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Privacy Policy

Personal Data Processing Policy

1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "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 undertaken by LLC "RBI Concept" (hereinafter - the Operator).

  1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including protection of rights to privacy, personal and family secrets.
  2. This Operator's policy regarding personal data processing (hereinafter - the Policy) applies to all information that the Operator may receive about visitors to the website rbiconcept.ru.

2. Basic concepts used in the Policy

  1. Automated processing of personal data - processing of personal data using computer equipment.
  2. Blocking of personal data - temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
  3. Website - a collection of graphic and informational materials, as well as computer programs and databases that ensure their accessibility on the internet at the network address rbiconcept.ru.
  4. Personal data information system - a collection of personal data contained in databases and information technologies and technical means that ensure their processing.
  5. Depersonalization of personal data - actions as a result of which it is impossible to determine the ownership of personal data to a specific User or other personal data subject without using additional information.
  6. Processing of personal data - any action (operation) or 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), depersonalization, blocking, deletion, destruction of personal data.
  7. Operator - a state body, municipal body, legal entity or individual who independently or jointly with other persons organizes and (or) carries out processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
  8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website rbiconcept.ru.
  9. Personal data permitted by the personal data subject for distribution - personal data to which access by an unlimited number of persons is provided by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided by the Personal Data Law (hereinafter - personal data permitted for distribution).
  10. User - any visitor to the website rbiconcept.ru.
  11. Provision of personal data - actions aimed at disclosing personal data to a specific person or specific group of persons.
  12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
  13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.
  14. Destruction of personal data - any actions as a result of which personal data is destroyed irreversibly with the impossibility of further restoration of the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

  1. The Operator has the right to:
    • receive reliable information and/or documents containing personal data from the personal data subject;
    • in case of withdrawal of consent for personal data processing by the personal data subject, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
    • independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations provided 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.
  2. The Operator is obliged to:
    • provide the personal data subject with information regarding the processing of their personal data upon request;
    • organize personal data processing in the manner established by the current legislation of the Russian Federation;
    • respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
    • report to the authorized body for protection of personal data subjects' rights upon request of this body the necessary information within 30 days from the date of receipt of such request;
    • publish or otherwise provide unlimited access to this Personal Data Processing Policy;
    • take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
    • cease transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided by the Personal Data Law;
    • fulfill other obligations provided by the Personal Data Law.

4. Basic rights and obligations of personal data subjects

  1. Personal data subjects have the right to:
    • receive information regarding the processing of their personal data, except for cases provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects, except for cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
    • require the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
    • put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services in the market;
    • withdraw consent for personal data processing;
    • appeal to the authorized body for protection of personal data subjects' rights or in 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.
  2. Personal data subjects are obliged to:
    • provide the Operator with reliable data about themselves;
    • inform the Operator about clarification (updating, modification) of their personal data.
  3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

  1. Last name, first name, patronymic.
  2. Email address.
  3. Phone numbers.
  4. Also, the site collects and processes depersonalized data about visitors (including "cookie" files) using internet statistics services (Yandex Metrica and Google Analytics and others).
  5. The above-mentioned data hereinafter in the text of the Policy are combined by the general concept of Personal data.
  6. Processing of special categories of personal data concerning racial, ethnic origin, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
  7. Processing of personal data permitted for distribution from among special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.
  8. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of their personal data. At the same time, the conditions provided, in particular, by Article 10.1 of the Personal Data Law are observed. Requirements for the content of such consent are established by the authorized body for protection of personal data subjects' rights.
    • The User provides consent for processing personal data permitted for distribution to the Operator directly.
    • The Operator is obliged to publish information about processing conditions, about the existence of prohibitions and conditions for processing by an unlimited number of persons of personal data permitted for distribution no later than three working days from the moment of receiving the specified consent from the User.
    • Transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be stopped at any time at the request of the personal data subject. This requirement must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be stopped. The personal data specified in this requirement may be processed only by the Operator to whom it is directed.
    • Consent for processing personal data permitted for distribution ceases to be valid from the moment the Operator receives the requirement specified in clause 5.8.3 of this Policy regarding personal data processing.

6. Principles of personal data processing

  1. Personal data processing is carried out on a legal and fair basis.
  2. Personal data processing is limited to achieving specific, predetermined and legal purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
  3. Combining databases containing personal data whose processing is carried out for purposes incompatible with each other is not allowed.
  4. Only personal data that meets the purposes of their processing is subject to processing.
  5. The content and scope 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.
  6. When processing personal data, the accuracy of personal data, their sufficiency, and when necessary, relevance in relation to the purposes of personal data processing is ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
  7. Storage of personal data is carried out in a form that allows determining the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achieving processing goals or in case of loss of necessity to achieve these goals, unless otherwise provided by federal law.

7. Purposes of personal data processing

  1. The purpose of processing the User's personal data:
    • to establish feedback.
  2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending the Operator a letter to the email address info@rbiconcept.ru with the note "Refusal of notifications about new products and services and special offers".
  3. Depersonalized data of Users collected using internet statistics services serve to collect information about Users' actions on the site, improve the quality of the site and its content.
  1. The legal grounds for personal data processing by the Operator are:
    • charter (founding) documents of the Operator;
    • contracts concluded between the operator and the personal data subject;
    • federal laws, other regulatory legal acts in the field of personal data protection;
    • Users' consent to processing their personal data, to processing personal data permitted for distribution.
  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 site rbiconcept.ru or sent to the Operator via email. By filling in the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
  3. The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (saving "cookie" files and using JavaScript technology is enabled).
  4. The personal data subject independently decides on providing their personal data and gives consent freely, by their will and in their interest.

9. Conditions for personal data processing

  1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
  2. Personal data processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, to exercise functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
  3. Personal data processing is necessary for the administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
  4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for concluding 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.
  5. Personal data processing is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
  6. Processing of personal data is carried out to which access by an unlimited number of persons is provided by the personal data subject or at their request (hereinafter - publicly available personal data).
  7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured through 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.

  1. The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
  2. The User's personal data will never, under any circumstances, be transferred to third parties, except for cases related to the execution of current legislation or in case the personal data subject has given consent to the Operator to transfer data to a third party for fulfilling obligations under a civil law contract.
  3. In case of identifying inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address info@rbiconcept.ru with the note "Personal data update".
  4. The period of personal data processing is determined by achieving the purposes for which personal data was collected, unless another period is provided by contract or current legislation. The User may at any time withdraw their consent to personal data processing by sending the Operator a notification via email to the Operator's email address info@rbiconcept.ru with the note "Withdrawal of consent to personal data processing".
  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 Privacy Policy. The personal data subject and/or User is obliged to independently and timely familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
  6. Prohibitions established by the personal data subject on transfer (except for providing access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public and other public interests defined by the legislation of the Russian Federation.
  7. The Operator ensures confidentiality of personal data when processing personal data.
  8. The Operator stores personal data in a form that allows determining the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract to which the personal data subject is a party, beneficiary or guarantor.
  9. The condition for terminating personal data processing may be achieving the purposes of personal data processing, expiration of the consent of the personal data subject or withdrawal of consent by the personal data subject, as well as identification of unlawful personal data processing.

11. List of actions performed by the Operator with received personal data

  1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
  2. The Operator carries out automated processing of personal data with receiving and/or transmitting the received information via information and telecommunication networks or without such.

12. Cross-border transfer of personal data

  1. Before starting cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory personal data transfer is intended to be carried out provides reliable protection of personal data subjects' rights.
  2. Cross-border transfer of personal data to territories of foreign states that do not meet the above requirements may be carried out only in case of written consent of the personal data subject to cross-border transfer of their personal data and/or performance of a contract to which the personal data subject is a party.

13. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final provisions

  1. The User can receive any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email info@rbiconcept.ru.

  2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.

  3. The current version of the Policy is freely available on the Internet at https://rbiconcept.ru/privacy/.