Personal Data Processing Policy

Personal Data Policy (PDF)

According to the Regulations on commercial secrets, the approved LLC "buffer Bay" from 06.12.2017

1. General provisions

1.1. processing of personal data policy of "buffer Bay" (hereinafter - the Policy) defines the procedure for the processing and protection of "buffer Bay "(hereinafter - Operator) and its affiliates of information about individuals (hereinafter - the User), which can be obtained Operator when using services provided by the User provided through the website and its subdomains lifehacker.ru * .lifehacker.ru (hereinafter - Site).

1.2. This policy is aimed at protecting the rights and freedoms of man and citizen when handling operator personal data, including on the protection of the rights to privacy, personal and family secret.

1.3. This policy was developed in accordance with the Federal Law of 27.07.2006 №152-FZ "On Personal Data" (hereinafter - the Federal Law "On Personal Data").

1.4. Policy applies to all personal information from users, operator handled using automation and without the use of such funds received, both before and after the approval of this Politicians.

1.5. The policy contains information subject to disclosure in accordance with Part. 1 tbsp. 14 of the Federal Law "On Personal Data".

1.6. Policy posted on the operator's website at: https://lifehacker.ru/privacy, It is a public document and is required to familiarize persons transferred to operator personal information through the Site.

2. Terms and Definitions

Personal Data - any information relating to a particular directly or indirectly, or determined by an individual (personal data subject).

Information - data (messages, data) regardless of their presentation.

personal data operator (Operator) - a government body, municipal body, a legal or natural person, alone or together with others, organizing and (or) performing processing of personal data as well as determining the purpose of personal data, the composition of the personal data to be processed, the action (operation) in respect of personal data.

personal data - any action (operation) or a set of actions (operations) performed with the use of automation equipment or without the use of such means with personal data, including collection, recording, accumulation, storage, clarification (update, change) extraction, use, transfer (spreading, providing access), depersonalization, blocking, deletion, destruction of personal data.

Automated processing of personal data - personal data processing by means of computing.

The provision of personal data - actions aimed at the disclosure of personal data to a certain person or a certain group of people.

Dissemination of personal data - actions aimed at the disclosure of personal data to the public.

Cross-border transfer of personal data - personal data transfer to the territory of a foreign state authority of a foreign state, a foreign person or foreign entity.

Blocking of personal data - temporary suspension of processing of personal data (except in cases where the processing is necessary to clarify the personal data).

Destruction of personal data - actions as a result of which it becomes impossible to restore the contents of the personal Data in the personal data information system and (or) as a result of which recording media are destroyed personal data.

Depersonalization of personal data - actions as a result of which it becomes impossible to use without more information to determine the personal data belonging to a particular subject of personal data.

The information system of personal data - a set contained in the databases of personal data and ensure their processing of information technologies and means.

3. the purpose of collection of personal data

3.1. In accordance with the current legislation of the Russian Federation Operator defines the purposes of processing personal data, the composition of the personal data to be processed, actions (operations) in respect of personal data, organizes and carries out the processing of personal data as well as organizes and protects the cultivated personal data.

3.2. Information about the operator:

Full name: Limited Liability Company "buffer Bay"

Abbreviated name: LLC "buffer Bay"

BIN 1087328004752, INN 7328054190, KPP 732501001

Registered office and address of the location: 432071, city Ulyanovsk, ul. Radishchev, d. 68, 3rd floor

3.3. The operator processes personal data in order to comply with the norms of the Russian legislation, including, but not limited to, the following objectives:

3.3.1. user identification;

3.3.2. directions user notifications and information related to the use of the site, the provision of services, as well as the processing of applications and user applications;

3.3.3. information about new products, special promotions and offers;

3.3.4. competitions;

3.3.5. the formation of user authentication means used by them to access private site segments;

3.3.6. of user feedback Operator Site, including obtaining from user feedback, questions on the information websites and information products of the Operator, as well as for sending them answers;

3.3.7. for other lawful purposes.

4. Legal basis of personal data

4.1. Considered in this Agreement relationships associated with the collection, storage, processing, distribution, and user information protection are regulated in accordance with the current legislation of the Russian Federation. Subjecting them to foreign law is possible only in cases stipulated by the legislation of the Russian Federation and in force for the Russian Federation, international agreements.

5. The principles, procedures and conditions for processing personal data

5.1. The operator in the activity ensures compliance of personal data processing principles set forth in Art. 5 of the Federal Law dated 27.07.2006 №152-FZ "On personal data", including:

5.1.1. law and justice and the purposes of processing personal data;

5.1.2. compliance of personal data processing goals goals predetermined and stated in the collection of personal data, as well as the powers of the Company;

5.1.3. compliance with the scope and nature of the processed personal data, methods of processing of personal data of their treatment goals;

5.1.4. reliability of personal data, their adequacy for processing purposes of non personal data, redundant with respect to the objectives stated in the collection of personal data;

5.1.5. unacceptability association created for disparate database purposes, containing personal data;

5.1.6. storage of personal data should be carried out in a form that define personal data subject for no longer than required by the purpose of processing, if the term storage of personal data is not set by the federal law, treaties to which, beneficiary or beneficiary, under which is the subject of the personal Information;

5.1.7. destruction of achieving the purposes of processing personal data or in the case of loss necessary to achieve them, unless otherwise provided by federal law.

5.2. The operator processes personal data on legitimate and fair manner to carry out their legislation functions, powers and duties of the Operator's rights and legitimate interests of workers The operator and third parties.

5.3. The operator handles the personal data of users with their consent, provides users and / or their legal representatives by committing conclusive Operator actions on the Site, including, but not limited to placing your order, registration in a private office, a subscription to the newsletter, in accordance with this Policy.

5.4. The operator handles the personal data automated and non-automated methods, with the use of computer equipment and without the use of tools.

5.5. The operator can process the following personal data of clients:

5.5.1. Full Name;

5.5.2. Address;

5.5.3. A contact telephone number;

5.5.4. E-mail address;

5.5.5. IP-address.

5.6. Actions for processing personal data include the collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (spreading, providing access), depersonalization, blocking, and removal destruction.

5.7. The operator does not check the accuracy provided by users of personal data. The operator assumes that the user provides personal data in their own interest, without intent to infringe on the rights and legitimate interests of third parties and the operator or cause them losses.

5.8. The operator and other persons who have access to personal data are obliged not to disclose to third parties not distribute personal data without the consent of the personal data subject, unless otherwise stipulated by the Federal Russian law.

5.9. The operator handles the user's personal data no longer than is required by the purpose of the processing of personal data, unless otherwise provided by the requirements of the Russian legislation.

5.10. Destruction of personal data by the Operator in a manner and time frame stipulated by the Federal Law dated 27.07.2006 №152-FZ "On personal data".

5.11. The content and volume of the processed personal data consistent with the stated purposes of the processing. Personal data are processed are not excessive in relation to the stated purposes of the processing.

6. Information about the security of personal data security

6.1. The operator in the processing of personal data shall take the necessary legal, organizational and technical measures and ensure their adoption to protect personal data against unauthorized or random access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions in respect of personal data.

6.2. security measures of personal data when they are used by the operator, planned and implemented in order to ensure compliance with the requirements set out in Article 19 of the Federal Law # 152 "On Personal data. "

6.3. In accordance with Article 18.1 of the Federal Law 152-operator determines the composition and the list of measures that are necessary and sufficient to ensure compliance with legal requirements. Operator in particular has taken the following measures:

6.3.1. Introduced local acts on the processing of personal data, as well as local acts establishing procedures aimed at preventing and detecting violations of established procedures for the processing of personal data and the elimination of the consequences such disorders;

6.3.2. subject to the legal, organizational and technical measures to ensure the security of personal data in accordance with Article 19 of Federal Law # 152;

6.3.3. Internal control is performed processing of personal data matching FZ-152 and received in accordance with this regulatory legislation, the requirements of the protection of personal data, the Operator's policy on personal data processing, local acts operator;

6.3.4. assesses the damage that can be caused to subjects personal data in the event of FL-152, the ratio of said damage and the measures taken by the operator to ensure the performance of duties, provided FZ-152;

6.3.5. Operator employees directly engaged in the processing of personal data, are familiar with the provisions of the Russian legislation on personal data, including requirements for the protection of personal data, documents, defined by the operator policy in relation to personal data processing, local acts on the processing of personal Information;

6.3.6. In addition to the requirements of 152-FZ "On personal data", the Operator carries out a complex of measures aimed at the protection of information about customers, employees and contractors.

7. Rights of subjects of personal data

7.1. personal data subject has the right:

7.1.1. to personal data relating to this subject, and information related to their treatment;

7.1.2. to clarify, blocking or destruction of his personal data if they are incomplete, outdated, inaccurate, or unlawfully obtained are not necessary for the stated purpose processing;

7.1.3. to withdraw consent to the processing of personal data by directing such request to the Operator by mail or by contacting personally;

7.1.4. to protect their legitimate rights and interests;

7.2. For realization of the rights and legitimate interests of personal data subjects have the right to apply to the operator or send a request in person or through a representative. The request must contain the information specified in para. 3 tbsp. 14 of the Federal Law "On Personal Data".

7.3. If the data subject considers that the operator carries out the processing of personal data in violation of the Federal Law requirements or otherwise violates his rights and freedom of personal data subject has the right to appeal against the acts or omissions of the Operator by contacting the authorized body for the protection of the rights of personal data subjects or in the court order.

7.4. Rights and obligations of the Operator Operator determined by the current legislation and agreements.

7.5. Comments and suggestions for changes to the policy should be directed to [email protected]. Policy is updated as needed.