Personal data processing policy
1. General Provisions
This personal data processing policy has been drafted in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-ФЗ “On Personal Data” and determines the procedure for processing personal data and measures to ensure the security of personal data of Winergo (hereinafter referred to as the Operator).
The operator sets as his most important goal and condition for the implementation of his activity the observance of the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
This policy of the Operator in relation to the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can receive about visitors to the website http://win-ergo.com.
2. Basic concepts used in the Policy
Automated processing of personal data - processing of personal data using computer equipment;
Blocking of personal data - temporary suspension of the processing of personal data (unless it is necessary to process personal data);
Website - a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address http://win-ergo.com;
Personal data information system - a set of personal data contained in databases, and information technologies and technical means ensuring their processing;
Personalization of personal data means actions that can not be determined without the use of additional information if the personal data belong to a specific User or other subject of personal data;
Personal data processing - any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including the collection, recording, systematization, accumulation, storage, refinement (update, change), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
Operator - a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
Personal data - any information relating directly or indirectly to a specific or definable User of the website http://win-ergo.com;
User - any visitor of the website http://win-ergo.com;
Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons;
Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or to become familiar with personal data of an unlimited number of persons, including public disclosure of personal data in the media, placement in information and telecommunication networks or access to personal data in any other way;
Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign natural or foreign legal entity;
Destruction of personal data - any actions that result in personal data being irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and (or) the result of which are destroyed the physical media of personal data.
3. The operator can process the following personal data of the User
Year, month, date and place of birth;
Also on the site is the collection and processing of impersonal data about visitors (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics and others).
The above data is hereinafter referred to as a Policy merged by the general concept of Personal Data.
4. Purpose of processing personal data
The purpose of processing User’s personal data is to inform the User by sending e-mails; providing User access to the services, information and / or materials contained on the website.
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 refuse to receive informational messages by sending an e-mail to the Operator firstname.lastname@example.org with the note “Refusal to notify about new products and services and special offers”.
Impersonal User data collected using Internet statistics services, are used to collect information about the actions of Users on the site, improve the quality of the site and its content.
5. Legal grounds for the processing of personal data
The Operator processes the User’s personal data only if it is completed and / or sent by the User independently through special forms located on the website http://win-ergo.com. By filling out the appropriate forms and / or sending your personal data to the Operator, the User agrees with this Policy.
6. The order of collection, storage, transmission and other types of personal data processing
The security of personal data that are processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully implement the requirements of the current legislation in the field of personal data protection.
The operator ensures the safety of personal data and takes all possible measures to prevent access to personal data of unauthorized persons.
The personal data of the User will never, under any circumstances, be passed on to third parties, except in cases related to the implementation of current legislation.
In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s email address email@example.com with the note “Actualization of personal data”.
The term for processing personal data is unlimited. The user may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator’s email address firstname.lastname@example.org with the note “Withdrawal of consent to the processing of personal data”.
7. Cross-border transfer of personal data
Prior to the commencement of the cross-border transfer of personal data, the operator must ensure that the foreign state, to whose territory it is planned to transfer personal data, ensures reliable protection of the rights of personal data subjects.
Cross-border transfer of personal data on the territory of foreign countries that do not meet the above requirements can only be carried out if there is a written consent of the subject of personal data on the cross-border transfer of his personal data and / or performance of a contract to which the subject of personal data is party.
8. Final provisions
The user can receive any clarification on issues of interest relating to the processing of his personal data by contacting the Operator via e-mail email@example.com.
This document will reflect any changes in the personal data processing policy of the Operator. The policy is valid indefinitely until replaced with a new version.