Policy on personal data processing

1. General provisions

This policy on processing personal data is prepared in accordance with the requirements of the law and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by papaproxy.net (hereinafter, the "Operator").

1.1 The Operator's most important goal and condition for its activities is to respect the rights and freedoms of a person and citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's personal data processing policy (hereinafter - the Policy) applies to all information that the Operator may receive about visitors to the https://papaproxy.net website.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data by means of computer technology.
2.2. Blocking of personal data - temporary termination of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as programs for computers and databases, making them available on the Internet at the network address https://papaproxy.net.
2.4. Information system of personal data is a set of personal data contained in databases of personal data, and providing information technology and technical means for its processing.
2.5. Depersonalization of personal data - actions that make it impossible to determine, without the use of additional information, whether the personal data belongs to a particular user or another subject of personal data.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data.
2.7. Operator - a state body, municipal authority, legal entity or individual, independently or together with other persons, organizing and (or) carrying out processing of personal data, as well as determining the purpose of personal data processing, 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 https://papaproxy.net website.
2.9. Personal data, authorized by the subject of personal data for distribution - personal data, access to which is provided 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 the manner prescribed by law on personal data (hereinafter - personal data, authorized for distribution).
2.10. Пользователь – любой посетитель веб-сайта https://papaproxy.net.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of people.
2.12. Dissemination of personal data - any action aimed at the disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize with personal data to an unlimited number of persons, including the publication of personal data in the media, placing in information and telecommunications networks or provide access to personal data in any other way.
2.13. Trans-border transfer of personal data - transfer of personal data to a foreign country to a foreign authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any action resulting in the destruction of personal data irretrievably with the inability to further restore the content of personal data in the information system of personal data and (or) the destruction of the material media 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 accurate information and / or documents containing personal data;
– if the subject of personal data withdraws consent to the processing of personal data, the operator has the right to continue the processing of personal data without the consent of the subject of personal data on the 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 under the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The operator is obligated to:
– provide the subject of personal data, at his request, information relating to the processing of his personal data;
– organize processing of personal data in accordance with the procedure established by applicable law of the Russian Federation;
– respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
– to inform the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receipt of such 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, distribution of personal data, as well as from other unlawful actions in relation to personal data;
– stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Law on Personal Data;
– perform other duties stipulated 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 related to processing of his/her personal data, except in cases stipulated by federal laws. Information shall be provided to the subject of personal data by the operator in an accessible form, and shall not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
– demand from the operator to clarify his personal data, block or destroy them if personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
– condition prior consent when processing personal data for the purpose of promoting goods, works and services;
– to withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of his personal data;
– to exercise other rights provided for by law.
4.2. Subjects of personal data are obliged to:
– provide the Operator with reliable data about himself/herself;
– inform the Operator about clarification (update, change) of his personal data.
4.3. persons who provided the Operator with unreliable information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the law.

5. The operator can process the following personal data of the User

5.1. Surname, first name.
5.2. E-mail.
5.3. Phone numbers.
5.4. The site also collects and processes impersonal data about visitors (including cookies) using Internet statistical services (Google Analytics and others).
5.5. The above-mentioned data hereinafter in the text of the Policy are combined under the general term Personal Data.
5.6. The operator does not process special categories of personal data related to race, ethnicity, political views, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data, authorized for dissemination, from among the special categories of personal data is allowed, if the prohibitions and conditions stipulated in the law on personal data are observed.
5.8. The User's consent to the processing of personal data authorized for distribution shall be executed separately from other consents to the processing of their personal data. The conditions stipulated by the Personal Data Law shall be observed. Requirements for the content of such consent shall be established by the authorized body for the protection of personal data subjects' rights.
5.8.1 Consent to the processing of personal data allowed for distribution, the User provides to the Operator directly.
5.8.2 The operator is obliged, within three working days of receiving the above consent from the User, to publish information about the conditions of processing, the existence of prohibitions and conditions for processing by an unlimited number of persons of personal data allowed for distribution.
5.8.3 Transfer (distribution, provision, access) of personal data, authorized by the subject of personal data for distribution, must be terminated at any time at the request of the subject of personal data. This requirement must include the surname, first name, patronymic (if any), contact information (telephone number, email address or mailing address) of the personal data subject, as well as a list of personal data, which processing is to be terminated. Personal data specified in this request may be processed only by the operator to which it is sent.
5.8.4 Consent to the processing of personal data, authorized for distribution, ceases to be valid at the moment of receipt by the Operator of the request specified in paragraph 5.8.3 of this Policy with respect to processing of personal data.

6. Principles of personal data processing

6.1. Processing of personal data is performed on a lawful and fair basis.
6.2. Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
6.4. Only personal data that meet the purposes of its processing may be processed.
6.5. The content and scope of processed personal data correspond to the stated processing purposes. Processed personal data shall not be excessive in relation to the stated purposes of its processing.
6.6. When processing personal data, the accuracy of personal data, its sufficiency and, where necessary, relevance in relation to the purpose of personal data processing shall be ensured. The operator shall take necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows identification of the subject of personal data, no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, an agreement to which the subject of personal data is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalized upon attainment of processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by the federal law.

7. Purposes of personal data processing

7.1. Purpose of processing of personal data:
– informing the User by sending e-mails;
– providing the User with access to the services, information and/or materials contained on the website https://papaproxy.net.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers and different events. The User can always refuse to receive information messages by sending a letter to the Operator to the e-mail address [email protected] with the note "Refuse notifications about new products and services and special offers"..
7.3. Anonymized User data collected through Internet statistical services is used to collect information about the actions of Users on the site, to improve the quality of the site and its content.

8. Legal basis for processing personal data

8.1. The legal basis for the processing of personal data by the operator is:
– contracts concluded between the operator and the subject of personal data;
– federal laws and other regulations in the field of personal data protection;
– Users' consent to the processing of their personal data, to the processing of personal data allowed for distribution.
8.2. The Operator processes the User's personal data only in case the User fills them in and/or sends them by himself via special forms located on the site https://papaproxy.net or sent to the Operator by e-mail. By filling in the relevant forms and/or sending his/her personal data to the Operator the User expresses his/her consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the settings of the User's browser (cookies saving and JavaScript technology usage are enabled).
8.4. The subject of personal data independently decides to provide his personal data and gives his consent freely, willingly and in his own interest.

9. Terms of personal data processing

9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
9.2. Processing of personal data is necessary to achieve the objectives set out in an international treaty of the Russian Federation or the law, to carry out the functions, powers and duties imposed on the operator by law.
9.3. Processing of personal data is necessary for the implementation of justice, execution of a judicial act, the act of another body or an official to be executed in accordance with the legislation on enforcement proceedings.
9.4. Processing of personal data is necessary to perform the contract, which party or beneficiary or guarantor under which the subject of personal data, as well as to conclude the contract on the initiative of the subject of personal data or the contract under which the subject of personal data will be a beneficiary or guarantor.
9.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially important goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Processing of personal data, access to which is provided by the subject of personal data or at his request (hereinafter - public personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for collecting, storing, transferring and other processing of personal data

Security of personal data, which are processed by the operator, is provided by implementing legal, organizational and technical measures necessary to meet in full the requirements of current legislation in the field of protection of personal data.

10.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. Personal data of the User will never, under no circumstances be transferred to third parties, except in cases related to execution of the current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
10.3. In case of detection of inaccuracies in the personal data, the user can update them independently, by sending a notice to the Operator's e-mail address [email protected] with a note "Updating of personal data"..
10.4. The term of processing of personal data is determined by achieving the purposes for which the personal data were collected, unless another term is provided by contract or applicable law.
The user may withdraw his consent to the processing of personal data at any time by sending a notice by e-mail to the Operator's e-mail address [email protected] marked "Withdrawal of consent to the processing of personal data".
10.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to get acquainted with the specified documents on his/her own in time. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.
10.6. The prohibitions established by the subject of personal data on the transfer (other than granting access), as well as on the processing or processing conditions (other than access) of personal data permitted for distribution, do not apply in cases of processing of personal data in the state, public and other public interests, defined by Russian legislation.
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 to identify the subject of personal data, no longer than required by the objectives of personal data processing, unless the period of storage of personal data is not established by federal law, the contract, a party, beneficiary or guarantor of which is the subject of personal data.
10.9. The condition for termination of personal data processing may be the achievement of the objectives of personal data processing, the expiration of the consent of the subject of personal data or withdrawal of consent by the subject of personal data, as well as the detection of unlawful processing of personal data.

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

11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
11.2. The operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.

12. Cross-border transfer of personal data

12.1. Before transborder transfer of personal data, the operator must ensure that the foreign country, to the territory of which the transfer of personal data is supposed to be carried out, provides reliable protection of the rights of personal data subjects.
12.2. Transborder transfer of personal data in foreign countries that do not meet the above requirements may be carried out only if the consent in writing of the subject of personal data on the transborder transfer of his personal data and / or performance of the contract, to which the subject of personal data is a party.

13. Confidentiality of personal data

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

14. Closing Provisions

14.1. The user can get any clarifications on questions of interest concerning the processing of his personal data, by contacting the Operator via e-mail [email protected].
14.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://papaproxy.net/docs/privacy-policy.php.