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” dated July 27, 2006 (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 undertaken by the PIR Center (hereinafter referred to as the “Operator”).
1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the right to privacy, personal and family confidentiality, to be its most important goal and condition for conducting its activities.
1.2. This Operator’s policy regarding personal data processing (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the website https://pircenter.org/.
2. Basic Terms Used in the Policy
2.1. Automated Processing of Personal Data – processing of personal data using computing technology.
2.2. Blocking of Personal Data – temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as software and databases that ensure their availability on the internet at https://pircenter.org/.
2.4. Personal Data Information System – a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Depersonalization of Personal Data – actions that make it impossible to determine the affiliation of personal data to a specific User or other personal data subject without additional information.
2.6. Processing of Personal Data – any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a government agency, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing and determines the purposes of processing personal data, 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 a specific or identifiable User of the website https://pircenter.org/.
2.9. Personal Data Permitted by the Data Subject for Distribution – personal data to which an unlimited number of persons have access, as provided by the data subject through their consent for processing such data for distribution in accordance with the Personal Data Law.
2.10. User – any visitor to the website https://pircenter.org/.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of Personal Data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data publicly available, including publication in mass media, posting in information and telecommunications 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 a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data – any actions that result in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in a personal data information system and/or that destroy the physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
- Obtain accurate information and/or documents containing personal data from the data subject.
- Continue processing personal data without the data subject’s consent in cases specified by the Personal Data Law, even if the data subject withdraws their consent.
- Independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law unless otherwise stipulated by the law.
3.2. The Operator is obliged to:
- Provide the data subject, upon their request, with information regarding the processing of their personal data.
- Organize the processing of personal data in accordance with applicable Russian law.
- Respond to requests and inquiries from data subjects and their legal representatives as required by the Personal Data Law.
- Report to the authorized body for personal data protection upon request within 10 days of receiving such a request.
- Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing.
- Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as other unlawful actions.
- Stop the transfer (distribution, provision, access) of personal data and cease processing and destroy personal data under the conditions and circumstances specified by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
- Obtain information regarding the processing of their personal data, except in cases provided by federal law.
- Request the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing.
- Require prior consent for processing personal data for marketing purposes.
- Withdraw consent to the processing of personal data.
- Appeal unlawful actions or inaction of the Operator to the authorized body for the protection of personal data subjects’ rights or in court.
4.2. Personal data subjects are required to:
- Provide the Operator with accurate information about themselves.
- Notify the Operator about updates (changes) to their personal data.
4.3. Individuals who have provided inaccurate data about themselves or another personal data subject without consent are responsible in accordance with Russian law.
5. Principles of Personal Data Processing
5.1. Personal data is processed lawfully and fairly.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes.
5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
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 processing purposes.
5.6. Personal data is stored in a form that allows identifying the personal data subject no longer than required for the processing purposes.
6. Purposes of Personal Data Processing
- Purpose: To clarify details of a User’s inquiry. The Operator also has the right to send notifications about new products, services, special offers, and events.
- Processed Personal Data: Name, surname, patronymic, email address, phone number, job position, and place of work.
- Legal Basis: Federal Law No. 152-FZ “On Personal Data”.
- Processing Methods: Collection, recording, systematization, accumulation, storage, destruction, depersonalization, sending informational emails.
7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject.
7.2. The processing of personal data is necessary for achieving the purposes established by an international agreement of the Russian Federation or by law, for fulfilling functions, powers, and obligations assigned to the Operator by Russian law.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official that is enforceable under Russian law.
7.4. The processing of personal data is necessary for fulfilling a contract in which the data subject is a party, a beneficiary, or a guarantor, as well as for concluding a contract at the request of the data subject or a contract in which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for exercising the Operator’s rights and legitimate interests or those of third parties, or for achieving socially significant goals, provided that this does not infringe on the rights and freedoms of the personal data subject.
7.6. The processing of publicly available personal data is carried out when the data subject has made such data accessible to an unlimited number of people or upon the request of the data subject.
7.7. The processing of personal data that is required to be published or disclosed in accordance with federal law is carried out.
8. Procedure for Collecting, Storing, Transmitting, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary for full compliance with current legislation on personal data protection.
8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never be transferred to third parties under any circumstances, except in cases related to compliance with applicable law or when the data subject has given explicit consent for the transfer to third parties for fulfilling a civil contract.
8.3. If inaccuracies in personal data are identified, the User may update the data independently by sending a notification to the Operator at inform@pircenter.org with the subject “Personal Data Update.”
8.4. The processing duration of personal data is determined by the achievement of the purposes for which the data was collected, unless otherwise provided by law or contract. The User may withdraw their consent to personal data processing at any time by sending a request via email to inform@pircenter.org with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. Any information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by these parties according to their respective privacy policies. The Operator is not responsible for the actions of third parties.
8.6. Any restrictions imposed by the personal data subject on the processing of publicly available personal data do not apply when processing such data in state, public, or other legally significant interests as determined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than required for the processing purposes, unless a longer storage period is required by federal law or a contract in which the personal data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may occur when the processing purposes are achieved, the data subject’s consent expires, the data subject withdraws consent, or if unlawful processing is detected.
9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator performs the following actions on personal data: collection, recording, systematization, accumulation, storage, updating (modification), extraction, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.
9.2. The Operator performs automated processing of personal data, including receiving and/or transmitting collected information through information and telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before carrying out a cross-border transfer of personal data, the Operator must notify the authorized body responsible for protecting the rights of personal data subjects about its intention to transfer data abroad (this notification is sent separately from the general notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain relevant information from the foreign government authorities, foreign individuals, or foreign legal entities to which personal data is planned to be transferred.
11. Confidentiality of Personal Data
The Operator and any other persons who gain access to personal data must not disclose such data to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at inform@pircenter.org.
12.2. Any changes to this Personal Data Processing Policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available online at https://pircenter.org/privacy-policy/.
