Policy on personal data processing 1. general provisions
The present policy of personal data processing is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure of personal data processing and measures to ensure personal data security taken by HEKLER INDUSTRIAL HR OÜ (hereinafter referred to as the Operator). 1.1 The Operator sets as its most important goal and condition of its activity the observance of human and citizen's rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal and family secrecy. 1.2 This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about the visitors of the website https://hekler.hr.
2. Basic concepts used in the Policy
2.1 Automated processing of personal data - processing of personal data by means of computer equipment. 2.2 Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data). 2.3 Website - a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://hekler.hr. 2.4. Personal Data Information System - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of personal data content 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: - to receive from the subject of personal data reliable information and/or documents containing personal data; - in case the personal data subject revokes his/her consent to personal data processing, as well as in case the personal data subject submits a request to stop personal data processing, the Operator has the right to continue processing personal data without the consent of the personal data subject on the 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 shall:
- provide the personal data subject, upon his/her request, with information regarding the processing of his/her personal data; - organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation; - to 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 10 days from the date of receipt of such request; - publish or otherwise provide unrestricted access to this Policy on personal data processing; - take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with regard to personal data; - cease transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Personal Data Law; - fulfill other obligations stipulated by the Personal Data Law.
4. basic rights and obligations of personal data subjects
4.1 Personal data subjects have the right to: - To receive information regarding the processing of his/her personal data, except in cases provided for by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in 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; - demand from the operator to clarify his personal data, block or destroy it in case the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his rights; - to impose the condition of prior consent when processing personal data in order to market goods, works and services; - to withdraw consent to the processing of personal data, as well as to submit a request to stop the processing of personal data; - to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of his/her personal data; - to 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; - notify the Operator about clarification (update, 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. Principles of personal data processing
5.1 The processing of personal data is carried out on a lawful and fair basis. 5.2 The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed. 5.3 It is not allowed to merge databases containing personal data processed for incompatible purposes. 5.4 Only personal data that meet the purposes of their processing shall be processed. 5.5 The content and scope of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed. 5.6 When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, relevance to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data. 5.7 Storage of personal data is carried out in a form that allows to identify 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 federal law, contract, party to which, beneficiary or guarantor of which is the subject of personal data. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided for by federal law.
6. Purposes of personal data processing Purpose of processing: conclusion, execution and termination of civil law contracts Personal data :
surname, first name, patronymic
Legal grounds: contracts concluded between the operator and the subject of personal data Types of personal data processing:
Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
Sending informational letters to the e-mail address
7. Conditions of personal data processing
7.1 Processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data. 7.2 The processing of personal data is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or by law, to fulfill the functions, powers and duties imposed on the operator by the legislation of the Russian Federation. 7.3 The processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings. 7.4 The processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will 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 for the achievement of socially important purposes, provided that the rights and freedoms of the personal data subject are not violated. 7.6 Processing of personal data to which the subject of personal data or at his/her request (hereinafter referred to as publicly available personal data) is granted access by an unlimited number of persons. 7.7 Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for collection, storage, transfer and other types of personal data processing
9. List of actions performed by the Operator with the received personal data 9.1 The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete and destroy personal data. 9.2 The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1 Before commencing transborder transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out transborder transfer of personal data (such notification shall be sent separately from the notification on the intention to carry out personal data processing). 10.2 Before submitting the above-mentioned notification, the Operator shall be obliged to obtain relevant information from foreign authorities, foreign individuals, foreign legal entities to whom transborder transfer of personal data is planned.
11. Confidentiality of personal data
The operator and other persons who have 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 may obtain any clarifications on matters of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at email@example.com. 12.2 This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version. 12.3. The current version of the Policy is freely available on the Internet at https://hekler.hr/privacypolicy.