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POSITION on the protection of customer data at Zodiac LLC

APPROVED

By order of the General Director of Zodiac LLC

N 01 dated October 2, 2014

Edition 1

POSITION

on the protection of customer data at Zodiac LLC

 

Moscow city

 

1. General Provisions.

1.1. These Regulations are an official document of the Zodiac Limited Liability Company, registered at 197183, St. Petersburg, Primorsky Prospect, house 27, letter A, room 1 N (hereinafter - the Site Administration), and determines the procedure for processing and protecting information about individuals using the services of the website https://astroforyou.org (hereinafter referred to as the Site) and its services (hereinafter referred to as Users).

1.2. Relations related to the collection, storage, distribution and protection of information about users of the Site are governed by this Regulation, other official documents of the Site Administration and the current legislation of the Russian Federation.

1.3. The purpose of these Rules is to ensure adequate protection of information about users, including their personal data, from unauthorized access and disclosure.

1.4. The Regulation has been developed and used in accordance with the User Agreement posted on the Site at https://astroforyou.org/en/privacypolicy

In the event of any contradictions between this Regulation and other official documents of the Site Administration, this Regulation shall be applied.

1.5. By registering and using the Site, the User agrees with the terms of the Regulations. If the User disagrees with the terms of the Regulations, the use of the Site and its services must be terminated immediately.

1.6. The Site Administration does not verify the accuracy of the information received (collected) about users, except for cases when such verification is necessary in order to fulfill the obligations of the Site Administration to the user.

2. Procedure for putting into effect and changing the Regulations.

2.1. The Regulation comes into force from the moment of its approval by the General Director and is valid indefinitely, until it is replaced by a new Regulation.

2.2. The current version of the Regulations, which is a public document, is available to any Internet user by clicking on the link https://astroforyou.org/en/privacypolicy. The Site Administration has the right to make changes to the Regulations. When changes are made to the Regulations, notifies users of this by posting a new version on the Site at the permanent address. Previous versions of the Regulations are stored in the archive of the Site Administration documentation.

3. Conditions and purposes of personal data processing.

3.1. The Site Administration processes the user's personal data in order to fulfill the contract between the Site Administration and the User for the provision of services for the use of the Site and its services (User Agreement). By virtue of Article 6 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data", a separate user's consent to the processing of his personal data is not required. By virtue of paragraphs. 2, clause 2 of Article 22 of this law, the Site Administration has the right to process personal data without notifying the authorized body for the protection of the rights of subjects of personal data.

3.2. Providing services for the use of the Site and its services, the Site Administration, acting reasonably and in good faith, believes that the User:

has all the necessary rights to enable him to register and use this Site;

indicates reliable information about himself in the amount necessary to use the services of the Site;

understands that the information on the Site posted by the User about himself may become available to other Site Users and Internet users, may be copied and distributed by such users (i.e., is publicly available).

4. Purposes of information processing.

4.1. The Site Administration processes information about Users, including their personal data, in order to fulfill the obligations of the Site Administration to Users regarding the use of the Site and its services. 

5. Composition of personal data.

5.1. Users' personal data include:

5.1.1. unique identifier - email address;

5.1.2. additional data: name, mobile phone number, date and time of birth, gender, age, marital status, presence of children and others.

5.1.3. additionally provided by Users at the request of the Site Administration in order to fulfill the Site Administration's obligations to Users arising from the contract for the provision of Site services. The Site Administration has the right, in particular, to request from the User a copy of an identity document or other document containing the name, surname, photo of the User, as well as other additional information that, at the discretion of the Site Administration, will be necessary and sufficient to identify such User and will allow you to exclude abuse and violations of the rights of third parties.

5.2. Other information about Users processed by the Site Administration. 

The Site Administration also processes other information about Users, which includes:

5.2.1. standard data automatically received by the http server when accessing the Site and subsequent actions of the User (host IP address, type of the user's operating system, pages of the Site visited by the user);

5.2.2. information automatically obtained when accessing the Site using bookmarks (cookies); 

5.2.3. information obtained as a result of the User's actions on the Site;

5.2.4. information required to identify the User.

6. Processing information about users.

6.1. The processing of personal data is carried out on the basis of the principles:

the legality of the purposes and methods of processing personal data;

conscientiousness;

compliance of the purposes of processing personal data with the purposes predetermined and declared in the collection of personal data, as well as the powers of the Site Administration;

correspondence of the volume and nature of the processed personal data, methods of processing personal data to the purposes of processing personal data;

6.2. Collection of personal data.

6.2.1. The collection of the User's personal data is carried out on the Site during registration, as well as in the future when the user enters additional information on his own initiative in the Site toolkit.

6.3. Storage and use of personal data.

6.3.1. The personal data of Users are stored exclusively on electronic media and processed using automated systems, except for cases when manual processing of personal data is necessary in connection with the fulfillment of legal requirements.

6.4. Transfer of personal data.

6.4.1. The personal data of the Users are not transferred to any third parties, except for the cases expressly provided for by this Regulation.

6.4.2. When specifying a user or with the consent of the user, it is possible to transfer the User's personal data to third parties, contractors of the Site Administration, subject to the assumption of obligations by such counterparties to ensure the confidentiality of the information received, in particular, when using applications.

6.4.3. Applications used by Users on the Site are hosted and maintained by third parties (developers) who operate independently of the Site Administration and do not act on behalf of or on behalf of the Site Administration. Users are obliged to independently familiarize themselves with the rules for the provision of services and the personal data protection policy of such third parties (developers) before using the respective applications.

6.4.4. The provision of personal data of Users at the request of state bodies (local authorities) is carried out in the manner prescribed by law.

6.5. Destruction of personal data.

6.5.1. The user's personal data is destroyed when:

the User independently deletes data from his personal page using the "delete account" functionality available to the User using the profile settings;

removal by the Site Administration of information posted by the User, as well as the User's personal page in cases established by the User Agreement.

7. Measures to protect information about Users.

7.1. The Site Administration takes technical, organizational and legal measures in order to ensure the protection of the User's personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other illegal actions.

7.2. To authorize access to the Site, the User's login (email address or mobile phone number) and password are used. The User is responsible for the safety of this information. The user does not have the right to transfer his own username and password to third parties, and is also obliged to take measures to ensure their confidentiality.

8. Limitation of the validity of the Rules.

8.1. These Rules do not apply to the actions and Internet resources of third parties.

8.2. The Site Administration is not responsible for the actions of third parties who, as a result of using the Internet or the Site Services, have access to information about the User and for the consequences of using information that, due to the nature of the Site, is available to any Internet user.

8.3. The Site Administration recommends that Users take a responsible approach to resolving the issue of the amount of information about themselves posted on the Site.

9. User requests.

9.1. Users have the right to send their requests to the Site Administration, including requests regarding the use of their personal data in the form of an electronic document signed with a qualified electronic signature in accordance with the legislation of the Russian Federation, through the feedback form on the Site.

9.2. The request sent by the User must comply with the requirements established by the Rules for submitting requests to the Service and Support Service, namely, contain:

number of the main identity document of the user or his representative;

information about the date of issue of the specified document and the issuing authority;

information confirming the participation of the user in relations with the operator (in particular, the serial number of the user's id or a short (subdomain) name that replaces the serial number of the id);

the signature of the user or his representative.

9.3. The Site Administration undertakes to consider and send a response to the User's request within 30 days from the date of receipt of the request.