This version is a translation of the original Russian policy. In case of any discrepancies, the Russian version shall prevail.
1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Limited Liability Company “Association of Hay and Feed Producers and Exporters” (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://www.apehf.com/.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology
2.2. Blocking of personal data — temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://www.apehf.com/.
2.4. Personal data information system — 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 becomes impossible to determine, without the use of additional information, the belonging of personal data to a specific 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 automation tools with 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. Operator — a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, 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 website https://www.apehf.com/.
2.9. Personal data permitted by the subject of personal data for distribution — personal data, access to which is provided by the subject of personal data to an unlimited number of persons by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://www.apehf.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquainting an unlimited circle of persons with personal data, including disclosure of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
• receive from the subject of personal data reliable information and/or documents containing personal data;
• in case the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
• provide the subject of personal data, at his request, with information regarding the processing of his personal data;
• organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
• notify the authorized body for the protection of the rights of subjects of personal data, at the request of this body, of the necessary information within 30 days from the date of receipt of such a request;
• publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational, and technical measures to protect personal data from unlawful 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 for by the Personal Data Law;
• fulfill other obligations provided for 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 his personal data, except as provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, 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 Personal Data Law;
• demand from the Operator the clarification of his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights;
• put forward the condition of prior consent when processing personal data in order to promote goods, works, and services on the market;
• 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 actions or inaction of the Operator when processing his personal data;
• exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
• provide the Operator with reliable data about themselves;
• inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter shall be liable 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. Telephone numbers.
5.4. The website also collects and processes depersonalized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and others).
5.5. The above data hereinafter in the text of the Policy are united by the general concept of Personal Data.
5.6. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for by Article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for distribution is executed separately from other consents to the processing of his personal data. At the same time, the conditions provided for, in particular, by 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 subjects of personal data.
5.8.1. The User provides the Operator with consent to the processing of personal data permitted for distribution directly.
5.8.2. The Operator is obliged, no later than three working days from the date of receipt of the specified consent of the User, to publish information on the conditions of processing, on the availability of prohibitions and conditions for processing by an unlimited number of persons personal data permitted for distribution.
5.8.3. The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution must be stopped at any time at the request of the subject of personal data. This request must include the surname, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the subject of personal data, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may be processed only by the Operator to whom it is addressed.
5.8.4. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.8.3 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 legal and fair basis.
6.2. Processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
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 their processing are subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. The processed personal data must not be excessive in relation to the stated purposes of their processing.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data:
• informing the User by sending emails;
• conclusion, execution, and termination of civil law contracts;
• providing the User with access to services, information, and/or materials contained on the website https://www.apehf.com/.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending the Operator an email to info@apehf.com with the note "Refusal to receive notifications about new products and services and special offers".
7.3. Depersonalized User data collected using Internet statistics services is used to collect information about User actions on the site, improve the quality of the site and its content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for processing personal data by the Operator are:
• regulatory legal acts regulating relations related to your activities (for example, if your activity is related to information technology, in particular to website creation, you can specify the Federal Law "On Information, Information Technologies and Information Protection" of July 27, 2006 No. 149-FZ);
• the Operator's constituent documents;
• contracts concluded between the Operator and the subject of personal data;
• federal laws, other regulatory legal acts in the field of personal data protection;
• Users' consents to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://www.apehf.com/ or sent to the Operator by email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (the saving of cookies and the use of JavaScript technology are enabled).
8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, by his will, and in his interest.
9. Conditions for 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 purposes provided for by an international treaty of the Russian Federation or by law, to exercise the functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
9.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant purposes, 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 to an unlimited number of persons or at his request (hereinafter — publicly available personal data), is carried out.
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
110.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address info@apehf.com with the note "Updating personal data".
10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by contract or current legislation.
The User can at any time withdraw his consent to the processing of personal data by sending the Operator a notification via email to the Operator's email address info@apehf.com with the note "Withdrawal of consent to the processing of personal data".
10.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or User is obliged to independently familiarize himself in a timely manner with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
10.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.
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 identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the 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 Received Personal Data
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory it is intended to transfer personal data provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if the subject of personal data has given written consent to the cross-border transfer of his personal data and/or for the execution of a contract to which the subject of personal data is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have gained 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. Final Provisions
14.1. The User may receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email at info@apehf.com.
14.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://www.apehf.com/en/policy..
