Privacy policy

Personal data processing policy

1. General Provisions

This personal data protection policy (hereinafter referred to as the Privacy Policy) is developed under the Federal Law of the Russian Federation of 27 July 2006 No.152-FZ ‘On Personal Data’ (hereinafter referred to as Personal Data Law) and defines the personal data processing procedure and measures to ensure security of personal data taken by ORION IMPEX, LLC (hereinafter referred to as the Operator).

1.1. The Operator’s most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens while processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s personal data processing policy (hereinafter referred to as the Policy) applies to all the information that the Operator may receive about visitors of https://imbricsforum.com.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data means processing of personal data by means of computer technology.

2.2. Blocking of personal data means temporary termination of processing of personal data (unless processing is necessary to clarify personal data).

2.3. Website means a set of graphic and information materials, as well as computer programmes and databases, ensuring their availability on the Internet at https://imbricsforum.com network address.

2.4. Personal data information system is an aggregate of personal data contained in databases, and information technologies and technical means, ensuring processing of personal data.

2.5. De-identification of personal data means actions, because of which it is impossible to determine, without using additional information, the attribution of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction of personal data.

2.7. The Operator means a state body, municipal authority, legal entity or individual, independently or together with legal entities or individuals, arranging and (or) carrying out processing of personal data, as well as determining the purpose of personal data processing, composition of personal data to be processed, actions (operations) performed with personal data.

2.8 Personal data means any information relating directly or indirectly to a particular or defined User of the website https://imbricsforum.com.

2.9. Personal data, allowed by the User for distribution, means personal data, access to which is provided by the User through consent to the processing of personal data, allowed by the User for distribution in the manner prescribed by Personal Data Law (hereinafter referred to as Personal Data Allowed for Distribution).

2.10. The User means any visitor to https://imbricsforum.com.

2.11. Provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

2.12. Distribution of personal data means any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarise an unlimited number of persons with personal data, including publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data means any action, as a result of which personal data is destroyed irretrievably with no possibility to further restore the contents of personal data in the information system of personal data, and (or) material media of personal data are destroyed.

3. Rights and Obligations of the Operator

3.1. The Operator shall have the right to:

– obtain reliable information and/or documents containing personal data from the User;

– in case the User withdraws their consent to the processing of personal data, the Operator has the right to continue the processing of personal data without the consent of the User on the grounds set out in the Personal Data Law;

– independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided for by the Personal Data Law and the regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator shall:

– provide the User, at their request, with information relating to the processing of their personal data;

– organise the processing of personal data in the manner prescribed by applicable laws of the Russian Federation;

– respond to requests and enquiries of the Users and their legal representatives, under the Personal Data Law;

– provide the authority responsible for protecting the rights of the User, at the request of the authority, with the necessary information within 30 days from the date of receipt of such 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 unauthorised or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful acts in relation to personal data;

– cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;

– perform other duties provided for by the Personal Data Law.

4. Rights of the User

4.1. The User shall have the right to:

– receive information relating to the processing of their personal data, except in the cases provided for by federal laws. The information is provided to the User by the Operator in an accessible form and must not contain personal data relating to other Users, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are set out in the Personal Data Law;

– require the Operator to clarify the personal data, to block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and to take statutory measures to protect the rights;

– set a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;

– withdraw the consent to the processing of personal data;

– appeal to the authorised body for the protection of the rights of Users or in court against unlawful acts or omissions of the Operator in the processing of his personal data;

– exercise other rights provided by the legislations of the Russian Federation.

4.2. The User shall:

– provide the Operator with accurate data about themselves;

– inform the Operator of the clarification (updating, modification) of their personal data.

4.3. Persons who provided the Operator with inaccurate information about themselves, or information about another User without the consent of the latter, shall be liable under the laws of the Russian Federation.

5. The Operator may process the following personal data of the User:

5.1. Last name, first name, middle name.

5.2. E-mail address.

5.3. Phone numbers.

5.4. The site also collects and processes visitors’ anonymised data (including cookies) using Internet statistics services (Yandex Metrika, Google Analytics, etc.).

5.5. In this Policy, the above-mentioned data is hereinafter referred to as Personal Data.

5.6. The Operator shall not process any special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.

5.7. Processing of personal data, allowed for dissemination from the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law, is allowed, if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are observed.

5.8. The User’s consent to the processing of personal data authorised for dissemination shall be formalised separately from other consents to the processing of their personal data. The conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be complied with. The requirements for the content of such consent shall be established by the competent authority for protecting the rights of the Users.

5.8.1. The consent for the processing of personal data allowed for distribution shall be given by the User directly to the Operator.

5.8.2. The Operator is obliged to publish information about the conditions of processing, prohibitions and conditions for the processing of personal data allowed for distribution to an unlimited number of persons within three business days from the receipt of the above consent of the User.

5.8.3. The transfer (dissemination, provision, access) of personal data, authorised by the User for dissemination, must be stopped at any time at the request of the User. This request must include the last name, first name, patronymic/middle name (if any), contact information (telephone number, e-mail address or postal address) of the User, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is sent.

5.8.4. Consent to the processing of personal data authorised for dissemination shall cease upon receipt by the Operator of the request referred to in clause 5.8.3 of this Policy for the processing of personal data.

6. Principles of Personal Data Processing

6.1. Processing of personal data shall be lawful and fair.

6.2. Processing of personal data shall be limited to achieving specific, predetermined, and legitimate objectives. No processing of personal data which is incompatible with the purposes for which the personal data is collected shall be permitted.

6.3. Databases containing personal data that are processed for purposes that are incompatible with each other shall not be merged.

6.4. Only personal data that meets the purposes for which it is being processed shall be processed.

6.5. The content and scope of personal data processed shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.

6.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance in relation to the purpose of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to remove or clarify incomplete or inaccurate data.

6.7. Personal data shall be stored in a form that allows identification of the User for no longer than the purposes of personal data processing require, unless the storage period of personal data is established by federal law, an agreement to which the User is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalised upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.

7. Purposes of Personal Data Processing

7.1. Purposes of processing of personal data of the User:

– informing the User by sending emails;

– conclusion, performance and termination of civil law contracts;

– giving the User access to services, information and/or materials contained on the https://imbricsforum.com website.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers and different events. The User can always refuse receiving information messages by sending an email to the Operator at info@imbricsforum.com with the note “Unsubscribe from notifications about new products and services and special offers”.

7.3. The anonymised User data collected by means of Internet statistics services are used to collect information about the User's activities on the website and to improve the quality of the website and its contents.

8. Legal Basis for the Processing of Personal Data

8.1. The legal basis for the processing of personal data by the Operator are:

– List the laws and regulations governing relations related to your activities, for example, if your activity involves information technology, in particular the creation of sites, you can specify here the Federal Law "On Information, Information Technology and Information Protection" of July 27, 2006, No. 149-FL;

– the Operator's bylaws;

– contracts between the Operator and the User;

– federal laws, other laws and regulations in the sphere of personal data protection;

–  consent of the Users for the processing of their personal data, for the processing of personal data allowed for dissemination.

8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User himself via special forms located on the website https://imbricsforum.com or sent to the Operator by e-mail. By completing the relevant forms and/or sending his personal data to the Operator, the User expresses his consent to this Policy.

8.3. The Operator processes anonymised data about the User, if this is allowed in the User's browser settings (cookie saving and the use of JavaScript technology are enabled).

8.4. The User decides independently on the provision of his personal data and gives consent freely, willingly and in his own interest.

9. Conditions for the Processing of Personal Data

9.1. Processing of personal data shall be subject to the consent of the User to the processing of their personal data.

9.2. Processing of personal data is necessary for achievement of the objectives envisaged by an international treaty of the Russian Federation or by law, for performance of the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.

9.3. Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which the User is a party, as well as for conclusion of an agreement on the initiative of the User or an agreement, under which the User will be a beneficiary or guarantor.

9.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially important objectives, provided that the rights and freedoms of the User are not thereby violated.

9.6. Processing of personal data, to which access has been granted by or at the request of the User (hereinafter reffered to as Publicly Available Personal Data").

9.7. Processing of the User to publication or compulsory disclosure in accordance with federal law.

10. Procedure for 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 to comply fully with the requirements of current legislation in the area of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures, which exclude access to personal data by unauthorised persons.

10.2. The personal data of the User will never, under no circumstances be transferred to third parties, except in cases related to the execution of the current legislation, or if the User has given their consent to the Operator for the transfer of data to a third party to fulfil their obligations under a civil law contract.

10.3. In case of identification of inaccuracies in the personal data, the User may update the personal data themselves by sending a notification to the Operator's email address info@imbricsforum.com, marked "Update of personal data".

10.4. The time period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different time period is stipulated by contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator's email address info@imbricsforum.com with the note "Withdrawal of consent to the processing of personal data".

10.5. All information that is collected by third party services, including payment systems, means of communication and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The User and/or the User is obliged to acquaint themselves with the said documents in due time. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.

10.6. The prohibitions established by the User on the transfer (other than granting access) as well as on the processing or processing conditions (other than gaining access) of personal data allowed for distribution shall not apply in cases of processing of personal data in state, public and other public interests as defined by Russian legislation.

10.7. The Operator shall ensure the confidentiality of personal data when processing personal data.

10.8. The Operator shall store personal data in a form that allows the User to be identified, for no longer than is required by the purposes of personal data processing, unless the period of storage of personal data is set by federal law, an agreement to which the User is a party, a beneficiary or a guarantor under which the User is a beneficiary.

10.9. A condition for the termination of personal data processing may be the achievement of the personal data processing objectives, expiration of the User's consent or withdrawal of consent by the User, as well as identification of unlawful processing of personal data.

11. List of actions carried out by the Operator with the personal data received

11.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (dissemination, provision, access), anonymises, blocks, deletes, and destroys personal data.

11.2. The Operator shall carry out automated processing of personal data with or without the receipt and/or transmission of received information via information and telecommunications networks.

12. Cross-border Transfer of Personal Data

12.1. The Operator is obliged to make sure that the foreign country, on the territory of which the personal data transfer is supposed to be carried out, provides reliable protection of the Users' rights before the start of the cross-border transfer of personal data.

12.2. The cross-border transfer of personal data to foreign countries, which do not comply with the above requirements, may take place only if the User consents in writing to the cross-border transfer of his/her personal data and/or to the performance of the contract, to which the User is a party.

13. Confidentiality of Personal Data

The Operator and other persons who obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without consent of the User, unless otherwise provided for by federal law.

14. Final Provisions

14.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator by email at info@imbricsforum.com.

14.2. 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.

14.3. The current version of the Policy is in free access at https://en.imbricsforum.com/privacy-policy/