Personal Data Processing Policy
1. General Provisions
1.1. This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and establishes the procedure for processing personal data and the measures to ensure the security of personal data at OOO Flysound (hereinafter, the “Operator”).
1.2. The Operator considers respect for human and civil rights and freedoms when processing personal data, including protection of the rights to privacy and personal and family confidentiality, to be its most important objective and a prerequisite for its activities.
1.3. This Personal Data Processing Policy of the Operator (hereinafter, the “Policy”) applies to all information that the Operator may obtain about visitors to the website http://flysound.ru.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer equipment;
2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify the personal data;
2.3. Website means the collection of graphic and information materials, computer programs and databases that make them available on the Internet at http://flysound.ru;
2.4. Personal data information system means the aggregate of personal data contained in databases and the information technologies and technical means used to process those data;
2.5. Depersonalisation of personal data means actions that make it impossible, without additional information, to determine whether personal data belong to a particular User or another personal data subject;
2.6. Processing of personal data means any action or operation, or combination of actions or operations, performed on personal data, with or without automated means, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data;
2.7. Operator means a state body, municipal body, legal entity or individual that independently or jointly with other persons organises and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of the personal data to be processed and the actions or operations to be performed on personal data;
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website http://flysound.ru;
2.9. User means any visitor to the website http://flysound.ru;
2.10. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons;
2.11. Distribution of personal data means any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including publishing personal data in the mass media, placing them on information and telecommunications networks or providing access to personal data in any other way;
2.12. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity;
2.13. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of the personal data in the personal data information system, and/or the destruction of tangible media containing personal data.
3. The Operator May Process the Following Personal Data of the User
Last name, first name and patronymic;
Email address;
Telephone numbers;
The website also collects and processes depersonalised data about visitors, including cookies, using Internet statistics services (Yandex Metrica).
The data listed above are collectively referred to as Personal Data in this Policy.
4. Purposes of Personal Data Processing
4.1. The purposes of processing the User’s personal data are to inform the User by sending emails and to provide the User with access to services, information and/or materials on the website.
4.2. Depersonalised User data collected through Internet statistics services are used to gather information about Users’ activities on the website and to improve the quality of the website and its content.
5. Legal Grounds for Personal Data Processing
5.1. The Operator processes the User’s personal data only when the User independently enters and/or submits them through the dedicated forms on http://flysound.ru. By completing the relevant forms and/or submitting their personal data to the Operator, the User expresses consent to this Policy.
5.2. The Operator processes depersonalised data about the User if this is permitted by the User’s browser settings.
6. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data
6.1. The security of personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to comply fully with the requirements of applicable personal data protection legislation.
6.2. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorised persons from accessing personal data.
6.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except where the User has consented to this or in cases connected with compliance with applicable legislation of the Russian Federation.
6.4. If inaccuracies are identified in the personal data, the User may update them independently by sending a notice to the Operator at info@flysound.ru, marked “Updating Personal Data”, with a scanned copy of the passport page containing the photograph attached.
6.5. Consent to personal data processing remains valid until the data subject withdraws their consent using the form available on the Website. The completed form and a scanned copy of the passport page containing the photograph must be sent to the Operator at info@flysound.ru, marked “Withdrawal of Consent to Personal Data Processing”.
7. Cross-Border Transfer of Personal Data
7.1. The Operator does not carry out cross-border transfers of personal data.
8. Main Rights and Obligations of the Operator
8.1. The Operator has the right to:
1) independently determine the composition and list of measures necessary and sufficient to fulfil the obligations established by the Law on Personal Data and the regulatory legal acts adopted pursuant to it, unless otherwise provided by the Law on Personal Data or other federal laws;
2) entrust the processing of personal data to another person, with the consent of the personal data subject, unless otherwise provided by federal law, under a contract concluded with that person. A person processing personal data on behalf of the Operator must observe the principles and rules of personal data processing established by the Law on Personal Data, maintain the confidentiality of personal data and take the necessary measures to fulfil the obligations established by the Law on Personal Data;
3) continue processing personal data without the consent of the personal data subject if the subject withdraws their consent to personal data processing, where grounds specified in the Law on Personal Data exist.
8.2. The Operator must:
1) organise personal data processing in accordance with the requirements of the Law on Personal Data;
2) respond to enquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
3) provide the authorised body for the protection of the rights of personal data subjects (the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)) with the necessary information at that body’s request within 10 working days of receiving the request. This period may be extended by no more than five working days. To do so, the Operator must send Roskomnadzor a reasoned notice stating the reasons for extending the period for providing the requested information;
4) in accordance with the procedure established by the federal executive body authorised in the field of security, ensure interaction with the state system for detecting and preventing computer attacks on the information resources of the Russian Federation and eliminating their consequences, including informing that body of computer incidents that resulted in the unlawful transfer of personal data (provision, distribution or access).
9. Main Rights of the Personal Data Subject
9.1. The personal data subject has the right to:
1) receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator provides this information to the personal data subject in an accessible form; it must not contain personal data relating to other personal data subjects, except where lawful grounds exist for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
2) require the Operator to clarify, block or destroy their personal data if the data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take the measures provided for by law to protect their rights;
3) require prior consent as a condition for processing personal data for the purpose of promoting goods, works and services on the market;
4) challenge the Operator’s unlawful actions or omissions in processing their personal data before Roskomnadzor or in court.
10. Compliance with the requirements of this Policy is monitored by an authorised person responsible for organising personal data processing at the Operator.
11. Liability for violations of the requirements of the legislation of the Russian Federation and the regulations of OOO Flysound concerning the processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.
12. Procedure and Conditions for Personal Data Processing
12.1. The Operator processes personal data in accordance with the requirements of the legislation of the Russian Federation.
12.2. Personal data are processed with the consent of the personal data subjects to the processing of their personal data, and without such consent in cases provided for by the legislation of the Russian Federation.
12.3. The Operator carries out both automated and non-automated processing of personal data.
12.4. Employees of the Operator whose duties include personal data processing are authorised to process personal data.
12.5. Personal data may not be disclosed to third parties or distributed without the consent of the personal data subject, unless otherwise provided by federal law. Consent to the processing of personal data authorised by the personal data subject for distribution is given separately from the subject’s other consents to the processing of their personal data.
12.6. Personal data are transferred to bodies of inquiry and investigation, the Federal Tax Service, the Social Fund of Russia and other authorised executive bodies and organisations in accordance with the requirements of the legislation of the Russian Federation.
12.7. The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, distribution and other unauthorised actions, including:
12.9. When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures the recording, systematisation, accumulation, storage, clarification (updating, modification) and retrieval of personal data of citizens of the Russian Federation using databases located within the Russian Federation, except in cases specified in the Law on Personal Data.
13. Updating, Rectification, Deletion and Destruction of Personal Data; Responses to Data Subjects’ Requests for Access to Personal Data
13.1. Confirmation that the Operator is processing personal data, the legal grounds and purposes of personal data processing, and the other information specified in Part 7 of Article 14 of the Law on Personal Data are provided by the Operator to the personal data subject or their representative within 10 working days of an enquiry or receipt of a request from the personal data subject or their representative. This period may be extended by no more than five working days. To do so, the Operator should send the personal data subject a reasoned notice stating the reasons for extending the period for providing the requested information.
The information provided does not include personal data relating to other personal data subjects, except where lawful grounds exist for disclosing such personal data.
The request must contain:
If the personal data subject’s enquiry or request does not contain all the information required by the Law on Personal Data, or the subject does not have the right to access the requested information, a reasoned refusal is sent to them.
The personal data subject’s right to access their personal data may be restricted in accordance with Part 8 of Article 14 of the Law on Personal Data, including where the subject’s access to their personal data would infringe the rights and legitimate interests of third parties.
13.2. If inaccurate personal data are identified following an enquiry by a personal data subject or their representative, or a request from them or Roskomnadzor, the Operator blocks the personal data relating to that subject from the time of the enquiry or receipt of the request for the duration of the verification, provided that blocking the personal data does not infringe the rights and legitimate interests of the personal data subject or third parties.
If the inaccuracy of the personal data is confirmed, the Operator clarifies the personal data on the basis of information provided by the personal data subject, their representative or Roskomnadzor, or other necessary documents, within seven working days of the date on which that information is provided, and lifts the blocking of the personal data.
13.3. If unlawful personal data processing is identified following an enquiry or request by a personal data subject, their representative or Roskomnadzor, the Operator blocks the unlawfully processed personal data relating to that subject from the time of the enquiry or receipt of the request.
13.4. If the Operator, Roskomnadzor or another interested person identifies an unlawful or accidental transfer of personal data (provision or distribution), or access to personal data, that has resulted in an infringement of the rights of personal data subjects, the Operator:
1.1. This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and establishes the procedure for processing personal data and the measures to ensure the security of personal data at OOO Flysound (hereinafter, the “Operator”).
1.2. The Operator considers respect for human and civil rights and freedoms when processing personal data, including protection of the rights to privacy and personal and family confidentiality, to be its most important objective and a prerequisite for its activities.
1.3. This Personal Data Processing Policy of the Operator (hereinafter, the “Policy”) applies to all information that the Operator may obtain about visitors to the website http://flysound.ru.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer equipment;
2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify the personal data;
2.3. Website means the collection of graphic and information materials, computer programs and databases that make them available on the Internet at http://flysound.ru;
2.4. Personal data information system means the aggregate of personal data contained in databases and the information technologies and technical means used to process those data;
2.5. Depersonalisation of personal data means actions that make it impossible, without additional information, to determine whether personal data belong to a particular User or another personal data subject;
2.6. Processing of personal data means any action or operation, or combination of actions or operations, performed on personal data, with or without automated means, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data;
2.7. Operator means a state body, municipal body, legal entity or individual that independently or jointly with other persons organises and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of the personal data to be processed and the actions or operations to be performed on personal data;
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website http://flysound.ru;
2.9. User means any visitor to the website http://flysound.ru;
2.10. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons;
2.11. Distribution of personal data means any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including publishing personal data in the mass media, placing them on information and telecommunications networks or providing access to personal data in any other way;
2.12. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity;
2.13. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of the personal data in the personal data information system, and/or the destruction of tangible media containing personal data.
3. The Operator May Process the Following Personal Data of the User
Last name, first name and patronymic;
Email address;
Telephone numbers;
The website also collects and processes depersonalised data about visitors, including cookies, using Internet statistics services (Yandex Metrica).
The data listed above are collectively referred to as Personal Data in this Policy.
4. Purposes of Personal Data Processing
4.1. The purposes of processing the User’s personal data are to inform the User by sending emails and to provide the User with access to services, information and/or materials on the website.
4.2. Depersonalised User data collected through Internet statistics services are used to gather information about Users’ activities on the website and to improve the quality of the website and its content.
5. Legal Grounds for Personal Data Processing
5.1. The Operator processes the User’s personal data only when the User independently enters and/or submits them through the dedicated forms on http://flysound.ru. By completing the relevant forms and/or submitting their personal data to the Operator, the User expresses consent to this Policy.
5.2. The Operator processes depersonalised data about the User if this is permitted by the User’s browser settings.
6. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data
6.1. The security of personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to comply fully with the requirements of applicable personal data protection legislation.
6.2. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorised persons from accessing personal data.
6.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except where the User has consented to this or in cases connected with compliance with applicable legislation of the Russian Federation.
6.4. If inaccuracies are identified in the personal data, the User may update them independently by sending a notice to the Operator at info@flysound.ru, marked “Updating Personal Data”, with a scanned copy of the passport page containing the photograph attached.
6.5. Consent to personal data processing remains valid until the data subject withdraws their consent using the form available on the Website. The completed form and a scanned copy of the passport page containing the photograph must be sent to the Operator at info@flysound.ru, marked “Withdrawal of Consent to Personal Data Processing”.
7. Cross-Border Transfer of Personal Data
7.1. The Operator does not carry out cross-border transfers of personal data.
8. Main Rights and Obligations of the Operator
8.1. The Operator has the right to:
1) independently determine the composition and list of measures necessary and sufficient to fulfil the obligations established by the Law on Personal Data and the regulatory legal acts adopted pursuant to it, unless otherwise provided by the Law on Personal Data or other federal laws;
2) entrust the processing of personal data to another person, with the consent of the personal data subject, unless otherwise provided by federal law, under a contract concluded with that person. A person processing personal data on behalf of the Operator must observe the principles and rules of personal data processing established by the Law on Personal Data, maintain the confidentiality of personal data and take the necessary measures to fulfil the obligations established by the Law on Personal Data;
3) continue processing personal data without the consent of the personal data subject if the subject withdraws their consent to personal data processing, where grounds specified in the Law on Personal Data exist.
8.2. The Operator must:
1) organise personal data processing in accordance with the requirements of the Law on Personal Data;
2) respond to enquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
3) provide the authorised body for the protection of the rights of personal data subjects (the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)) with the necessary information at that body’s request within 10 working days of receiving the request. This period may be extended by no more than five working days. To do so, the Operator must send Roskomnadzor a reasoned notice stating the reasons for extending the period for providing the requested information;
4) in accordance with the procedure established by the federal executive body authorised in the field of security, ensure interaction with the state system for detecting and preventing computer attacks on the information resources of the Russian Federation and eliminating their consequences, including informing that body of computer incidents that resulted in the unlawful transfer of personal data (provision, distribution or access).
9. Main Rights of the Personal Data Subject
9.1. The personal data subject has the right to:
1) receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator provides this information to the personal data subject in an accessible form; it must not contain personal data relating to other personal data subjects, except where lawful grounds exist for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
2) require the Operator to clarify, block or destroy their personal data if the data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take the measures provided for by law to protect their rights;
3) require prior consent as a condition for processing personal data for the purpose of promoting goods, works and services on the market;
4) challenge the Operator’s unlawful actions or omissions in processing their personal data before Roskomnadzor or in court.
10. Compliance with the requirements of this Policy is monitored by an authorised person responsible for organising personal data processing at the Operator.
11. Liability for violations of the requirements of the legislation of the Russian Federation and the regulations of OOO Flysound concerning the processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.
12. Procedure and Conditions for Personal Data Processing
12.1. The Operator processes personal data in accordance with the requirements of the legislation of the Russian Federation.
12.2. Personal data are processed with the consent of the personal data subjects to the processing of their personal data, and without such consent in cases provided for by the legislation of the Russian Federation.
12.3. The Operator carries out both automated and non-automated processing of personal data.
12.4. Employees of the Operator whose duties include personal data processing are authorised to process personal data.
12.5. Personal data may not be disclosed to third parties or distributed without the consent of the personal data subject, unless otherwise provided by federal law. Consent to the processing of personal data authorised by the personal data subject for distribution is given separately from the subject’s other consents to the processing of their personal data.
12.6. Personal data are transferred to bodies of inquiry and investigation, the Federal Tax Service, the Social Fund of Russia and other authorised executive bodies and organisations in accordance with the requirements of the legislation of the Russian Federation.
12.7. The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, distribution and other unauthorised actions, including:
- identifying threats to the security of personal data during processing;
- adopting internal regulations and other documents governing relations concerning the processing and protection of personal data;
- appointing persons responsible for ensuring personal data security in the Operator’s organisational units and information systems;
- creating the necessary conditions for working with personal data;
- organising the accounting of documents containing personal data;
- organising work with information systems in which personal data are processed;
- storing personal data under conditions that ensure their safekeeping and prevent unlawful access to them;
- organising training for the Operator’s employees who process personal data.
12.9. When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures the recording, systematisation, accumulation, storage, clarification (updating, modification) and retrieval of personal data of citizens of the Russian Federation using databases located within the Russian Federation, except in cases specified in the Law on Personal Data.
13. Updating, Rectification, Deletion and Destruction of Personal Data; Responses to Data Subjects’ Requests for Access to Personal Data
13.1. Confirmation that the Operator is processing personal data, the legal grounds and purposes of personal data processing, and the other information specified in Part 7 of Article 14 of the Law on Personal Data are provided by the Operator to the personal data subject or their representative within 10 working days of an enquiry or receipt of a request from the personal data subject or their representative. This period may be extended by no more than five working days. To do so, the Operator should send the personal data subject a reasoned notice stating the reasons for extending the period for providing the requested information.
The information provided does not include personal data relating to other personal data subjects, except where lawful grounds exist for disclosing such personal data.
The request must contain:
- the number of the principal identity document of the personal data subject or their representative, the date of issue of that document and the authority that issued it;
- information confirming the personal data subject’s relationship with the Operator (contract number, date of conclusion of the contract, a designated verbal identifier and/or other information), or other information confirming that the Operator processes the personal data;
- the signature of the personal data subject or their representative.
If the personal data subject’s enquiry or request does not contain all the information required by the Law on Personal Data, or the subject does not have the right to access the requested information, a reasoned refusal is sent to them.
The personal data subject’s right to access their personal data may be restricted in accordance with Part 8 of Article 14 of the Law on Personal Data, including where the subject’s access to their personal data would infringe the rights and legitimate interests of third parties.
13.2. If inaccurate personal data are identified following an enquiry by a personal data subject or their representative, or a request from them or Roskomnadzor, the Operator blocks the personal data relating to that subject from the time of the enquiry or receipt of the request for the duration of the verification, provided that blocking the personal data does not infringe the rights and legitimate interests of the personal data subject or third parties.
If the inaccuracy of the personal data is confirmed, the Operator clarifies the personal data on the basis of information provided by the personal data subject, their representative or Roskomnadzor, or other necessary documents, within seven working days of the date on which that information is provided, and lifts the blocking of the personal data.
13.3. If unlawful personal data processing is identified following an enquiry or request by a personal data subject, their representative or Roskomnadzor, the Operator blocks the unlawfully processed personal data relating to that subject from the time of the enquiry or receipt of the request.
13.4. If the Operator, Roskomnadzor or another interested person identifies an unlawful or accidental transfer of personal data (provision or distribution), or access to personal data, that has resulted in an infringement of the rights of personal data subjects, the Operator:
- within 24 hours, notifies Roskomnadzor of the incident, the presumed causes of the infringement of the rights of personal data subjects, the presumed harm caused to those rights and the measures taken to remedy the consequences of the incident, and provides details of the person authorised by the Operator to liaise with Roskomnadzor on matters relating to the incident;
- within 72 hours, notifies Roskomnadzor of the results of the internal investigation of the incident and provides information about the persons whose actions caused it, if any.
- a contract to which the personal data subject is a party, beneficiary or guarantor does not provide otherwise;
- the Operator is not entitled to process the data without the personal data subject’s consent on the grounds provided for by the Law on Personal Data or other federal laws;
- another agreement between the Operator and the personal data subject does not provide otherwise.
- 13.6. If a personal data subject requests that the Operator cease processing their personal data, the processing ceases within no more than three working days of the Operator’s receipt of the relevant request, except in cases provided for by the Law on Personal Data. This period may be extended by no more than five working days. To do so, the Operator must send the personal data subject a reasoned notice stating the reasons for the extension.
info@flysound.ru
© 2023
All rights are reserved
All rights are reserved