1. General provisions
This Personal Data Processing Policy is in accordance with the requirements of the Federal Act of 27.07.2006. 152-FZ «About Personal Data» (hereinafter - the Law on Personal Data) and defines the procedure of processing of personal data and measures to ensure the security of personal data taken by LLC "Sputnik Med" (further - Operator).
1.1. The operator sets as his most important goal and condition for the performance of his activity the observance of human and civil rights and freedoms in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as Policy) applies to all information that the Operator may obtain about visitors to the https://sputnikmed.com website.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data is the processing of personal data using computer tools.
2.2. The blocking of personal data is the temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. The website is a collection of graphic and informational materials, as well as computer software and databases that make them available on the Internet at the network address https://sputnikmed.com.
2.4. Personal Data Information System is a set of personal data contained in databases, and providing their processing information technologies and technical means.
2.5. Anonymization of personal data is actions in which it is impossible to determine without the use of additional information the belonging of personal data to a particular User or other subject of personal data.
2.6. Processing of personal data is any action (operation) or set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Data controller is a government agency, municipal agency, legal or natural person, acting independently or jointly with other persons, who organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, and actions (operations) performed with personal data.
2.8. Personal data is any information relating directly or indirectly to a specific or identifiable User of the website https://sputnik-med.com.
2.9. Personal data authorized by the data subject for dissemination is a personal data to which an unlimited circle of persons has access, provided by the data subject by giving consent to the processing of personal data authorized for dissemination in the manner provided for by the Personal Data Protection Law (hereinafter referred to as personal data authorized for dissemination).
2.10. User is an any visitor to the website https://sputnik-med.com.
2.11. Provision of personal data is action aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data is any action aimed at disclosing personal data to an indefinite circle of persons (transmission of personal data) or acquainting an unlimited circle of persons with personal data, including the publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Distribution of personal data is any action aimed at disclosing personal data to an indefinite circle of persons (transmission of personal data) or acquainting an unlimited circle of persons with personal data, including the publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.14. Destruction of personal data is any action that result in the irreversible destruction of personal data without the possibility of further recovery of the content of personal data in the information system of personal data and/or the destruction of material carriers of personal data.
3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
– receive reliable information and/or documents containing personal data from the data subject;
– continue processing personal data without the consent of the data subject in case the data subject revokes their consent, if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
– provide the data subject with information regarding the processing of their personal data upon request;
– organize the processing of personal data in accordance with the current legislation of the Russian Federation;
– respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide the necessary information to the authorized body for the protection of the rights of data subjects within 30 days from the date of receiving such request;
– publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, and dissemination, as well as from other unlawful actions in relation to personal data;
– stop the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedures and cases provided by the Personal Data Law;
– fulfill other obligations stipulated by the Personal Data Law.
4. Main rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
– receive information regarding the processing of their personal data, except as provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and should 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 Law on Personal Data;
– demand from the operator the clarification of his personal data, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
– require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
– withdraw consent for the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator in processing his personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator in processing his personal data;
4.2. Personal data subjects are obliged to:
– provide the Operator with accurate information about themselves;
– inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with false information about themselves or information about another personal data subject without the latter's consent bear responsibility in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User:
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Year, month, date, and place of birth.
5.5. Photographs.
5.6. Certificate of citizenship.
5.7. Identification document details.
5.8. . Address of actual place of residence and registration by place of residence and (or) place of stay.
5.9. Documents confirming illness.
5.10.Also, the website collects and processes anonymized visitor data (including "cookies") using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.11. The above-mentioned data are collectively referred to as Personal Data in this Policy.
5.12. The Operator does not process special categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.
5.13. Processing of personal data allowed for distribution, from the list of 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.
5.14. The User's consent to the processing of personal data authorized for distribution is separate from other consents to the processing of his/her personal data. The conditions stipulated in particular in 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.
5.14.1 The User provides the Operator with consent to the processing of personal data authorized for distribution directly.
5.14.2 Within a period not exceeding three working days from the receipt of the User's consent, the Operator must publish information on the conditions for processing, the presence of prohibitions and conditions on the processing of the personal data authorized for distribution by an unlimited circle of persons.
5.14.3 The transfer (distribution, provision, access) of personal data authorized 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 surname, first name, patronymic (if any), contact information (phone number, email address, or mailing address) of the personal data subject, as well as a list of personal data the processing of which must be terminated. The personal data specified in this request can only be processed by the Operator to whom the request is addressed.
5.14.4 The consent to the processing of personal data authorized for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.14.3 of this Policy regarding the processing of personal data.
6. Principles of personal data processing
6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to the achievement of specific, pre-determined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not allowed.
6.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data that is relevant to the purposes of processing should be processed.
6.5. The content and scope of processed personal data should correspond to the stated purposes of processing. Processing of excessive personal data in relation to the stated purposes is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing should be ensured. The data controller takes necessary measures and/or ensures their adoption to delete or correct incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows the identification of the data subject for no longer than required by the purposes of processed personal data, unless the storage period is established by federal law, a contract, the party to which, the beneficiary or the guarantor of which is the data subject. Processed personal data is destroyed or anonymized upon reaching the purposes of processing or when the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.
7. Purposes of processing personal data
7.1. The purpose of processing the user's personal data is as follows:
– informing the user through sending emails;
– conclusion, execution, and termination of civil contracts;
– providing the user with access to services, information, and/or materials contained on the website https://sputnik-med.com.
7.2. The operator also has the right to send notifications to the user about new products and services, special offers, and various events. The user can always unsubscribe from receiving informational messages by sending a letter to the operator's email address info@sputnik-med.com with the subject "Unsubscribing from notifications about new products and services and special offers."
7.3. Depersonalized user data collected through internet statistics services is used to collect information about user actions on the website, improve the quality of the website, and its content.
8. Legal grounds for processing personal data
8.1. The legal grounds for processing personal data by the Operator are:
– the constituent (charter) documents of the Operator;
– contracts concluded between the operator and the subject of personal data;
– federal laws, other regulatory legal acts in the field of personal data protection;
– consent of Users to the processing of their personal data, to the processing of personal data allowed for distribution.
8.2. The Operator processes the personal data of the User only if they are filled in and/or sent by the User independently through special forms located on the website https://sputnik-med.com or sent to the Operator via email. By filling out the corresponding forms and/or sending their personal data to the Operator, the User expresses his/her consent to this Policy.
8.3. The Operator processes impersonal data about the User if this is allowed in the User's browser settings (when saving "cookies" files and using JavaScript technology).
8.4. The subject of personal data independently decides to provide his/her personal data and gives consent freely, voluntarily, and in his/her own interest.
9. Terms of personal data processing
9.1. The processing of personal data is carried out with the consent of the subject of personal data to process his/her personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to exercise 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 to administer justice, to enforce a judicial act, an act of another authority or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary to perform a contract, where the subject of personal data is a party, a beneficiary, or a guarantor, as well as to conclude a contract at the initiative of the subject of personal data or a contract where the subject of personal data will be a beneficiary or a guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Processing of personal data is carried out for personal data that is publicly available, where unlimited access to them is provided by the subject of personal data or at his/her request (hereinafter referred to as publicly available personal data).
9.7. Processing of personal data that is subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Order of collection, storage, transfer, and other processing of personal data 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 security of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the performance of current legislation or if the data subject has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil-legal contract.
10.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address info@sputnik-med.com with the subject "Updating personal data".
10.4. The processing period of personal data is determined by the achievement of the purposes for which personal data were collected, unless another term is provided by the contract or current legislation. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address info@sputnik-med.com with the subject "Revoking consent to the processing of personal data".
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or User are responsible for independently familiarizing themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
10.6. Prohibitions on the transfer (except for granting access) or processing (except for obtaining access) of personal data, as well as the conditions for processing personal data permissible for distribution, do not apply in cases of processing personal data in the public interest, determined by Russian legislation.
10.7. The Operator ensures the confidentiality of personal data during its processing.
10.8. The Operator stores personal data in a form allowing the identification of data subjects for no longer than necessary for the purposes of processing personal data, unless the storage period of personal data is determined by federal law, a contract, in which the data subject is a party, beneficiary, or guarantor.
10.9. The termination of the processing of personal data may be based on the achievement of the purposes of processing personal data, expiration of the consent period of the data subject, revocation of consent by the data subject, or the identification 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), retrieves, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The Operator carries out automated processing of personal data, including obtaining and/or transmitting the received information through information and telecommunication networks or without them.
12. Cross-border transfer of personal data
12.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign state, to whose territory the transfer of personal data is intended, provides reliable protection of the rights of personal data subjects.
12.2. The cross-border transfer of personal data to the territory of foreign states that do not meet the above-mentioned requirements may only be carried out with the written consent of the personal data subject for the cross-border transfer of his/her personal data and/or in fulfillment of the contract, the party to which is the personal data subject.
13. Confidentiality of personal data
The Operator and other individuals who have access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final provisions
14.1. The User can obtain any clarifications on issues related to the processing of his/her personal data by contacting the Operator via email at info@sputnik-med.com.
14.2. Any changes to the Operator's policy on the processing of personal data will be reflected in this document. The policy is effective 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://sputnik-med.com/.