Personal Data Processing Policy
General Provisions This personal data processing policy is drawn up in accordance with the requirements of the General Data Protection Regulation, GDPR; Regulation (European Union) 2016/679 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Vasilenka Aliaksandr Grigorievich (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 a person and a citizen when processing his 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 referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://lobytrade.com/login. 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 - temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data). 2.3. Website - a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at a network address https://lobytrade.com. 2.4. Personal data information system is a set of personal data contained in databases, and information technologies and technical means that ensure 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 ownership 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 means with personal data, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data. 2.7. Operator - 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 personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data. 2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://lobytrade.com. 2.9. Personal data allowed by the subject of personal data for distribution - personal data, access of an unlimited number of persons to which 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 prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution). 2.10. User – any visitor to the website https://lobytrade.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 indefinite circle of persons (transfer of personal data) or at familiarizing with personal data of an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way. 2.13. Cross-border 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 a 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) material carriers of personal data are destroyed. 3. Basic rights and obligations of the Operator 3.1. The Operator has the right to: – 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 the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data in 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 regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other laws. 3.2. The Operator shall: – 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 established by the current legislation of the Russian Federation; – respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data; – to inform the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request; – publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data; – take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of 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 obligations provided for by the Law on Personal Data. 4. Fundamental rights and obligations of personal data subjects 4.1. Subjects of personal data have the right to: – receive information regarding the processing of his personal data, except in cases provided for by law. The information is provided to the subject of personal data by the Operator in an accessible form, and they should not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosing 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 or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take the measures provided for by law to protect their rights; – put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market; – to withdraw consent to the processing of personal data; – appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator in the processing of his personal data; – to exercise other rights provided for by the legislation of the Russian Federation. 4.2. Subjects of personal data are obliged to: – provide the Operator with reliable data about himself; – inform the Operator about the clarification (updating, change) of their personal data. 4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation. 5. The Operator may process the following personal data of the User 5.1. Surname, name, patronymic. 5.2. E-mail address. 5.3. Also, the site collects and processes impersonal data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics and others). 5.4. The above data are further down the text of the Policy and are united by the general concept of Personal Data. 5.5. The processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator. 5.6. The processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Article 10.1 of the Law on Personal Data are observed. 5.7. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of his personal data. At the same time, the conditions provided for, in particular, by Art. 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects. 5.7.1 Consent to the processing of personal data permitted for distribution, the User provides to the Operator directly. 5.7.2 The Operator is obliged to publish information on the terms of processing, the presence of prohibitions and conditions on the processing by an unlimited number of persons of personal data permitted for distribution within three working days from the date of receipt of the User's consent. 5.7.3 The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement should include the surname, name, patronymic (if any), contact information (phone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is sent. 5.7.4 Consent to the processing of personal data permitted for distribution shall terminate from the moment the Operator receives the requirement specified in clause 5.7.3 of this Policy regarding the processing of personal data. 6. Principles of personal data processing 6.1. The processing of personal data is carried out on a lawful and fair basis. 6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed. 6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other. 6.4. Only personal data that meet the purposes of their processing are subject to processing. 6.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed. 6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data. 6.7. Storage of personal data is carried out in a form that allows to determine 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 law, by a contract to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or anonymized upon achievement of the purposes of processing or in case of loss of need to achieve these goals, unless otherwise provided by law. 7. Purposes of personal data processing 7.1. Purpose of processing the User's personal data: – informing the User by sending e-mails; – providing the User with access to the services, information and / or materials contained on the https://lobytrade.com website. 7.2. Also, the Operator has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive information messages by sending the Operator a letter to the e-mail address of the eaquantumlab@gmail.com marked "Refusal of notifications about new products and services and special offers". 7.3. Impersonal data of Users collected through Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content. 8. The procedure for the collection, storage, transfer and other types of processing of personal data The security of personal data processed by the Operator is ensured by 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 that 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, except for cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract. 8.3. In case of inaccuracies in personal data, the User can update them independently, by sending the Operator a notification to the Operator's e-mail address eaquantumlab@gmail.com marked "Updating of 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 another period is provided for by the contract or the current legislation.The user can at any time withdraw his consent to the processing of personal data by sending a notification to the Operator by e-mail to the operator's e-mail address eaquantumlab@gmail.com marked "Withdrawal of consent to the processing of personal data". 8.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and / or the User is obliged to familiarize himself with these documents in a timely manner. The operator is not responsible for the actions of third parties, including those specified in this point of service providers. 8.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for gaining access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public and other public interests defined 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 to determine the subject of personal data no longer than required by the purposes of personal data processing, if the period of storage of personal data is not established by law, by a contract to which the beneficiary or guarantor is a party , under which the subject of personal data is a party. 8.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the detection of illegal processing of personal data. 9. List of actions performed by the Operator with the personal data received 9.1. The Operator collects, records, systematizes, accumulates, stores, refines (update, changes), extracts, uses, transfers (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data. 9.2. The Operator carries out automated processing of personal data with or without receipt and / or transmission of the information received via information and telecommunication networks. 10. Cross-border transfer of personal data 10.1. Before starting the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state, to the territory of which the transfer of personal data is supposed to be carried out, ensures reliable protection of the rights of personal data subjects. 10.2. Cross-border transfer of personal data in the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of his personal data and / or the execution of the contract to which the subject of personal data is a party. 11. Confidentiality 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 distribute personal data without the consent of the subject of personal data, unless otherwise provided by law. 12. Final provisions 1 2.1. The User can obtain any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail eaquantumlab@gmail.com. 1 2.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced by a new version. 1 2.3. The current version of the Policy is freely available on the Internet at https://lobytrade.com/privacy.