary, relevance of personal data shall be ensured in relation to the purposes of processing. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than necessary to fulfill the purposes of processing, unless a storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.
Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or when it is no longer necessary to achieve such purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
7.1. Personal data shall be processed with the consent of the personal data subject.
7.2. Processing of personal data is necessary to achieve the purposes established by an international treaty of the Russian Federation or by law, or to perform functions, powers and obligations imposed on the Operator by Russian legislation.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a court decision or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for entering into a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing concerns personal data to which an unlimited number of persons has been granted access by the data subject or at their request (publicly available personal data).
7.7. Processing concerns personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Collection, Storage, Transfer and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with applicable legislation concerning the protection of personal data.
8.1. The Operator ensures the security of personal data and takes all reasonable measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never be transferred to third parties, except where such transfer is required by applicable law or where the personal data subject has consented to the transfer of their data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update their data by sending a notification to the Operator's email address exoaril.ru@gmail.com with the subject line “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is established by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator's email address exoaril.ru@gmail.com with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by such third parties (Operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject should review the relevant documents of such third parties. The Operator is not responsible for the actions of third parties, including the service providers referred to in this section.
8.6. Restrictions established by a personal data subject on the transfer (except for granting access), processing or conditions of processing of personal data made publicly available shall not apply where such personal data are processed in the public, governmental or other public interests defined by Russian legislation.
8.7. The Operator shall ensure the confidentiality of personal data when processing such data.
8.8. The Operator shall store personal data in a form that allows identification of the data subject for no longer than necessary to fulfill 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 guarantor.
8.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the data subject's consent, withdrawal of consent, receipt of a request to terminate processing, or identification of unlawful processing.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating and modification), extraction, use, transfer (distribution, provision and access), depersonalization, blocking, deletion and destruction.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of information through information and telecommunications networks, or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized personal data protection authority of its intention to carry out such transfer. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above notification, the Operator shall obtain the relevant information from the governmental authorities of the foreign state, foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data shall not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may receive any clarification regarding the processing of their personal data by contacting the Operator via email at exoaril.ru@gmail.com.
12.2. Any amendments to the Operator's personal data processing policy shall be reflected in this document. This Policy shall remain in force indefinitely until it is replaced by a new version.
12.3. The current version of this Policy is freely available online at https://exoaril.com/policy.
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and establishes the procedure for processing personal data and the measures taken to ensure the security of personal data by EXOARI L (hereinafter referred to as the “Operator”).
1. General Provisions
1.1. The Operator considers the protection of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy and personal and family confidentiality, to be one of the most important objectives and conditions of its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the Website https://exoaril.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where such processing is necessary to clarify the personal data.
2.3. Website means a collection of graphic and informational materials, computer programs and databases ensuring their availability online at https://exoaril.com.
2.4. Personal data information system means a set of personal data contained in databases and information technologies and technical means used for their processing.
2.5. Depersonalization of personal data means actions resulting in the impossibility of determining, without the use of additional information, the identity of the personal data to a specific User or other personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automated means in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.
2.7. Operator means a state or municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the scope of personal data to be processed, and the actions performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the Website https://exoaril.com.
2.9. Personal data made publicly available by the data subject means personal data to which an unlimited number of persons has been granted access by the data subject through consent to the processing of such personal data in accordance with the procedure established by the Personal Data Law.
2.10. User means any visitor to the Website https://exoaril.com.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons, including publication in the mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a governmental authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore its contents in a personal data information system and/or resulting in the destruction of physical media containing personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive accurate information and/or documents containing personal data from the data subject;
- continue processing personal data without the data subject's consent if the data subject withdraws consent to the processing of personal data or submits a request to terminate such processing, provided that there are legal grounds established by the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to fulfill its obligations under the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.
- provide the data subject, upon request, with information concerning the processing of their personal data;
- organize the processing of personal data in accordance with applicable legislation of the Russian Federation;
- respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized personal data protection authority, upon its request, with the necessary information within 10 days from the date of receipt of such request;
- publish this Policy or otherwise ensure unrestricted access to it;
- take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution and other unlawful actions;
- cease the transfer (distribution, provision or access to) personal data, terminate processing and destroy personal data in accordance with the procedures and cases established by the Personal Data Law;
- perform other obligations established by the Personal Data Law.
4.1. Personal data subjects have the right to:
- receive information concerning the processing of their personal data, except in cases provided for by federal law;
- require the Operator to correct, block or delete their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
- require prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
- withdraw their consent to the processing of personal data and request termination of such processing;
- appeal unlawful actions or omissions of the Operator in relation to the processing of personal data to the authorized personal data protection authority or to a court;
- exercise other rights provided by the legislation of the Russian Federation.
- provide the Operator with accurate information about themselves;
- notify the Operator of any clarification, update or change to their personal data.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Processing of personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which the data were collected is not permitted.
5.3. Databases containing personal data processed for purposes that are incompatible with one another shall not be combined.
5.4. Only personal data that correspond to the purposes of their processing shall be processed.
5.5. The content and scope of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. The accuracy, sufficiency and, where necessary, relevance of personal data shall be ensured in relation to the purposes of processing. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than necessary to fulfill the purposes of processing, unless a storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.
Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or when it is no longer necessary to achieve such purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
- conclusion, performance and termination of civil-law contracts.
- first name, last name and patronymic;
- email address;
- telephone numbers.
- contracts concluded between the Operator and the personal data subject.
- sending informational emails to the email address.
7.1. Personal data shall be processed with the consent of the personal data subject.
7.2. Processing of personal data is necessary to achieve the purposes established by an international treaty of the Russian Federation or by law, or to perform functions, powers and obligations imposed on the Operator by Russian legislation.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a court decision or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for entering into a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing concerns personal data to which an unlimited number of persons has been granted access by the data subject or at their request (publicly available personal data).
7.7. Processing concerns personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Collection, Storage, Transfer and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with applicable legislation concerning the protection of personal data.
8.1. The Operator ensures the security of personal data and takes all reasonable measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never be transferred to third parties, except where such transfer is required by applicable law or where the personal data subject has consented to the transfer of their data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update their data by sending a notification to the Operator's email address exoaril.ru@gmail.com with the subject line “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is established by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator's email address exoaril.ru@gmail.com with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by such third parties (Operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject should review the relevant documents of such third parties. The Operator is not responsible for the actions of third parties, including the service providers referred to in this section.
8.6. Restrictions established by a personal data subject on the transfer (except for granting access), processing or conditions of processing of personal data made publicly available shall not apply where such personal data are processed in the public, governmental or other public interests defined by Russian legislation.
8.7. The Operator shall ensure the confidentiality of personal data when processing such data.
8.8. The Operator shall store personal data in a form that allows identification of the data subject for no longer than necessary to fulfill 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 guarantor.
8.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the data subject's consent, withdrawal of consent, receipt of a request to terminate processing, or identification of unlawful processing.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating and modification), extraction, use, transfer (distribution, provision and access), depersonalization, blocking, deletion and destruction.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of information through information and telecommunications networks, or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized personal data protection authority of its intention to carry out such transfer. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above notification, the Operator shall obtain the relevant information from the governmental authorities of the foreign state, foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data shall not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may receive any clarification regarding the processing of their personal data by contacting the Operator via email at exoaril.ru@gmail.com.
12.2. Any amendments to the Operator's personal data processing policy shall be reflected in this document. This Policy shall remain in force indefinitely until it is replaced by a new version.
12.3. The current version of this Policy is freely available online at https://exoaril.com/policy.