Privacy Policy on Personal Data Processing
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by LLC “Uralsky Lider Plyus” (hereinafter — the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrecy, as a fundamental goal and condition of its activities.
1.2. This Policy of the Operator regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://theuralleader.com/.
2. Main Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking personal data — temporary suspension of personal data processing (except in cases where processing is required to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as software and databases that ensure access to them on the Internet at https://theuralleader.com/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine personal data belonging to a specific User without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person that independently or jointly with others organizes and/or carries out personal data processing and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable visitor to the website https://theuralleader.com/.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which unrestricted access is provided by the personal data subject by giving consent for personal data processing in accordance with the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://theuralleader.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unlimited number of persons (transfer of personal data) or at making personal data publicly accessible, including placing them in mass media, on telecommunications networks, or providing access to personal data in any other manner.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state body, a foreign natural or foreign legal person.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data and/or physical media so that further restoration of the content of personal data in the personal data information system is impossible.
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;
– continue processing personal data without the consent of the personal data subject in case of withdrawal of consent, if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, 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 concerning the processing of their personal data;
– organize the processing of personal data in accordance with the procedure established by current legislation of the Russian Federation;
– respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– notify the authorized body for the protection of the rights of personal data subjects, at the request of that body, of the necessary information within 10 days from the date of receipt of such request;
– publish or otherwise ensure unrestricted access to this Personal Data Processing Policy.
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 provided for by federal laws;
– demand clarification, blocking, or destruction of their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing;
– require prior consent for the processing of personal data for the purpose of promoting goods, works, or services on the market;
– withdraw consent to the processing of personal data;
– appeal against unlawful actions or inaction of the Operator in the authorized body for the protection of the rights of personal data subjects or in court.
4.2. Personal data subjects are obliged to:
– provide the Operator with accurate personal data about themselves;
– notify the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the consent of the latter 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 the achievement of specific, predetermined, and lawful purposes.
5.3. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.
5.6. When processing personal data, accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of Processing
informing the User by sending e-mails
Personal Data
• last name, first name, patronymic
• e-mail address
• phone numbers
Legal Grounds
• statutory (founding) documents of the Operator
• agreements concluded between the Operator and the personal data subject
Types of Personal Data Processing
• collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
• sending informational e-mails to the e-mail address
7. Conditions for Personal Data Processing7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, an act of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data is carried out, access to which is granted to an unlimited number of persons by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure is carried out in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with 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 prevent access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In the event that inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator to the Operator’s e-mail address lider.ural174@ya.ru with the subject line “Updating personal data”.
8.4. 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 a contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator’s e-mail address lider.ural174@ya.ru with the subject line “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject agrees to this and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of personal data processing in state, public, or other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. A condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, a requirement to terminate personal data processing, as well as the detection of unlawful personal data processing.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the obtained information via information and telecommunications networks or without using such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above notification, the Operator is obliged to obtain from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via e-mail at lider.ural174@ya.ru.
12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://theuralleader.com/privacy.
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by LLC “Uralsky Lider Plyus” (hereinafter — the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrecy, as a fundamental goal and condition of its activities.
1.2. This Policy of the Operator regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://theuralleader.com/.
2. Main Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking personal data — temporary suspension of personal data processing (except in cases where processing is required to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as software and databases that ensure access to them on the Internet at https://theuralleader.com/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine personal data belonging to a specific User without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person that independently or jointly with others organizes and/or carries out personal data processing and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable visitor to the website https://theuralleader.com/.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which unrestricted access is provided by the personal data subject by giving consent for personal data processing in accordance with the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://theuralleader.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unlimited number of persons (transfer of personal data) or at making personal data publicly accessible, including placing them in mass media, on telecommunications networks, or providing access to personal data in any other manner.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state body, a foreign natural or foreign legal person.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data and/or physical media so that further restoration of the content of personal data in the personal data information system is impossible.
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;
– continue processing personal data without the consent of the personal data subject in case of withdrawal of consent, if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, 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 concerning the processing of their personal data;
– organize the processing of personal data in accordance with the procedure established by current legislation of the Russian Federation;
– respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– notify the authorized body for the protection of the rights of personal data subjects, at the request of that body, of the necessary information within 10 days from the date of receipt of such request;
– publish or otherwise ensure unrestricted access to this Personal Data Processing Policy.
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 provided for by federal laws;
– demand clarification, blocking, or destruction of their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing;
– require prior consent for the processing of personal data for the purpose of promoting goods, works, or services on the market;
– withdraw consent to the processing of personal data;
– appeal against unlawful actions or inaction of the Operator in the authorized body for the protection of the rights of personal data subjects or in court.
4.2. Personal data subjects are obliged to:
– provide the Operator with accurate personal data about themselves;
– notify the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the consent of the latter 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 the achievement of specific, predetermined, and lawful purposes.
5.3. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.
5.6. When processing personal data, accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of Processing
informing the User by sending e-mails
Personal Data
• last name, first name, patronymic
• e-mail address
• phone numbers
Legal Grounds
• statutory (founding) documents of the Operator
• agreements concluded between the Operator and the personal data subject
Types of Personal Data Processing
• collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
• sending informational e-mails to the e-mail address
7. Conditions for Personal Data Processing7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, an act of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data is carried out, access to which is granted to an unlimited number of persons by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure is carried out in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with 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 prevent access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In the event that inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator to the Operator’s e-mail address lider.ural174@ya.ru with the subject line “Updating personal data”.
8.4. 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 a contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator’s e-mail address lider.ural174@ya.ru with the subject line “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject agrees to this and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of personal data processing in state, public, or other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. A condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, a requirement to terminate personal data processing, as well as the detection of unlawful personal data processing.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the obtained information via information and telecommunications networks or without using such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above notification, the Operator is obliged to obtain from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via e-mail at lider.ural174@ya.ru.
12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://theuralleader.com/privacy.