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This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "Creative Digital Technologies" (hereinafter referred to as the Operator).
1.1. The Operator's most important goal and condition for carrying out its activities is to observe the rights and freedoms of man and citizen 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 referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://csg.su/.
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://csg.su/.
2.4. Personal data information system means a set of personal data contained in databases, and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data means actions as a result of which it becomes impossible to determine the ownership of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator means a state body, municipal body, legal entity 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, and the actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to a specific or identifiable User of the website https://csg.su/.
2.9. Personal data authorized by the subject of personal data for distribution means personal data to which an unlimited circle of persons has been granted access by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in accordance with the procedure provided for by the Law on Personal Data (hereinafter referred to as personal data authorized for distribution).
2.10. User means any visitor of the website https://csg.su/.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication 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. Destruction of personal data means any actions as a result of which personal data is irrevocably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3.1. The Operator has the right to:
- receive from the subject of personal data reliable information and/or documents containing personal data;
- in the event that the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and 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, upon their request, with information relating to the processing of their personal data;
- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- provide the authorized body for the protection of the rights of personal data subjects with the necessary information within 30 days from the date of receipt of such a request from this body;
- publish or otherwise provide unrestricted 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 to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
- cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Law on Personal Data;
- fulfill other duties provided for by the Law on Personal Data.
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except in cases where 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 clarify their personal data, block or destroy them 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;
- impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court the unlawful actions or inaction of the Operator when processing their personal data;
- to 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 data about themselves;
- inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.
5.1. The Operator may process the following personal data of the User:
- Last name, first name, patronymic;
- Age;
- Citizenship;
- Bank details;
- Passport data;
- Email address;
- Phone numbers;
- Address of actual place of residence and registration at the place of residence and/or place of stay.
5.2. The site also collects and processes anonymized data about visitors (including "cookie" files) using the Yandex Metrica internet statistics service.
5.3. The above data are hereinafter referred to in the Policy as Personal Data.
5.4. The Operator does not process special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.
5.5. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted provided that the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are observed.
5.6. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of their personal data. At the same time, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.6.1 The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
5.6.2 The Operator is obliged, no later than three working days from the moment of receiving the said consent from the User, to publish information about the processing conditions, about the presence of prohibitions and conditions for processing by an unlimited number of persons of personal data permitted for distribution.
5.6.3 The transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be terminated at any time upon the request of the personal data subject. This request 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 terminated. The personal data specified in this request may be processed only by the Operator to whom it is addressed.
5.6.4 Consent to the processing of personal data permitted for distribution shall terminate from the moment the Operator receives the request specified in clause 5.6.3 of this Policy regarding the processing of personal data.
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
6.3. Merging of databases containing personal data processed for purposes incompatible with each other is not permitted.
6.4. Only personal data that meet the purposes of their processing shall be subject to processing.
6.5. The content and scope of the 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 permitted.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance in relation to 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.
6.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than is required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
7.1. The purpose of processing the User's personal data:
- informing the User by sending electronic emails;
- conclusion, execution and termination of civil law contracts;
- providing the User with access to services, information and/or materials contained on the website https://csg.su/.
7.2. 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 opt out of receiving informational messages by sending the Operator an email to promotion@creativesight.group with the subject line "Unsubscribe from notifications about new products and services and special offers."
7.3. Anonymized data of Users collected using internet statistics services serves to collect information about Users' actions on the site, improve the quality of the site and its content.
8.1. The legal grounds for the processing of personal data by the Operator are:
- list the regulatory legal acts governing relations related to your activities, for example, if your activity is related to information technology, in particular to the creation of websites, then here you can specify Federal Law "On Information, Information Technologies and Information Protection" dated 27.07.2006 No. 149-FZ; Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data", Federal Law dated 07.02.1992 No. 2300-1 "On Protection of Consumer Rights" (for processing customer data), the Civil Code of the Russian Federation (for processing for the purpose of contract execution), the Tax Code of the Russian Federation (for data storage).
- the Operator's founding documents;
- contracts concluded between the operator and the personal data subject;
- federal laws and other regulatory legal acts in the field of personal data protection;
- consents of Users 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://csg.su/, or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (saving of "cookie" files and use of JavaScript technology are enabled).
8.4. The personal data subject independently makes the decision to provide their personal data and gives consent freely, of their own will and in their own interest.
9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, or a beneficiary or guarantor under which, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
9.6. Processing of personal data 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) is carried out.
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
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.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
10.2. 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 given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address promotion@creativesight.group with the subject line "Update of personal data".
10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by the contract or current legislation, but not less than 5 years from the date of the last activity. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at promotion@creativesight.group with the subject line "Withdrawal of consent to the processing of personal data".
10.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by these services (third parties) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. Prohibitions established by the personal data subject on the transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.
10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the consent period of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.
11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of 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 such transmission.
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.
13.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at promotion@creativesight.group.
13.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
13.3. The current version of the Policy is freely available on the Internet at https://csg.su/.