Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Khlaponin Igor Grigorievich (hereinafter — the Operator).
1.1.
The Operator considers the observance of the rights and freedoms of man and citizen during the processing of his personal data, including the protection of the rights to privacy, personal and family secrets, to be its primary goal and condition for carrying out its activities.
1.2.
This Operator’s policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://clutch.llc/.
2. Basic Terms 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 when processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the address https://clutch.llc/.
2.4. Personal data information system — a set of personal data contained in databases and the technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible, without using additional information, to determine the belonging of personal data to a specific User or other 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 such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://clutch.llc/.
2.9. Personal data authorized by the subject of personal data for dissemination — personal data access to which is provided by the subject of personal data by giving consent to process such personal data in the manner prescribed by the Personal Data Law (hereinafter — personal data authorized for dissemination).
2.10. User — any visitor to the website https://clutch.llc/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or familiarizing with personal data by an unlimited group of persons, including publishing personal data in the media, placing them 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in case the subject of personal data withdraws consent to the processing of personal data or sends a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the subject 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:
— provide the subject of personal data, at his request, with information relating to the processing of his personal data;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to requests and inquiries 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 subjects of personal data, at its request, with the necessary information within 10 days from the date of receiving such request;
— publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
— stop transferring (disseminating, providing, granting access to) 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. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— receive information relating to the processing of their personal data, except in cases provided for by federal laws. Such information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
— impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as send a request to stop the processing of personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or to a court against unlawful actions or inaction of the Operator when processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about clarification (updating, changing) of their personal data.
4.3. Persons who provided the Operator with false 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. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful 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 collecting personal data is not permitted.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
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. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, a contract, a party to which, a beneficiary or guarantor under which is the subject of personal data. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if there is no longer a need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails.
Personal data:
— last name, first name, patronymic
— email address
— phone numbers
Legal grounds:
Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ of 27.07.2006
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 is processed with the consent of the subject of personal data to process his personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, an act of another body or official subject to execution 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 to which the subject of personal data is a party, or a beneficiary or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data made publicly available by the subject of personal data or at his request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by the implementation of 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 exclude 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 compliance with current legislation or if the subject of personal data has given the Operator consent to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address ceo.clutchcrm@gmail.com marked “Updating personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected unless another period is provided for by the contract or current legislation. The User may revoke consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator’s address ceo.clutchcrm@gmail.com marked “Revocation of consent to personal data processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data must independently familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including those specified in this paragraph of service providers.
8.6. Restrictions set by the subject of personal data on transfer (except granting access), as well as on processing or conditions of processing (except access provision) of personal data authorized for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined 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 allowing identification of the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, a contract, a party to which, a beneficiary or guarantor under which is the subject of personal data.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of processing personal data, expiration of the subject’s consent, revocation of consent by the subject of personal data, a request to stop processing personal data, or identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such means.
10. Cross-Border Transfer of Personal Data
10.1. Before starting cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border 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 or 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 receive any clarifications on issues related to the processing of his personal data by contacting the Operator via email at ceo.clutchcrm@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced with a new version.
12.3. The current version of the Policy is freely available on the Internet at https://clutch.llc/privacy.
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Khlaponin Igor Grigorievich (hereinafter — the Operator).
1.1.
The Operator considers the observance of the rights and freedoms of man and citizen during the processing of his personal data, including the protection of the rights to privacy, personal and family secrets, to be its primary goal and condition for carrying out its activities.
1.2.
This Operator’s policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://clutch.llc/.
2. Basic Terms 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 when processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the address https://clutch.llc/.
2.4. Personal data information system — a set of personal data contained in databases and the technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible, without using additional information, to determine the belonging of personal data to a specific User or other 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 such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://clutch.llc/.
2.9. Personal data authorized by the subject of personal data for dissemination — personal data access to which is provided by the subject of personal data by giving consent to process such personal data in the manner prescribed by the Personal Data Law (hereinafter — personal data authorized for dissemination).
2.10. User — any visitor to the website https://clutch.llc/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or familiarizing with personal data by an unlimited group of persons, including publishing personal data in the media, placing them 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in case the subject of personal data withdraws consent to the processing of personal data or sends a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the subject 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:
— provide the subject of personal data, at his request, with information relating to the processing of his personal data;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to requests and inquiries 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 subjects of personal data, at its request, with the necessary information within 10 days from the date of receiving such request;
— publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
— stop transferring (disseminating, providing, granting access to) 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. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— receive information relating to the processing of their personal data, except in cases provided for by federal laws. Such information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
— impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as send a request to stop the processing of personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or to a court against unlawful actions or inaction of the Operator when processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about clarification (updating, changing) of their personal data.
4.3. Persons who provided the Operator with false 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. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful 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 collecting personal data is not permitted.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
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. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, a contract, a party to which, a beneficiary or guarantor under which is the subject of personal data. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if there is no longer a need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails.
Personal data:
— last name, first name, patronymic
— email address
— phone numbers
Legal grounds:
Federal Law “On Information, Information Technologies and Information Protection” No. 149-FZ of 27.07.2006
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 is processed with the consent of the subject of personal data to process his personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, an act of another body or official subject to execution 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 to which the subject of personal data is a party, or a beneficiary or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data made publicly available by the subject of personal data or at his request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by the implementation of 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 exclude 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 compliance with current legislation or if the subject of personal data has given the Operator consent to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address ceo.clutchcrm@gmail.com marked “Updating personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected unless another period is provided for by the contract or current legislation. The User may revoke consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator’s address ceo.clutchcrm@gmail.com marked “Revocation of consent to personal data processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data must independently familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including those specified in this paragraph of service providers.
8.6. Restrictions set by the subject of personal data on transfer (except granting access), as well as on processing or conditions of processing (except access provision) of personal data authorized for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined 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 allowing identification of the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, a contract, a party to which, a beneficiary or guarantor under which is the subject of personal data.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of processing personal data, expiration of the subject’s consent, revocation of consent by the subject of personal data, a request to stop processing personal data, or identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such means.
10. Cross-Border Transfer of Personal Data
10.1. Before starting cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border 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 or 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 receive any clarifications on issues related to the processing of his personal data by contacting the Operator via email at ceo.clutchcrm@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced with a new version.
12.3. The current version of the Policy is freely available on the Internet at https://clutch.llc/privacy.
