Personal Data Policy
1.1 The purpose of LLC “RESEARCHVIEW-M” (hereinafter referred to as “Company”) Personal Data Policy (hereinafter referred to as “Policy”) is to comply with the requirements of the Law of the Russian Federation related to personal data processing and protection against unauthorized access, wrongful use or loss and observing the legal rights of personal data subjects.
1.2 This Policy provides basic information on personal data processing, including:
- principles and procedures for personal data processing;
- purposes of personal data processing;
- grounds for personal data processing and storage;
- conditions of personal data transfer to third parties;
- information on organization of access to personal data;
- measures to observe the rights of personal data subjects;
- measures to provide personal data protection;
- consent to personal data processing.
1.3 This Policy is developed based on the requirements of the Law of the Russian Federation related to personal data processing and protection.
2. Terms, definitions and abbreviations
2.1 The following terms and definitions are used in this Policy:
- Personal data (“PD”) - any information related to directly or indirectly specified natural person (“PD subject”);
- Operator - state authority, municipal authority, legal or private person, who severally or jointly arranges and/or performs personal data processing, as well as defines the aims of personal data processing, the volume of personal data subject to processing and personal data handling;
- Personal data processing - any action or a series of actions performed towards personal data with or without the software, including the personal data acquisition, recording, systematization, accumulation, storage, update and alteration, extraction, use, transfer (distribution, presentation, providing access), depersonalization, blocking, deleting and annihilation;
- Automated personal data processing - personal data processing via PC software;
- Information system of personal data - a set of personal data included into personal data databases, as well as the software and tools used for their processing;
- Confidentiality of information – mandatory requirement for the person who has access to certain information not to transfer such information to third parties without consent of the PD subject.
3. Principles and procedures for personal data processing
3.1 Personal data processing is based on the following principles:
- provision of the legitimacy of purposes and methods of PD processing;
- compliance of the purposes of PD processing with the predetermined and stated purposes of PD acquisition;
- compliance of the amount and content of PD as well as methods of PD processing with the purposes of PD processing;
- no PD redundancy in relation to the stated purposes;
- provision of adequacy of PD;
- use of separate databases for PD processing for the incompatible purposes.
3.2 PD subjects’ PD processing in the Company is automated.
3.3 PD processing in the Company is performed in accordance with the Federal Law No. 152-FZ ‘On Personal Data’, dated July 27, 2006 and other current statutory acts related to personal data processing and protection.
4. Purposes for personal data processing
4.1 The Company processes personal data for the purpose of:
- organization of participation of the PD subjects in marketing research;
- providing feedback to the Customers of marketing research;
- conducting market research;
- verification of information provided by the PD subjects.
5. Grounds for personal data processing and storage
5.1 The Company processes and stores personal data under the PD subject’s consent to personal data processing.
5.2 The Company processes and stores personal data under the agreement being entered into with the Customers of market research.
6. Personal data transfer to third parties
6.1 Personal data is transferred to third parties with consent of the PD subject.
7. Organization of access to personal data
7.1 Personal data protection in the Company provides the limitation of access to them.
7.2 Access to personal data is only allowed to specially authorized employees of the Company's subdivisions. These persons have the right to process only those personal data that are necessary for the performance of their official duties, and for the purposes for which they are provided.
7.3 Access of representatives of state bodies to PD is regulated by the current Law of the Russian Federation.
8. Observing the rights of personal data subjects
8.1 The PD subjects are entitled for adjusting their personal data, as well as data blocking or annihilation in case of personal data are incomplete, outdated, inaccurate, illegally obtained or inessential for processing purpose declared, as well as taking statutory actions to protect their rights.
8.2 In case of notification in the prescribed form of the PD subjects the Company:
- identifies the PD subjects;
- establishes the fact of the PD subjects’ PD processing;
- provides to the PD subjects completing information on their personal data under processing in the Company;
- performs PD adjusting, blocking or annihilation under request of the PD subjects if they provide information confirming that processed personal data are incomplete, outdated, inaccurate, illegally obtained or inessential for processing purpose declared, as well as the data processed with violation of the requirements of the Law of the Russian Federation;
- notifies all persons who has been previously informed of incorrect or incomplete personal data of the PD subjects on all exceptions, corrections or additions made;
- notifies the PD subjects on the results of the actions requested in the manner and time limits stipulated by the Law of the Russian Federation.
9. Measures of personal data protection
9.1 The Company ensures the personal data confidentiality while processing.
9.2 The Company has implemented measures in accordance with the Articles 18.1 and 19 of the Federal Law No. 152-FZ ‘On Personal Data’, dated July 27, 2006, as well as measures to provide personal data protection in accordance with the requirements to the personal data protection established by The Russian Federation Government:
9.2.1 A person responsible for organization of personal data processing is appointed;
9.2.2 A person responsible for providing personal data protection is appointed;
9.2.3 Local regulating documents on the matters of personal data processing and protection are developed and approved;
9.2.4 A list of persons for whom access to personal data is necessary for the performance of their official duties is approved;
9.2.5 The employees of the Company who are directly involved in personal data processing are familiarized with the provisions of the Law of the Russian Federation including the requirements to the personal data protection, this Policy and local regulating documents on the matters of personal data processing and protection;
9.2.6 This Policy is published;
9.2.7 In-house control over the compliance of personal data processing with the Federal Law ‘On Personal Data’ and relevant statutory acts is being exercised;
9.2.8 Technical measures to provide personal data protection at processing thereof within the information systems of personal data are being taken;
9.2.9 The rules of providing protection of the personal data processed with usage of physical data media are defined;
9.2.10 The mode of physical security of premises where the information systems of personal data are located preventing uncontrolled penetration or staying in these premises of persons who do not have the right to access these premises is organized.
9.2.11 Other measures provided by the current Law of the Russian Federation.
10. Consent to personal data processing
10.1 In accordance with the Article 12 of the Federal Law No. 152-FZ ‘On Personal Data’, dated July 27, 2006 by providing data for participation in the research of LLC “RESEARCHVIEW-M”, acting of my own free will and in my interest I make a decision to provide my personal data and give consent to their processing for the purposes of conducting market research;
10.2 Name and address of the operator receiving the consent of the PD subject: LLC “RESEARCHVIEW-M”, 115162, Moscow, Khavskaya 18 bld.2;
10.3 This consent is given for the following personal data: surname, first name and patronymic, position, name of the employer, telephone number, e-mail address, residential address, and any other information relating to my identity.
10.4 The list of actions with personal data for which consent is given, a general description of the methods of processing used by the operator: the above personal data will be processed by combined personal data processing, including personal data collection, systematization, accumulation, storage, clarification, updating, modification, use, distribution, transfer to third parties, trans-border transfer outside the Russian Federation, depersonalization, blocking, deleting and annihilation.
10.5 Validity term of the consent of the PD subject and procedure for the consent revocation in case the other is not set by a federal law: This consent is in force from the moment of its signing for an indefinite period and terminates only on my written application (revocation) in accordance with the Articles 9 and 12 of the Federal Law No. 152-FZ ‘On Personal Data’, dated July 27, 2006.