Personal Data Processing and Storage Policy
1. General Terms
This Personal Data Processing Policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 'On Personal Data' (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 Limited Liability Company 'Modern Motherhood Technologies' (hereinafter referred to as the 'Operator').
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of a person and citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy 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://ecofamilyclinic.ru.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation 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 accessibility on the Internet at the network address https://ecofamilyclinic.ru.
2.4. Personal data information system – 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 belonging 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 using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, 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 the processing of 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 relating directly or indirectly to a specific or identifiable User of the website https://ecofamilyclinic.ru.
2.9. Personal data permitted for distribution by the subject of personal data – personal data, access to which is granted by the subject of personal data to an unlimited number of persons by giving consent to the processing of personal data permitted for distribution by the subject of personal data in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User – any visitor to the website https://ecofamilyclinic.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a certain circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.
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 subject of personal data;
In the event that the subject of personal data withdraws 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 if there are grounds specified in the Personal Data Law;
Independently determine the composition and list of measures necessary and sufficient to ensure the 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 subject of personal data, at their request, with information regarding the processing of their 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 from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
Provide the authorized body for the protection of the rights of subjects of personal data, at the request of this body, with 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, 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 in the cases provided for by the Personal Data Law;
Fulfill other obligations stipulated by the Personal Data Law.
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. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
Require the operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
Put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
Withdraw consent to the processing of personal data;
Appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or inaction of the Operator when processing their personal data;
Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
Provide the Operator with reliable data about themselves;
Inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User:
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Year, month, date, and place of birth.
5.5. The website also collects and processes anonymized data about visitors (including "cookie" files) using web analytics services (Yandex Metrica, Google Analytics, and others).
5.6. The above data is hereinafter referred to in the text of the Policy as Personal Data.
5.7. The Operator does not process special categories of personal data relating to racial, national origin, political views, religious or philosophical beliefs, or intimate life.
5.8. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Personal Data Law are observed.
5.9. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of their personal data. In this case, the conditions provided for, in particular, by Art. 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.9.1 The User provides the Operator with consent to the processing of personal data permitted for distribution directly.
5.9.2 The Operator is obliged, no later than three working days from the moment of receiving the specified consent from the User, to publish information about the processing conditions, the presence of prohibitions and conditions for the processing of personal data permitted for distribution by an unlimited number of persons.
5.9.3 The transfer (distribution, provision, access) of personal data permitted for distribution by the subject of personal data must be terminated at any time at the request of the subject of personal data. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the subject of personal data, as well as a list of personal data, the processing of which must be terminated. The personal data specified in this request may only be processed by the Operator to whom it is addressed.
5.9.4 Consent to the processing of personal data permitted for distribution terminates from the moment the Operator receives the request specified in clause 5.9.3 of this Personal Data Processing Policy.
6. Principles of Personal Data Processing
6.1. Personal data processing is carried out on a legal and fair basis.
6.2. Personal data processing is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
6.4. Only personal data that meets the purposes of its processing is subject to processing.
6.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of its processing is not allowed.
6.6. When processing personal data, the accuracy, sufficiency, and, if necessary, relevance of personal data in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data is 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 storage period for personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or in case the need to achieve these purposes ceases to exist, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data is:
Informing the User by sending emails;
Concluding, executing, and terminating civil law contracts;
Consulting and clarifying the details of requests for the organization's services.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the Operator at the email address reception@ecofamilyclinic.ru marked "Refusal of notifications about new products and services and special offers."
7.3. Anonymized User data collected using web analytics services is used to collect information about User actions on the website, improve the quality of the website and its content.
8. Legal Basis for Processing Personal Data
8.1. The legal basis for the processing of personal data by the Operator are:
Federal Law "On Information, Information Technologies and Protection of Information" dated July 27, 2006 N 149-FZ;
Federal laws and other regulatory legal acts in the field of personal data protection;
User consents to the processing of their personal data, and to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User independently through special forms located on the website https://ecofamilyclinic.ru or sent to the Operator via email. By filling in the appropriate forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is permitted in the User's browser settings (saving "cookie" files and using JavaScript technology is enabled).
8.4. The subject of personal data independently makes the decision to provide their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions for Processing Personal Data
9.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
9.5. Processing of personal data 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 the rights and freedoms of the subject of personal data are not violated.
9.6. Personal data is processed, access to which is granted by the subject of personal data to an unlimited number of persons or at their request (hereinafter referred to as publicly available personal data)
.
9.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.
10. 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 current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. 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 subject of personal data has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.
10.3. If inaccuracies in personal data are found, the User can update them independently by sending a notification to the Operator at the Operator's email address reception@ecofamilyclinic.ru marked "Personal Data Update."
10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address reception@ecofamilyclinic.ru marked "Withdrawal of consent to the processing of personal data."
10.5. All information collected by third-party services, including payment systems, communication tools, 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 independently familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. Prohibitions on the transfer (except for granting access), as well as on the processing or conditions for processing (except for obtaining access) of personal data permitted for distribution, established by the subject of personal data, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data when processing it.
10.8. The Operator stores personal data in a form that allows identification of the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor.
10.9. The condition for 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 identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator performs the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such networks.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only with the written consent of the personal data subject to the cross-border transfer of their personal data and/or performance of a contract to which the personal data subject is a party.
13. 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 personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at reception@ecofamilyclinic.ru.
14.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://ecofamilyclinic.ru/policy