Personal Data Processing Policy
General Provisions
This personal data processing policy is developed in accordance with the requirements of the Federal Law dated 27.07.2006 No. 152-FZ «On Personal Data» (hereinafter referred to as the Personal Data Law) and defines the procedures for processing personal data and measures to ensure the security of personal data taken by Malpensa-IT (hereinafter referred to as the Operator).
1.1. The Operator aims to ensure the observance of human and citizen rights and freedoms when processing personal data, including the protection of the right to privacy, personal, and family secrets.
1.2. This Operator’s policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://malpensa-it.com.
Basic Concepts Used in the Policy
2.1. Automated personal data processing — processing of personal data using computing resources.
2.2. Blocking of personal data — temporary cessation of personal data processing (except when processing is necessary for clarifying personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the address https://malpensa-it.com.
2.4. Personal Data Information System — a collection of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Anonymization of personal data — actions that result in the inability to determine, without using additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Personal data processing — any action (operation) or combination of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual organizing and/or carrying out personal data processing independently or jointly with other persons, as well as determining 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 relating directly or indirectly to a specific or definable User of the website https://malpensa-it.com.
2.9. Personal data, approved by the subject of personal data for distribution — personal data to which access is granted to an unlimited number of persons by the personal data subject by providing consent for processing personal data approved for distribution in accordance with the Personal Data Law (hereinafter referred to as personal data approved for distribution).
2.10. User — any visitor to the website https://malpensa-it.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at providing access to personal data to an unlimited number of persons, including public disclosure of personal data in the 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 — transfer of personal data to the territory of a foreign state to an authority of a foreign state, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in personal data being irretrievably destroyed with no possibility of further restoring the content of personal data in the personal data information system and/or destroying physical carriers of personal data.
Main Rights and Duties of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in case of withdrawal of consent by the subject of personal data for processing personal data, as well as a request to cease processing, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and adopted legal acts unless otherwise specified by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, at their request, information regarding the processing of their personal data;
— organize personal data processing in accordance with the current legislation of the Russian Federation;
— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of subjects of personal data, at the request of this body, with the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions regarding personal data;
— cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data according to the procedures and cases stipulated by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
Main Rights and Duties of Personal Data Subjects
4.1. Subjects of personal data have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data related to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for its acquisition are established by the Personal Data Law;
— require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and also take measures to protect their rights as specified by law;
— impose a condition of prior consent when processing personal data for marketing purposes of goods, works, and services;
— withdraw consent for the processing of personal data, as well as submit a request to cease processing personal data;
— contest in the authorized body for the protection of the rights of subjects of personal data or in court the unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights stipulated by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable information about themselves;
— notify the Operator of any clarifications (updates, changes) to their personal data.
4.3. Persons who provided the Operator with unreliable information about themselves or information about another personal data subject without their consent bear responsibility in accordance with the legislation of the Russian Federation.
Principles of Personal Data Processing
5.1. Personal data processing is carried out lawfully and fairly.
5.2. Personal data processing is limited to achieving specific, pre-defined, and lawful goals. Processing personal data incompatible with the purposes of data collection is not permitted.
5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the processing goals is subject to processing.
5.5. The content and scope of personal data processed must meet the stated processing goals. Excessive personal data processing in relation to the stated goals is not permitted.
5.6. The accuracy of personal data is ensured during processing, along with its sufficiency and, where necessary, its relevance to the goals of personal data processing. The Operator takes necessary measures or ensures the removal or clarification of incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the personal data subject for no longer than is required for the purposes of personal data processing, unless the storage period is established by federal law, an agreement, or the subject of personal data is a party, beneficiary, or guarantor under such an agreement. Processed personal data is destroyed or anonymized upon achieving the processing goals or if the need for achieving these goals is lost unless otherwise stipulated by federal law.
Purposes of Personal Data Processing
Purpose of processing: Inform the User by sending electronic emails.
Personal data: Philosophical beliefs
Legal basis: Federal Law «On Information, Information Technologies, and Information Protection» dated 27.07.2006 No. 149-FZ
Types of personal data processing: Transmission of personal data
Conditions for Personal Data Processing
7.1. Personal data processing is conducted with the consent of the personal data subject for processing their personal data.
7.2. Personal data processing is necessary to achieve goals provided for by international treaties of the Russian Federation or laws for performing functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for administering justice, executing judicial acts, actions from other authorities or officials that must be executed under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary to fulfill a contract, one party of which is the personal data subject or for the benefit of which a third party is a beneficiary or guarantor, as well as for signing a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for exercising the rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed when the access to which has been provided by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Personal data processing is conducted regarding personal data subject to publication or mandatory disclosure in accordance with federal law.
Procedure for Collecting, Storing, Transmitting, and Other Types of Personal Data Processing
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 the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to exclude unauthorized access to personal data.
8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of applicable law or if the personal data subject has given consent to the Operator for transferring data to a third party for fulfilling obligations under a civil contract.
8.3. In cases of inaccuracies found in personal data, the User can update them independently by sending the Operator a notification to the Operator’s email address info@malpensa-it.com with the subject «Updating Personal Data.»
8.4. The duration of personal data processing is determined by the achievement of the goals for which the personal data was collected, unless another period is established by a contract or current legislation. The User can revoke their consent for personal data processing at any time by sending a notification to the Operator via email at info@malpensa-it.com with the subject «Revocation of Consent to Personal Data Processing.»
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the respective parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data is responsible for reviewing those documents. The Operator is not liable for the actions of third parties, including those mentioned in this clause.
8.6. Prohibitions established by the subject of personal data on the transfer (except for granting access) as well as on the processing or conditions of processing (except for accessing) of personal data approved for distribution are not applicable to the processing of personal data in state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures confidentiality.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than is necessary for the purposes of personal data processing unless the storage period is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The condition for ceasing personal data processing can be the achievement of the processing goals, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, or a request to cease personal data processing, as well as detection of unlawful personal data processing.
Actions Taken by the Operator with Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transmits (distributes, provides, gives access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated personal data processing with obtaining and/or transmitting the received information through information and telecommunications networks or without it.
Cross-Border Transfer of Personal Data
10.1. Before starting cross-border personal data transfer activities, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out cross-border transfers (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the appropriate information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
Confidentiality of Personal Data
The Operator and other individuals who have access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
Final Provisions
12.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@malpensa-it.com.
12.2. This document will reflect any changes to the personal data processing policy of the Operator. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://malpensa-it.com/privacy-policy/.