Personal Data Privacy Policy



1. General Provisions
This Personal Data Privacy Policy has been adopted in accordance with the requirements of the Federal Law of 27 July 2006 N 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the personal data processing procedure and measures to ensure the security of personal data taken by Grebenkina N.V. (hereinafter referred to as the Operator).
1.1. The operator sets as her most important goal and condition for the implementation of her activities the observance of the protection of a person's rights and liberties while processing his/her personal data, including the right to privacy, personal and family secrecy.
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 shall receive about visitors to the website https://rehabinsider.ru.
2. Basic concepts used in the Policy
2.1. Automated personal data processing – personal data processing by means of computer technology.
2.2. Blocking of personal data – the temporary cessation of personal data processing (except for the cases when the processing is needed for personal data specification.
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://rehabinsider.ru 
2.4. Personal data information system – a database that contains personal data as well as information technologies and hardware used for data processing.
2.5. Anonymization of personal data – actions performed on personal data that do not permit the identity of the individual concerned to be verified solely from such anonymized data.
2.6. Personal data processing – any action (operation) or a combination of actions (operations) performed both automatically and manually with personal data, including collection, recording, arrangement, accumulation, storage, specification (updating, changing), extraction, use, distribution (including transfer), anonymizing, blocking and destruction of personal data.
2.7. Operator – a state agency, municipal authority, legal entity or individual who independently or in cooperation with other entities organizes and (or) processes personal data as well as determines the purposes and scope of personal data processing.
2.8. Personal data – any information referring directly or indirectly to a particular or identified User of the website https://rehabinsider.ru
2.9. Personal data authorized by the subject of personal data for dissemination – personal data accessed by an unlimited number of persons to which it is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data allowed for dissemination).
2.10. User – any visitor to the website https://rehabinsider.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Distribution of personal data – actions related to making the data available to indefinite range of persons including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way. 
2.13. Cross-border transfer of personal data – cross-border transfer of personal data to a foreign state agency, foreign legal entity or individual located in a foreign state.
2.14. Destruction of personal data – actions performed on personal data contained in the respective database that prevent such data from being restored and (or) actions aimed at the physical destruction of the tangible medium of personal data.
3. Basic 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 a personal data subject withdraws his consent to the processing of personal data, the operator shall have the right to continue the processing of personal data without the consent of the personal data subject if any of the grounds set in the Law on Personal Data;
- to independently determine the composition and list of measures, not necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator is obliged:
- to provide the subject of personal data with information regarding the processing of his personal data at his request;
- to organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
- to respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- to report the necessary information to the authorized body for the protection of the rights of subjects of personal data upon the request of this body within 30 days from the date of receipt of such request;
- to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
- to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision or dissemination of personal data or in other unlawful actions in connection with the processing of those personal data;
- to stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- to perform other duties provided for by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Subjects of personal data have the right:
- to receive information regarding the processing of his personal data, except in cases provided by federal laws. The information is provided to the personal data subject by an operator in an accessible form, and shall not contain personal data relating to other data subjects, except where there are lawful grounds for the disclosure of such personal data;
- to request an operator to rectify, block or destroy his personal data in the event that the personal data are incomplete, out-of-date, inaccurate or unlawfully obtained or are not needed for the stated purpose of the processing, and shall have the right to take measures provided for by law to protect his rights;
- to put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
- to withdraw consent to the processing of personal data;
- to 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 his personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged:
- to provide the Operator with reliable personal data;
- to inform the Operator about the specification (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 are liable in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User:
5.1. Full Name.
5.2. Email address.
5.3. Phone numbers.
5.4. The site also collects and processes anonymous data about visitors (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics and others).
5.5. The above data are united and referred to as the general concept of Personal data further in the text of the Policy.
5.6. Processing of special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or sexual life is not carried out by the Operator.
5.7. The processing of the special categories of personal data referred to in part 1 of Art. 10 of the Law on Personal Data is permitted if the prohibitions and conditions provided in Art. 10.1 of the Personal Data Law are met. 
5.8. The User's consent to the processing of personal data permitted for dissemination is issued separately from other consents to the processing of his personal data. At the same time, the conditions stipulated, in particular, by Article 10 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.8.1 The User provides the consent to the processing of personal data permitted for dissemination to the Operator directly. 
5.8.2 The Operator is obliged to publish information on the conditions of processing, on the existence of prohibitions and conditions for processing of personal data permitted for dissemination by unlimited circle of persons no later than three working days from the date of receipt of the specified consent of the User.
5.8.3 The transfer (dissemination, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time upon the request of the subject of personal data. This requirement should include the last name, first name, patronymic (if any), contact information (phone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request can be processed only by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data permitted for distribution terminates from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of personal data processing
6.1. Personal data shall be processed on a legal and equitable basis.
6.2. Personal data processing shall be restricted by achieving specific pre-determined and legal purposes. It is not allowed to process personal data for the purpose incompatible with that one of personal data collection.
6.3. It is not allowed to combine the data bases containing personal data to be processed for incompatible purposes.
6.4. There shall be processed only personal data that comply with the purposes of their processing.
6.5. The scope and character of personal data to be processed shall comply with the intended purposes of such data processing. The personal data to be processed shall not be irrelevant to the declared purposes of their processing.
6.6. In the course of personal data processing it shall be necessary to ensure the personal data accuracy, their sufficiency and in case of need their adequacy for processing purposes. Operators shall take the required measures or ensure their adoption to delete or specify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows verification of the identity of personal data subjects only to the extent necessary for processing purposes unless the personal data storage time is not established by federal laws, agreements concluded with personal data subjects as a beneficiary or guarantor party. Personal data shall be destroyed or depersonalized upon achieving the set goals as well as when such goals cease to be relevant unless otherwise stipulated by federal law.
7. Purposes of personal data processing
7.1. The purpose of processing the User's personal data:
– informing the User by sending e-mails;
– conclusion, execution and termination of civil law contracts;
– providing the User with access to the services, information and/or materials contained on the website https://rehabinsider.ru
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator to the e-mail address rehabinsider@yandex.ru marked "Refusal to receive notifications about new products and services and special offers".
7.3. Anonymized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.
8. Legal grounds for the processing of personal data
8.1. The legal grounds for the personal data processing by the Operator are:
- Federal Law No. 323-FZ of 21 November 2011 on Basics of Health Protection of the Citizens in the Russian Federation as amended to 29 December 2015;
- statutory documents of the Operator;
- agreements concluded between the operator and the subject of personal data;
- federal laws, other regulatory legal acts in the field of personal data protection;
- Users' consent to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://rehabinsider.ru or sent to the Operator by e-mail. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses his consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (saving cookies and using JavaScript technology is enabled).
8.4. The subject of personal data independently decides to provide his personal data and gives consent freely, of his own free will and in his own interest.
9. Conditions of Personal Data Processing
9.1. The processing of personal data is carried out with the consent of the data subject to the processing of his personal data.
9.2. The personal data processing is required for achieving the purposes stipulated by an international agreement of the Russian Federation or by a law, or for exercise and fulfillment of functions, powers and obligations imposed on operators by the Russian Federation law.
9.3. The personal data processing is required for administration of justice or enforcement of a judicial act or an act of another body or official which are enforceable in accordance with the legislation of the Russian Federation concerning enforcement proceedings (hereinafter referred to as “enforcement of a judicial act).
9.4. The personal data processing is required for performance of an agreement to which a personal data subject is a party or under which the data subject is a beneficiary or surety, or for conclusion of an agreement on the initiative of a personal data subject or an agreement under which a personal data subject shall be a beneficiary or surety.
9.5. The processing of personal data is required for realization of the rights and legitimate interests of an operator or third parties or for the attainment of socially significant objectives, provided that this shall not cause the rights and freedoms of the personal data subject to be violated.
9.6. The public access to the personal data being processed shall be granted by or at the request of the personal data subject (hereinafter referred to as “personal data made public by the personal data subject”).
9.7. The personal data being processed are subject to publication or compulsory disclosure in accordance with federal laws.
10. The procedure for collecting, storing, transferring and other types of processing of personal data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures that are necessary and sufficient to ensure the fulfillment of the obligations laid down in the 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 exclude access to personal data of unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's e-mail address rehabinsider@yandex.ru marked "Updating personal data".
10.4. The term for the personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the contract or applicable law.
The User may withdraw his consent to the processing of his personal data by sending a notification to the Operator by e-mail to the Operator's email address rehabinsider@yandex.ru marked "Withdrawal of consent to the personal data processing".
10.5. All information that is collected by third-party services, including payment systems, means of communication 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 the specified 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. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, social and other public interests determined by the laws of Russian Federation.
10.7. The operator, when processing personal data, ensures the confidentiality of personal data.
10.8. Personal data shall be stored in a form that allows verification of the identity of personal data subjects only to the extent necessary for processing purposes unless the personal data storage time is not established by federal laws, agreements concluded with personal data subjects as a beneficiary or guarantor party. 
10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, 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 the received personal data
11.1. The operator collects, records, arranges, accumulates, stores, specifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes and destroys personal data.
11.2. The operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.
12. Cross-border transfer of personal data
12.1. An operator shall be obliged to satisfy itself that the foreign state into whose territory personal data are to be transferred provides adequate protection of the personal data subjects’ rights before commencing the cross-border transfer of personal data.
12.2. The cross-border transfer of personal data into the territories of foreign states which do not provide an adequate protection of the personal data subjects’ rights may be carried out only if the personal data subject has given his/her consent to the cross-border transfer of his/her personal data and/or the performance of a contract to which the personal data subject is a party.
13. Confidentiality of Personal Data
Operators and other persons who have obtained an access to personal data shall be obliged to refrain from disclosing to third parties or disseminating those personal data without the consent of the personal data subject, except as otherwise provided by federal laws. 
14. Final provisions
14.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail rehabinsider@yandex.ru.
14.2. This document will reflect any changes in the policy of processing personal data by the Operator. 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://rehabinsider.ru.
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