Privacy Policy
1. General Provisions
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 defines the procedure for processing personal data and measures to ensure the security of personal data taken by SECO (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.
1.2. This Operator’s policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://seco-team.com/.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at https://seco-team.com/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or another 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, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing, as well as determines the purposes of processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://seco-team.com/.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://seco-team.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in mass media, posting in 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 a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to: receive reliable information and/or documents containing personal data from the personal data subject; in case the personal data subject withdraws consent to the processing of personal data, as well as submits a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject 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 предусмотренных the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
- to provide the personal data subject, upon request, with information regarding the processing of their personal data;
- to organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- to respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- to provide the authorized body for the protection of the rights of personal data subjects, upon request, with the necessary information within 10 days from the date of receiving such request;
- to publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
- to take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
- to stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the cases and in the manner provided for by the Personal Data Law; to fulfill other obligations provided for by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right:
- to receive information regarding the processing of their personal data, except in cases предусмотренных federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except 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;
- to demand from the operator clarification of their personal data, their blocking or destruction in case the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures предусмотренные by law to protect their rights;
- to require prior consent when processing personal data for the purposes of promoting goods, works, and services on the market;
- to withdraw consent to the processing of personal data, as well as to submit a request to terminate the processing of personal data;
- to appeal unlawful actions or inaction of the Operator in the processing of their personal data to the authorized body for the protection of personal data subjects or in court;
- to exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
- to provide the Operator with reliable data about themselves;
- to inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not allowed.
5.3. It is not allowed to combine databases containing personal data processed for incompatible purposes.
5.4. Only personal data that meets the purposes of processing shall be processed.
5.5. The content and volume of processed personal data correspond to the stated purposes. Excessive personal data processing is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless otherwise provided by federal law or contract. Processed personal data shall be destroyed or anonymized upon achievement of processing purposes or when the need for their achievement ceases.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails
Personal data:
- full name
- email address
- phone numbers
Legal basis: Federal Law “On Information, Information Technologies and Information Protection” dated 27.07.2006 No. 149-FZ
Types of personal data processing: Transfer of personal data
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject.
7.2. Personal data processing is necessary to achieve purposes provided by international treaties or law, to perform functions, powers, and obligations assigned by Russian legislation to the Operator.
7.3. Personal data processing is necessary for the administration of justice and execution of judicial acts.
7.4. Personal data processing is necessary for the execution of a contract or its conclusion at the initiative of the personal data subject.
7.5. Personal data processing is necessary for the legitimate interests of the Operator or third parties.
7.6. Processing of publicly available personal data is carried out.
7.7. Processing of data subject to mandatory disclosure is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data is ensured through legal, organizational, and technical measures.
8.1. The Operator ensures the safety of personal data.
8.2. Personal data will not be transferred to third parties without legal grounds or consent.
8.3. The User may update data via email info@seco-team.com.
8.4. Processing continues until its purpose is achieved or consent is withdrawn.
8.5. Third-party services process data according to their own policies.
8.6. Restrictions do not apply in cases of public interest.
8.7. Confidentiality is ensured.
8.8. Data is stored only as long as necessary.
8.9. Processing ends upon achieving goals or withdrawal of consent.
9. Actions Performed with Personal Data
9.1. The Operator performs collection, storage, use, transfer, anonymization, and deletion of personal data.
9.2. Processing may be automated with or without network transmission.
10. Cross-Border Transfer of Personal Data
10.1. The Operator must notify authorities before cross-border transfer.
10.2. Required information must be obtained from foreign entities beforehand.
11. Confidentiality of Personal Data
Personal data must not be disclosed without consent unless required by law.
12. Final Provisions
12.1. Users may contact the Operator via info@seco-team.com.
12.2. Changes to this Policy will be reflected in this document.
12.3. The current version is available at https://seco-team.com/privacy-policy.