RU

Policy on personal data processing

This Personal Data Processing Policy is prepared in accordance with the requirements of the Federal Law dated July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and the Law on Personal Data. No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and defines the procedure of personal data processing and measures taken by Proton Jetton (hereinafter referred to as the Operator) to ensure personal data security.

1.1 The Operator's main goal and condition of its activity is to observe the rights and freedoms of a person and a citizen when processing his/her personal data, including protection of the rights to privacy, personal and family secrecy.
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 ProtonJetton.com website.

2. Basic concepts used in the Policy

2.1 Automated processing of personal data  processing of personal data with the help of computer hardware.
2.2 Blocking of personal data  - temporary cessation of personal data processing (with the exception of cases when processing is necessary to clarify personal data).
2.3 The website  is a set of graphic and informational materials, as well as computer programs and databases that make them available on the Internet at the ProtonJetton.com address.
2.4 The information system of personal data  a set of personal data contained in  databases and  information technologies and  technical means ensuring their processing.
2.5. Depersonalization of personal data  actions, as a result of which it is impossible to determine without using additional information whether personal data belong to a particular User or other subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of means of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and/or carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8 Personal data - any information relating directly or indirectly to a specific or identifiable User of the ProtonJetton.com website.
2.9. Personal data authorized by the subject of personal data for dissemination   personal data to which the subject of personal data has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data authorized for dissemination).
2.10. User - any visitor of the ProtonJetton.com website.
2.11. Provision of personal data - any actions aimed at  disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at  disclosure of personal data to an indefinite number of persons (transfer of personal data) or at  familiarization with  personal data of an unlimited number of persons, including disclosure of personal data in  mass media, placement in  information and telecommunication networks or providing access to  personal data in any other way.
2.13. Trans-border transfer of personal data  the transfer of personal data to the territory of a foreign country to a foreign government body, foreign individual or foreign legal entity.
2.14. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery 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

3.1 The Operator shall have the right to:

— Receive accurate information and/or documents containing personal data from the personal data subject;

— If the subject of personal data withdraws his/her consent to the processing of personal data, as well as if he/she submits a request to stop 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 Personal Data Law;

— Independently determine the composition and the list of measures necessary and sufficient to ensure fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with the Law on Personal Data, unless otherwise stipulated by the Law on Personal Data or other federal laws.

3.2 The Operator shall:

— Provide the personal data subject, upon his/her request, with information regarding the processing of his/her personal data;

— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

— Respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— To inform the authorized body for the protection of the rights of personal data subjects at the request of this body within 10 days from the date of receipt of such request;

— Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

— To take legal, organizational and technical measures to protect personal data from unlawful or accidental access to personal data, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;

— Stop transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases stipulated by the Law on Personal Data;

— To fulfill other obligations stipulated by the Law on Personal Data.

4.1. Personal data subjects have the right to:

— Receive information related to the processing of his/her personal data, with the exception of cases stipulated by federal laws. The 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 for cases when there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;

— To demand from the operator to clarify his personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his rights;

— To 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, as well as to send a request to stop the processing of personal data;

— To appeal to the authorized body for the protection of the rights of personal data subjects or to the court against unlawful acts or omissions of the Operator in the processing of his/her 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 true data about himself;

— Notify the Operator about clarification (update, change) of his/her personal data.

4.3. Persons who have passed to the Operator false information about themselves or information about another subject of personal data without the consent of the latter shall be held liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1 The processing of personal data shall be carried out on a lawful and fair basis.
5.2 The processing of personal data shall be limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3 Databases containing personal data processed for incompatible purposes shall not be merged.
5.4 Only personal data that meet the purposes of their processing shall be processed.
5.5 The content and scope of processed personal data correspond to the stated purposes of processing. The processed personal data shall not be redundant in relation to the stated purposes of their processing.
5.6 When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, their relevance to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
5.7 Personal data shall be stored in a form that allows identification of the subject of personal data for no longer than required for the purposes of personal data processing, unless the period of storage of personal data is established by federal law, a contract to which the subject of personal data is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalized upon completion of the purposes of processing or in case of loss of necessity in achieving these purposes, unless otherwise provided for by federal law.

6. Purposes of personal data processing

Purpose of processing:

— All possible options

Personal Data:

— Surname, first name, patronymic

— Email

— Phone numbers

— Year, month, date and place of birth

— Photos

— All possible options

Legal Basis:

— Charter (constituent) documents of the Operator

— Contracts concluded between the operator and the subject of personal data

— All possible options

Types of personal data processing:

— Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

— Sending newsletters to the e-mail address

— All possible options

— Certificate of citizenship   citizenship

— Details of the identity document

— Identification number of the taxpayer, date of its registration with the tax authority, details of the certificate of registration with the tax authority

— Number of compulsory pension insurance certificate, date of registration in the compulsory pension insurance system

— Number of compulsory health insurance policy

— Address of actual place of residence and registration at place of residence and/or at place of stay

— Information about education, profession, specialty and qualification, details of education documents

— Information about the family status and composition of the family

— Information on the property status of the following persons

— Information on income

— Information on indebtedness

— Information on previous positions and work experience, military duty, military registration, and military registration

7. Conditions of personal data processing

7.1 Processing of personal data shall be carried out with the consent of the personal data subject to the processing of his/her personal data.
7.2 Processing of personal data is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or by law, to fulfill the functions, powers and duties imposed by the legislation of the Russian Federation on the Operator.
7.3 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.
7.4 The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of 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.
7.5 The processing of personal data is necessary for the exercise of the rights and legal interests of the operator or third parties or for the achievement of socially important purposes, provided that the rights and freedoms of the personal data subject are not infringed.
7.6 Processing of personal data to which an unlimited number of persons have access by the subject of personal data or at his/her request (hereinafter referred to as publicly available personal data).
7.7 Personal data subject to publication or mandatory disclosure in accordance with the federal law shall be processed.

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

Security of personal data processed by the Operator shall be ensured by implementing legal, organizational and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.

8.1 The Operator shall ensure the safety of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.
8.2 The User's personal data will never, under no circumstances, be transferred to third parties, except in cases related to the execution of the applicable law or in the event that the subject of personal data has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
8.3 In case of identifying inaccuracies in the personal data, the User may update them independently by sending a notice to the Operator to the Operator's e-mail address protonjetton@gmail.com with the note "Personal Data Update".
8.4 The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is stipulated by the contract or the current legislation.
The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address protonjetton@gmail.com with the note "Withdrawal of consent to the processing of personal data".
8.5 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. Personal Data Subject and/or with the said documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6 Prohibitions established by the subject of personal data on the transfer (except for access), as well as on the processing or conditions of processing (except for access) of personal data authorized for dissemination shall not apply in cases of personal data processing in the state, public and other public interests defined by the legislation of the Russian Federation.
8.7 The Operator shall ensure confidentiality of personal data when processing personal data.
8.8 The Operator shall store personal data in a form that allows identification of the subject of personal data for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.9 The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject or a request for termination of personal data processing, as well as detection of unlawful processing of personal data.

9. List of actions to be performed by the Operator with the received personal data

9.1 The Operator shall collect, record, systematize, accumulate, store, update (update, change), retrieve, use, transfer (disseminate, provide, access), depersonalize, block, delete and destroy personal data.
9.2 The Operator shall carry out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Cross-border transfer of personal data

10.1 Before commencing transborder transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out transborder transfer of personal data (such notification shall be sent separately from the notification of intention to process personal data).
10.2 Before submitting the above notification, the Operator shall obtain relevant information from foreign authorities, foreign individuals, foreign legal entities to whom transborder transfer of personal data is planned.

11. 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 disseminate personal data without the consent of the subject of personal data, unless otherwise provided for by federal law.

12. Final provisions

12.1. The User may obtain any clarifications on any questions concerning the processing of his/her personal data by contacting the Operator via e-mail at protonjetton@gmail.com.
12.2 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.
12.3 The current version of the Policy is freely available on the Internet at the address protonjetton.com/privacy-policy-eng.