1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by JITL LLC (hereinafter — 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 individuals 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 — the Policy) applies to all information that the Operator can obtain about visitors to the website https://jitl.ru/en.2. Main 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 personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://jitl.ru
2.4. Personal data information system — a set of personal data contained in databases and providing their processing through information technologies and technical means.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data to a specific User or another 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, modification), extraction, use, transfer (distribution, provision, access), anonymization, 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 processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to a specific or identifiable User of the website https://jitl.ru
2.9. Personal data allowed by the subject of personal data for dissemination — personal data, access to which is granted by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner provided for by the Personal Data Law (hereinafter — personal data allowed for dissemination).
2.10. User — any visitor to the website https://jitl.ru
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transmission of personal data) or acquainting an unlimited circle of persons with personal data, including the disclosure of personal data in the mass 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 — transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.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 case of withdrawal of consent to the processing of personal data by the subject of personal data, as well as sending a request to cease processing of personal data, the Operator is entitled 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 provided for 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:
4. Main Rights and Obligations of Personal Data Subjects
- provide the subject of personal data with information concerning the processing of their personal data upon request;
- organize the processing of personal data in accordance with the current legislation of the Russian Federation;
- respond to inquiries 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 personal data subjects with the necessary information within 10 days from the date of receipt of such a 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 unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, and from other illegal actions concerning personal data;
- cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- fulfill other obligations provided for by the Personal Data Law.
4.1. Personal data subjects have the right to:
- receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator provides the personal data subject with information in an accessible form, which should not contain personal data related to other personal data subjects, except when 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;
- demand that the Operator update, block or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take legal measures to protect their rights;
- set a condition of preliminary consent when processing personal data for the purpose of promoting goods, works, and services in the market;
- withdraw consent to the processing of personal data, and also send a request to cease the processing of personal data;
- appeal against the Operator’s unlawful actions or inaction in processing their personal data to the authorized body for the protection of personal data subjects' rights or in court;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate information about themselves;
- inform the Operator about the updating (updating, changing) of their personal data.
4.3. Persons who provided the Operator with unreliable information about themselves or information about another personal data subject without the latter’s consent bear responsibility in accordance with the legislation of the Russian Federation.5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a legal and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. 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, sufficiency, and, when necessary, relevance of personal data concerning the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data storage is carried out in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing unless the storage period for personal data is established by federal law, a contract, a party to which, a beneficiary or guarantor of which is the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.6. Purposes of Personal Data Processing
The purpose of processing: informing the User by sending electronic emails.
Personal data: email address; phone numbers.
Legal basis: Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 N 149-FZ.
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails to the email address.7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, to carry out the functions, powers, and responsibilities entrusted by the legislation of the Russian Federation to the operator.
7.3. Personal data processing is necessary for the administration of justice, the execution of a court decision, an act of another body or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract, of which the personal data subject is a party or a beneficiary or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to protect the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data is carried out, access to an unlimited number of persons to which is provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.8. Procedure for the collection, storage, transfer, and other types of personal data processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. 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 personal data subject has consented to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address firstname.lastname@example.org
with the note "Updating personal data".
8.4. The personal data processing period is determined by achieving the goals for which personal data were collected unless another period is provided for by the contract or current legislation.
The User can withdraw their consent to personal data processing at any time by sending a notification to the Operator’s email address email@example.com
with the note "Revocation of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and
8.6. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, are not valid in cases of personal data processing in state, public, and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract, a party of which, the beneficiary, or the guarantor of which is the personal data subject.
8.9. The condition for terminating personal data processing may be the achievement of the purposes of personal data processing, the expiration of the personal data subject’s consent, the withdrawal of consent by the personal data subject or the requirement to terminate personal data processing, as well as the detection of unlawful personal data processing.9. List of actions performed by the Operator with the received personal data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without them.10. Cross-border transfer of personal data
10.1. Before starting the activities on cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights about its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject unless otherwise provided by federal law.12. Final provisions
12.1. The User can obtain any clarification on issues related to the processing of their personal data by contacting the Operator via email at firstname.lastname@example.org
12.2. This document will reflect any changes in the Operator’s personal data processing policy. The policy is in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://jitl.ru/privacy-policy