1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by Smart-solutions (the “Operator”) to ensure the security of personal data.
1.1.
The Operator’s most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy and personal and family confidentiality.
1.2.
This Policy of the Operator regarding personal data processing (the “Policy”) applies to all information that the Operator may obtain about visitors to the website http://smart-solutions-property.com/en
2. Definitions Used in the Policy
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 suspension of personal data processing, except where processing is necessary to clarify personal data.
2.3.
Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at http://smart-solutions-property.com/en
2.4.
Personal data information system means a set of personal data contained in databases, along with information technologies and technical means used for processing such data.
2.5.
Depersonalization of personal data means actions as a result of which it becomes impossible, without additional information, to determine whether personal data belongs to a specific User or another personal data subject.
2.6.
Processing of personal data means any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7.
Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of the personal data to be processed, and the actions performed with personal data.
2.8.
Personal data means any information relating directly or indirectly to an identified or identifiable User of the website http://smart-solutions-property.com/en
2.9.
Personal data permitted for distribution by the personal data subject means personal data to which an unlimited number of persons are granted access by the personal data subject by giving consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law.
2.10.
User means any visitor to the website http://smart-solutions-property.com/en
2.11.
Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12.
Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons, including publication in mass media, posting in information and telecommunications networks, or providing access by any other means.
2.13.
Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign public authority, foreign individual, or foreign legal entity.
2.14.
Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the contents of personal data in the personal data information system and/or resulting in the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
receive accurate information and/or documents containing personal data from the personal data subject;
continue processing personal data without the subject’s consent if the subject withdraws consent or submits a request to cease processing, provided there are legal grounds specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and related regulations, unless otherwise provided by law.
3.2. The Operator is obliged to:
provide the personal data subject, upon request, with information concerning the processing of their personal data;
organize personal data processing in accordance with applicable Russian law;
respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the Personal Data Law;
provide the authorized personal data protection authority with the necessary information within 10 days from receipt of such request;
publish or otherwise ensure unrestricted access to this Policy;
take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
cease transfer, provision, access, processing, and destruction of personal data in the cases and manner prescribed by the Personal Data Law;
perform other duties established by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
receive information concerning the processing of their personal data, except in cases provided by federal laws;
request clarification, blocking, or destruction of their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purpose;
require prior consent when personal data is processed for the promotion of goods, works, and services;
withdraw consent to personal data processing and submit a request to cease processing;
appeal unlawful actions or omissions of the Operator to the authorized personal data protection authority or in court;
exercise other rights provided by Russian law.
4.2. Personal data subjects are obliged to:
provide the Operator with accurate data about themselves;
notify the Operator of any clarification, update, or change to their personal data.
4.3.
Persons who provide the Operator with false information about themselves, or information about another personal data subject without that subject’s consent, bear liability under Russian law.
5. Principles of Personal Data Processing
5.1.
Personal data shall be processed lawfully and fairly.
5.2.
Processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing that is incompatible with the purposes of data collection is not permitted.
5.3.
Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4.
Only personal data that corresponds to the purposes of its processing shall be processed.
5.5.
The content and scope of processed personal data must correspond to the stated purposes of processing. Excessive processing in relation to the stated purposes is not permitted.
5.6.
When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7.
Personal data shall be stored in a form allowing identification of the personal data subject for no longer than required by the purposes of processing, unless a longer storage period is established by federal law or contract. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or in case the need to achieve these purposes ceases, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
The purpose of processing is to inform the User by sending emails and/or messages via messengers.
The personal data processed may include:
last name, first name, patronymic;
email address;
phone numbers;
city of residence.
Legal basis
Personal data is processed on the basis of the User’s consent in accordance with Federal Law No. 152-FZ of the Russian Federation “On Personal Data” dated July 27, 2006.
Purpose of use
The data is processed solely for the purpose of informing the User about the company’s products, services, and promotions by sending emails and/or messages through messengers. The User has the right to withdraw consent to personal data processing at any time by sending written notice to the company.
Types of personal data processing
collection;
recording;
systematization;
accumulation;
storage;
destruction;
depersonalization of personal data;
sending informational emails to an email address;
sending informational emails and messenger messages to a mobile phone number.
7. Conditions of Personal Data Processing
7.1.
Personal data shall be processed with the consent of the personal data subject.
7.2.
Processing is permitted where necessary to achieve purposes provided by an international treaty of the Russian Federation or law, and for the exercise of functions, powers, and duties imposed on the Operator by Russian law.
7.3.
Processing is permitted where necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to enforcement under Russian law on enforcement proceedings.
7.4.
Processing is permitted where necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, or for entering into a contract at the initiative of the personal data subject.
7.5.
Processing is permitted where necessary for the exercise of rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6.
Processing is permitted for personal data to which the subject has granted access to an unlimited number of persons, or upon the subject’s request, where such data becomes publicly available.
7.7.
Processing is permitted for personal data subject to publication or mandatory disclosure under federal law.
8. 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 applicable personal data protection legislation.
8.1.
The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2.
The User’s personal data will never be transferred to third parties under any circumstances, except where required by applicable law or where the personal data subject has given consent for transfer to a third party for the performance of obligations under a civil law contract.
8.3.
If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator at privacy@smart-solutions-property.com marked “Personal Data Update.”
8.4.
The period of personal data processing is determined by achievement of the purposes for which the personal data was collected, unless a different period is provided by contract or applicable law. The User may withdraw consent at any time by sending a notification to privacy@smart-solutions-property.com marked “Withdrawal 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 such persons (Operators) in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of such third parties, including the service providers referred to in this clause.
8.6.
Restrictions established by the personal data subject on transfer, processing, or conditions of processing of personal data permitted for distribution do not apply in cases of processing carried out in state, public, or other public interests determined by Russian law.
8.7.
When processing personal data, the Operator ensures the confidentiality of personal data.
8.8.
The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless a longer period is established by federal law or contract.
8.9.
Grounds for terminating personal data processing may include achievement of the processing purposes, expiry of the subject’s consent, withdrawal of consent, a request to cease processing, or detection of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1.
The Operator performs 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 receipt and/or transfer of information via information and telecommunications networks, or without such transfer.
10. Cross-Border Transfer of Personal Data
10.1.
Before commencing cross-border transfer of personal data, the Operator must notify the authorized personal data protection authority of its intention to carry out such transfer. This notification is submitted separately from the notification of intent to process personal data.
10.2.
Before submitting such notification, the Operator must obtain relevant information from foreign public authorities, 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 or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions12.1.
The User may obtain any clarifications on matters concerning the processing of personal data by contacting the Operator via email at privacy@smart-solutions-property.com.
12.2.
Any changes made by the Operator to this personal data processing policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
12.3.
The current version of the Policy is publicly available on the Internet at:
https://smart-solutions-property.com/privacy2