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Policy regarding the processing of personal data

1. General provisions

This policy of processing personal data is drawn up in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ ‘On Personal Data’ (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Marina Zinland (hereinafter referred to as the Operator).

1.1. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen in the processing of his personal data, including protecting the rights to privacy, personal and family secrets.

1.2. This operator’s personal data processing policy (hereinafter referred to as the Policy) applies to all information that the operator can get about visits to the website https://marinazinland.com.

2. Basic concepts used in politics

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data is a temporary termination of the processing of personal data (with the exception of cases, if processing is necessary to clarify personal data).

2.3. The website is a set of graphics and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://marinazinland.com.

2.4. Information system of personal data – a set of personal data contained in the databases and ensuring their processing of information technology and technical means.

2.5. Depersonalization of personal data – actions, as a result of which it is impossible to determine without the use of additional information the affiliation of personal data to a specific user or other subject of personal data.

2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with the use of automation tools or without the use of such funds with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, granting, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. The operator is a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and / or processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, Actions (operations) performed with personal data.

2.8. Personal data – any information related directly or indirectly to a specific or defined user of the website https://marinazinland.com.

2.9. Personal data permitted by the subject of personal data for distribution – personal data, access of an unlimited circle of persons to which the subject of personal data is provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner provided Personal data law (hereinafter referred to as personal data allowed for distribution).

2.10. User – any visitor to the website https://marinazinland.com.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a certain circle of persons.

2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or to familiarize with personal data of an unlimited circle of persons, including the publication of personal data in mass media information, placement in information and telecommunication networks or granting access to personal data in any other way.

2.13. Transboundary transfer of personal data – the transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or foreign legal entity.

2.14. Destruction of personal data – any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and / or destroyed material carriers of personal data.

3. Basic rights and obligations of the operator

3.1. The operator has the right:

– receive reliable information and / or documents containing personal data from the subject of personal data;

– in the event of the withdrawal of consent to the processing of personal data, as well as the direction of applying for the termination of the processing of personal data, the operator has the right to continue the processing of personal data without the consent of the personal data subject at the presence of the grounds specified in the Law on Personal Data;

– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by law About personal data or other federal laws.

3.2. The operator must:

– provide the subject of personal data at his request with information regarding the processing of his personal data;

– organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;

– respond to requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

– report 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 a request;

– publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;

– take legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, change, blocking, copying, providing, disseminating personal data, as well as from other illegal actions in relation to personal data;

– stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;

– perform other duties provided for by the Personal Data Law.

– in case of establishing the fact of unlawful accidental transfer (provision, distribution, access) of personal data that resulted in violation of the rights of users, within 24 hours from the moment such an incident was detected, notify the authorized body of the incident, as well as to accept Within the time limits established by law, other measures in connection with the identified incident.

4. Fundamental rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right to:

– receive information regarding the processing of his personal data, with the exception of cases provided for by federal laws. Information is provided to the subject of personal data by the operator in an accessible form, and they should not contain personal data related to other subjects of personal data, except for cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;

– require the operator to clarify his personal data, block them or destroy them in the event that personal data is incomplete, obsolete, inaccurate, illegally received or are not necessary for the stated purpose of processing; and also take the measures provided for by law to protect their rights;

– put forward a condition of preliminary consent when processing personal data in order to promote goods, works and services in the market;

– to recall consent to the processing of personal data, as well as to the direction of a requirement to terminate the processing of personal data;

– appeal to the authorized body for the protection of the rights of personal data subjects or in court illegal actions or inaction of the operator when processing his personal data;

– to exercise other rights provided for by the legislation of the Russian Federation.

4.2. The subjects of personal data are obliged to:

– provide the operator with reliable data about itself;

– inform the operator about the clarification (updating, changing) of their personal data.

4.3. Persons who transferred unreliable information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. The processing of personal data is carried out on a legal and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate goals. The processing of personal data is not allowed, incompatible with the purposes of collecting personal data.

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

5.4. Only personal data is subject to processing that meet the purposes of their processing.

5.5. The content and volume of the processed personal data correspond to the declared purposes of processing. The redundancy of the processed personal data is not allowed in relation to the stated goals of their processing.

5.6. When processing personal data, the accuracy of personal data is ensured, their sufficiency, and in necessary cases, and relevance in relation to the purposes of processing personal data. The operator takes the necessary measures and / or ensures their adoption by removing or clarifying incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows you to determine the subject of personal data not longer than the purpose of the processing of personal data required, if the period of storage of personal data is not established by the federal law, the contract, the party of which, the beneficiary or guarantor, for which the subject of personal data is. Processed personal data is destroyed or depersonalized upon achievement of the processing goals or in the event of loss of the need to achieve these goals, unless otherwise provided by federal law.

6. Purposes of personal data processing

 Purpose of processingConclusion, execution and termination of civil law contracts
 Personal data● surname, first name, patronymic
● E-mail address
● Phone numbers
 categories of users whose data is processedIndividuals (buyers, customers) who have concluded or have the intention to conclude a civil law contract with the operator of the sale and purchase of services presented on the site.
 Legal grounds● Civil Code of the Russian Federation;
● Federal Law No. 149-FZ of July 27, 2006 “On Information, Information Technologies and Information Protection”;
● other normative acts regulating relations related to the operator’s activities and regulatory documents of authorized state bodies of the Russian Federation;
● contracts concluded between the operator and the subjects of personal data;
● the consent of the subjects of personal data to the processing of their personal data.
 Types of personal data processingcollection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
 Ways to process personal dataMixed processing of personal data (non-automated and using automation, with or without the transmission of the received information over the network).
 Terms of processing and storage of personal datafrom the date of the provision of personal data by Users with their consent (in applicable cases) until the purpose of processing personal data or until the User withdraws his consent to the processing of personal data / obtaining a request by the Operator to terminate the processing of personal data, if other period is not provided for by the contract or applicable law. 
 personal storage dataon material carriers in special places excluding unauthorized access. on electronic media – using software tools to limit access to data.
 Achievements of goals processing personal dataWhen the goals of processing personal data or the occurrence of other grounds for terminating the processing of personal data, material carriers of personal data are destroyed, personal data is deleted from electronic media without the possibility of their restoration.
 Purpose of processingProviding access to the User to the Services, Information and/or Materials contained on the Website
 Personal data● surname, first name, patronymic
● E-mail address
● Phone numbers
 categories of users whose data is processed● Individuals individuals,
registered on the site or using the site without registration.
 Legal grounds● Civil Code of the Russian Federation;
● Federal Law No. 149-FZ of July 27, 2006 ‘On Information, Information Technologies and Information Protection’;
● the consent of the subjects of personal data to the processing of their personal data
 Types of personal data processingcollection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
 Ways to process personal dataMixed processing of personal data (non-automated and using automation tools, with or without the transmission of the received information over the network).
 Terms of processing and storage of personal dataFrom the date of the provision of personal data by users with their consent (in applicable cases) until the purpose of processing personal data or until the User withdraws his consent to the processing of personal data / obtaining a request by the Operator to terminate the processing of personal data, if other period is not provided for by the contract or applicable law. 
 personal storage dataon material carriers in special places excluding unauthorized access. on electronic media – using software tools to limit access to data.
 Achievements of goals processing personal dataWhen the goals of processing personal data or the occurrence of other grounds for terminating the processing of personal data, material carriers of personal data are destroyed, personal data is deleted from electronic media without the possibility of their restoration.
 Purpose of processingCollecting statistical information about user actions on the operator’s website, improving the quality of the site and its content using Internet statistics services (analytics) Yandex Metrica
 Personal dataCookies
 categories of users whose data is processedWebsite visitors.
 Legal grounds● Civil Code of the Russian Federation;
● Federal Law No. 149-FZ of July 27, 2006 ‘On Information, Information Technologies and Information Protection’;
● the consent of the subjects of personal data to the processing of their personal data
 Types of personal data processingcollection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
 Ways to process personal dataMixed processing of personal data (non-automated and using automation tools, with or without the transmission of the received information over the network).
 Terms of processing and storage of personal dataFrom the date of the provision of personal data by users with their consent (in applicable cases) until the purpose of processing personal data or until the User withdraws his consent to the processing of personal data / obtaining a request by the Operator to terminate the processing of personal data, if other period is not provided for by the contract or applicable law. 
 personal storage dataon material carriers in special places excluding unauthorized access. on electronic media – using software tools to limit access to data.
 Achievements of goals processing personal dataWhen the goals of processing personal data or the occurrence of other grounds for terminating the processing of personal data, material carriers of personal data are destroyed, personal data is deleted from electronic media without the possibility of their restoration.

7. Conditions for processing personal data

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers and duties assigned to the operator of the Russian Federation.

7.3. The processing of personal data is necessary for the implementation of justice, the execution of a judicial act, an act of another body or an official subject to execution in accordance with the legislation of the Russian Federation on executive proceedings.

7.4. The processing of personal data is necessary for the execution of the contract, the party of which is either the beneficiary or guarantor of which is the subject of personal data, as well as for the conclusion of the contract according to the initiative of the subject of personal data or the contract, according to which the subject of personal data will be 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 significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. The processing of personal data is carried out, the access of an unlimited circle of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as public personal data).

7.7. The processing of personal data subject to publication or mandatory disclosure is carried out in accordance with the federal law.

8. The procedure for collecting, storing, transferring and other types of processing of personal data

The security of personal data that is processed by the operator is ensured by implementing the legal, organizational and technical measures necessary to fulfill the full 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 of unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, with the exception of cases related to the implementation of the current legislation or if the subject of personal data has consented to the operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.

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8.3. If inaccuracies are detected in personal data, the user can update them on his own, by sending the operator a notification to the operator’s email address info@marinazinland.com marked ‘Personalized data update’.

8.4. The period of processing of personal data is determined by the achievement of the purposes for which personal data were collected, unless another period is provided for by the contract or applicable law.
The User may at any time revoke his consent to the processing of personal data by sending a notification to the Operator via e-mail to the operator’s email address info@marinazinland.com marked ‘Resume of consent to processing personal data’.

8.5. All information that is collected by third-party services, including payment systems, communications and other service providers, is stored and processed by the specified persons (operators) in accordance with their user agreement and policy privacy. subject of personal data and / or with the specified documents. The Operator is not responsible for the actions of third parties, including those specified in this paragraph of the Service Providers.

8.6. The prohibitions on the transfer (except for granting access) established by the subject of personal data, as well as the processing or conditions of processing (except for access) of personal data allowed for distribution, do not apply in cases of processing personal data in public, public and other public interests, determined by the legislation of the Russian Federation.

8.7. The operator, when processing personal data, ensures the confidentiality of personal data.

8.8. The operator stores personal data in a form that allows you to determine the subject of personal data not longer than the purpose of processing personal data required, unless the period of storage of personal data is established by the federal law, the contract, the party of which, the beneficiary or guarantor for which the subject of personal data is.

8.9. The condition for the termination of the processing of personal data may be the achievement of the goals of processing personal data, the expiration of the consent of the subject of personal data, the revocation of the consent of the personal data subject or the requirement to terminate the processing of personal data, as well as the identification of illegal processing of personal data.

9. List of actions performed by the operator with the received personal data

9.1. The operator collects, records, systematizes, accumulation, storage, clarification (updating, changing), retrieving, using, transmitting (distributing, granting, accessing), depersonalizing, blocking, removing and destroying personal data.

9.2. The operator carries out automated processing of personal data with the receipt and / or transfer of the received information on information and telecommunication networks or without it.

10. Transboundary transfer of personal data

10.1. The operator before the start of the transboundary transfer of personal data is obliged to notify the authorized body for the protection of the rights of personal data subjects of their intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification about the intention to process personal data).

10.2. The operator, before submitting the above notification, is obliged to receive from the authorities of a foreign state, foreign individuals, foreign legal entities who plan to cross-border transfer of personal data, the relevant information.

11. Privacy of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final provisions

12.1. The user can receive any clarification on issues of interest regarding the processing of his personal data by contacting the operator using e-mail info@marinazinland.com.

12.2. This document will reflect any changes in the policy of processing personal data by the operator. Politics operates indefinitely until it is replaced by a new version.

12.3. The current version of the policy in free access is located on the Internet at https://marinazinland.com/en/privacy-policy/.