This English translation is provided for convenience only. In case of any discrepancy, the Russian version prevails.
1. General provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” of July 27, 2006 (the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken by FLIP Joint Stock Company (FLIP JSC) (the “Operator”) to ensure the security of personal data.
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 when processing their personal data, including the protection of the rights to privacy and to personal and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (the “Policy”) applies to all information that the Operator may obtain about visitors to the website ().
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 the processing is necessary to clarify the personal data).
2.3. Website means a set of graphic and information materials, as well as computer programs and databases, that make them available on the internet at the network address ().
2.4. Personal data information system means the personal data contained in databases together with the information technologies and technical means used to process them.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belong to a specific User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator means a state body, municipal body, legal entity or individual that, alone or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of the processing, the personal data to be processed and the actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website ().
2.9. Personal data authorized by the personal data subject for dissemination means personal data to which the personal data subject has given access to an unlimited number of persons by consenting to the processing of personal data authorized for dissemination in the manner prescribed by the Personal Data Law (“personal data authorized for dissemination”).
2.10. User means any visitor to the website ().
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. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the mass media, posting them in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign government authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions that irreversibly destroy personal data, making it impossible to restore their content in the personal data information system, and/or that destroy the tangible media of personal data.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
4.2. Personal data subjects are obliged to:
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the laws of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data are processed on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of their collection is not permitted.
5.3. Combining databases containing personal data that are processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of their processing.
5.6. When personal data are processed, their accuracy, sufficiency and, where necessary, relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that makes it possible to identify the personal data subject for no longer than the purposes of processing require, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Where permitted by the applicable laws of the Russian Federation, the personal data processed are destroyed or depersonalized once the purposes of processing have been achieved or if the need to achieve these purposes no longer exists, unless otherwise provided by federal law.
6. Purposes of personal data processing
6.1 The User’s acceptance of the terms of this Agreement is regarded by the Administrator as specific, informed and conscious consent given by the User (personal data subject) to the processing of their personal data, including authentication data and data contained in cookies.
6.2 The Administrator assumes in good faith that the registration procedure is carried out by the User personally or by their legal representative. The Administrator does not undertake any obligation to verify the data provided by the User.
6.3 Since the Administrator does not carry out identity verification, it is not liable for any damage caused to other Users or third parties as a result of inaccurate information being provided.
6.4 The rules for processing personal data are set out in this Agreement and in the Privacy Policy published by the Administrator at ().
6.5 The Administrator is not responsible for any possible misuse of Users’ personal data resulting from:
1) technical failures in software, servers or computer networks beyond the Administrator’s control;
2) interruptions in the operation of the Site, including those related to intentional or unintentional misuse of the Site by third parties.
7. Rights of the Administrator
| Purpose of processing |
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| Categories of personal data subjects | |
| Personal data |
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| Legal grounds |
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| Types of personal data processing | collection, storage, recording, transfer, accumulation, deletion; |
| Description of the measures provided for by Articles 18.1 and 19 of the Personal Data Law |
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| Security tools |
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| Security information | In accordance with Decree of the Government of the Russian Federation No. 1119 of November 1, 2012 “On Approval of the Requirements for the Protection of Personal Data During Their Processing in Personal Data Information Systems”, the following has been done to ensure the 3rd level of protection of personal data processed in the information system:
In accordance with Decree of the Government of the Russian Federation No. 687 of September 15, 2008 “On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out Without the Use of Automation Tools”, persons who process personal data without the use of automation tools have been informed of the specifics and rules of such processing, and local regulations establish the places where personal data are stored and the list of persons who process personal data. |
| Security information | used within the limits permitted by the applicable laws of the Russian Federation. |
8. Conditions for processing personal data
8.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
8.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by the laws of the Russian Federation, to perform the functions, powers and duties imposed on the Operator by the laws of the Russian Federation, as well as for the purposes set out in this Policy that do not contradict the applicable laws of the Russian Federation.
8.3. The processing of personal data is also necessary for the administration of justice and for the enforcement of a judicial act or an act of another body or official that is subject to enforcement in accordance with the laws of the Russian Federation on enforcement proceedings.
8.4. Where permitted by the applicable laws of the Russian Federation, the processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
8.5. Where permitted by the applicable laws of the Russian Federation, the 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 this does not violate the rights and freedoms of the personal data subject or the applicable laws of the Russian Federation.
8.6. Where permitted by the applicable laws of the Russian Federation, personal data to which the personal data subject has given access to an unlimited number of persons, or which are made available at their request (“publicly available personal data”), are processed. The places where personal data are stored and the list of persons who process personal data have been established. Cryptographic protection of personal data is used within the limits permitted by the applicable laws of the Russian Federation.
8.7. Where permitted by the applicable laws of the Russian Federation, personal data that are subject to publication or mandatory disclosure in accordance with federal law are processed.
9. Procedure for the collection, storage, transfer and other types of personal data processing
The security of the personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with the requirements of the applicable laws on the protection of personal data.
9.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
9.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable laws or where the personal data subject has consented to the Operator transferring the data to a third party to fulfill obligations under a civil law contract.
9.3. If inaccuracies are found in the personal data, the User can update them on their own by sending a notice to the Operator’s email address support@flip-chart.ru marked “Updating personal data”.
9.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by an agreement or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to support@flip-chart.ru marked “Withdrawal of consent to the processing of personal data”.
9.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (operators) in accordance with their user agreements and privacy policies. The personal data subject and/or the User must review these documents on their own in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
9.6. Prohibitions set by the personal data subject on the transfer (other than providing access) and on the processing or conditions of processing (other than obtaining access) of personal data authorized for dissemination do not apply where personal data are processed in state, public and other public interests defined by the laws of the Russian Federation.
9.7. When processing personal data, the Operator ensures their confidentiality.
9.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than the purposes of processing require, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
9.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to stop processing personal data, termination of the Operator’s activities, or detection of unlawful processing of personal data.
10. Actions performed by the Operator with the personal data obtained
10.1. The Operator collects, stores, records, transfers, accumulates and deletes personal data.
10.2. The Operator carries out automated processing of personal data, with or without receiving and/or transferring the information obtained over information and telecommunication networks (both internal networks and the internet).
11. Cross-border transfer of personal data
11.1. Before starting any cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data (such notice is sent separately from the notice of the intention to process personal data).
11.2. Before submitting the above notice, the Operator must obtain the relevant information from the foreign government authorities, foreign individuals and foreign legal entities to which the cross-border transfer of personal data is planned.
11.3. As of the publication of this Policy, the Operator does not carry out cross-border transfers of personal data.
12. Confidentiality of personal data
12.1. The Operator and other persons who have gained access to personal data must not disclose personal data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.
13. Final provisions
13.1. The User can obtain any clarification on matters regarding the processing of their personal data by contacting the Operator by email at support@flip-chart.ru.
13.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
13.3. The current version of the Policy is freely available on the internet at ().
13.4. Matters not covered by this Policy are resolved in accordance with the applicable laws of the Russian Federation.