General Provisions
The present policy of personal data processing is made according to requirements of the Federal law from 27.07.2006. № 152-FZ "About personal data" (hereinafter - the Law on personal data) and defines the order of processing of personal data and measures on providing of safety of personal data, undertaken by Yuliya Yadreuskaya - Tabacu (hereinafter - the Operator).
1.1 The Operator's main goal and a condition for its activities is to observe the rights and freedoms of a person and a citizen during processing of their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2 This policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information which the Operator can obtain about the visitors of the https://up2uagency.com website.
2 Basic concepts used in the Policy
2.1 Automated processing of personal data - processing of personal data by means of computer technology.
2.2 Blocking of personal data - is temporary termination of processing of personal data (except when the processing is necessary to clarify personal data).
2.3 Website is an aggregate of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://up2uagency.com.
2.4 Personal data information system is a combination of personal data contained in databases of personal data and information technologies and technical means ensuring their processing.
2.5 Depersonalization of personal data - actions, as a result of which it is impossible to determine, without the use of additional information, the identity of personal data to a particular User or another subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data.
2.7 Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons, organizing and/or carrying out processing of personal data, as well as determining the purpose of processing of personal data, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8 Personal data - any information relating directly or indirectly to a particular or defined user of https://up2uagency.com website.
2.9 Personal data, authorized by the subject of personal data for distribution - personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, authorized for distribution).
2.10. User - any visitor to the https://up2uagency.com website.
2.11 Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize with personal data to an unlimited range of persons, including the publication of personal data in the media, placing in information and telecommunications 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, a foreign individual or a foreign legal entity.
2.14 Destruction of personal data - any action, as a result of which personal data is destroyed irretrievably with impossibility of further restoration of the content of personal data in the information system of personal data and or destroyed material media of personal data.
Basic rights and obligations of the Operator
3.1 The operator has the right:
- Receive from the subject of personal data reliable information and or documents containing personal data;
- In case of withdrawal by the subject of personal data of consent to processing personal data, as well as in case of sending a request for termination of personal data processing, the operator has the right to continue processing of personal data without the consent of the subject of personal data, if the grounds specified in the Law on Personal Data are provided;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2 The operator shall:
- provide the subject of personal data, at his/her request, with information relating to the processing of his/her personal data;
- Organize processing of personal data in the manner prescribed by applicable laws of the Russian Federation;
- to respond to requests and inquiries of personal data subjects and their and legal representatives in accordance with the requirements of the Law on Personal Data;
- To communicate to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 10 days from the date of receipt of such request
- Publish or otherwise ensure unrestricted access to this Policy on personal data processing;
- Take legal, organizational and technical measures to protect personal data from unauthorized 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, cease processing and destroy personal data in the manner and cases provided by the Personal Data Law
- Perform any other duties prescribed by the Personal Data Law.
4 The basic rights and obligations of subjects of personal data
4.1 The subjects of personal data have the right:
- To receive information relating to the processing of his personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, 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 is established by the Personal Data Law;
- To demand from the operator the clarification of his personal data, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take statutory measures to protect his rights;
- to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw the consent to the processing of personal data, as well as to request the termination of personal data processing
- To appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of his personal data
- To exercise other rights provided by the legislation of the Russian Federation.
4.2 Subjects of personal data shall:
- provide the Operator with reliable 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 subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Russian Federation.
5. Principles of personal data processing
5.1 Processing of personal data shall be lawful and fair.
5.2 Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purpose of collecting personal data shall not be permitted.
5.3 Databases containing personal data, which are processed for purposes incompatible with each other, shall not be combined
5.4 Only personal data that meet the purposes for which it is being processed may be processed.
5.5 The content and scope of processed personal data corresponds to the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.
5.6 When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, its relevance in relation to the purpose of personal data processing shall be ensured. The operator shall take the necessary measures and/or ensure that incomplete or inaccurate data is deleted or clarified.
5.7 Personal data shall be stored in a form that allows the identification of the subject of personal data, no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, a contract, a party to which, a beneficiary or a guarantor under which the subject of personal data is a party. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or in case of loss of necessity in achievement of these purposes, unless otherwise provided by the federal law.
6. Purposes of personal data processing
Purpose of processing Informing the User by sending emailsPersonal dataname, first name, middle name
e-mail address
telephone numbers
certificate of citizenship
Data on previously held positions and length of service, military service, military registration
Legal basis of the contracts concluded between the operator and the subject of personal data
Type of processing of personal dataCollection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
Sending informative letters to the e-mail address
7. Terms of processing of personal data
7.1 Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2 Processing of personal data is necessary for achievement of the purposes provided by the international treaty of the Russian Federation or law, for implementation of the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
7.3 Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4 Processing of personal data is necessary for execution of the contract, a party to which or a beneficiary or guarantor under which the subject of personal data is the subject of personal data, as well as for conclusion of the contract on the initiative of the subject of personal data or contract, under which the subject of personal data will be a beneficiary or guarantor.
7.5 The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially important goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6 Personal data shall be processed if access to such data is granted to an unlimited number of persons by or at the request of the personal data subject (hereinafter, "publicly available personal data").
7.7 Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for collecting, storing, transferring and other processing of personal data
The safety of personal data, which are processed by the Operator, is ensured by implementing legal, organizational and technical measures, necessary for fulfilling in full the requirements of the current legislation in the field of personal data protection.
8.1 The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2 The User's personal data will never, under any circumstances, be transmitted to third parties, except in cases related to the execution of the current legislation or if the subject of the personal data has given his consent to the Operator for the transfer of data to a third party for the performance of obligations under a civil law contract.
8.3 In case of detection of inaccuracies in the personal data, the User can update them independently, by sending a notice to the Operator's e-mail address up2u.esl@gmail.com with the note "Updating of personal data".
8.4 The term of personal data processing is determined by achieving the purposes for which the personal data were collected, unless a different term is stipulated by the contract or the legislation in force.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via e-mail to the Operator's e-mail address up2u.esl@gmail.com with the note "Withdrawal of consent to the processing of personal data".
8.5 All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the mentioned persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or the said documents. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.
8.6 The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or processing conditions (other than gaining access) of personal data permitted for distribution, shall not apply in cases of processing of personal data in state, public and other public interests as defined by Russian legislation.
8.7. The Operator shall ensure the confidentiality of personal data when processing personal data.
8.8 The operator shall store personal data in a form that allows to identify the subject of the personal data, no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, a contract, a party to which, a beneficiary or a guarantor under which the subject of the personal data is a party.
8.9 A condition for termination of personal data processing may be the achievement of the personal data processing objectives, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or a requirement to terminate personal data processing, as well as the detection of unlawful processing of personal data.
9. List of actions performed by the operator with personal data received
9.1 The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
9.2 The operator carries out automated processing of personal data with or without obtaining and/or transmitting the received information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1 The operator is obliged to notify the competent authority for personal data protection of its intention to transfer personal data across borders (such notification is sent separately from the notification of the intention to process personal data) before starting the transborder transfer of personal data.
10.2 Prior to submitting the above notification, the operator must obtain the relevant information from the foreign authorities, foreign individuals, foreign legal entities to which the trans-border transfer of personal data is planned.
11. Confidentiality of personal data
The operator and other persons who obtained access to personal data must not disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final provisions
12.1 The User can get any clarifications on the questions of interest concerning the processing of his personal data by contacting the Operator by e-mail at up2u.esl@gmail.com.
12.2 This document will reflect any changes in the personal data processing policy of the Operator. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://up2uagency.com/privacypolicy.
