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472 lines
28 KiB
472 lines
28 KiB
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<meta name="viewport" content="width=device-width, initial-scale=1.0">
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<title>Personal Data Processing Policy</title>
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</head>
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<body>
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<div class="privacy-text">
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<header>
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<h1>Personal Data Processing Policy</h1>
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</header>
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<section>
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<h2>1. General Provisions</h2>
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<p>
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This personal data processing policy is prepared in accordance with the requirements of Federal Law No.
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152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and
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defines the procedure for processing personal data and measures to ensure the security of personal data
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taken by LLC "Spatial Systems" (hereinafter referred to as the Operator).
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</p>
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<div>
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<div>
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<strong>1.1.</strong> The Operator considers the observance of human and civil rights and freedoms
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when processing their personal data, including the protection of the rights to privacy, personal and
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family secrets, as its most important goal and condition for carrying out its activities.
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</div>
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<div>
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<strong>1.2.</strong> This Operator's policy regarding the processing of personal data (hereinafter
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referred to as the Policy) applies to all information that the Operator may obtain about visitors to
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the website https://spatialsystems.ru.
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</div>
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</div>
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</section>
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<section>
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<h2>2. Basic Concepts Used in the Policy</h2>
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<div>
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<div>
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<strong>2.1.</strong> Automated processing of personal data - processing of personal data using
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computer technology.
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</div>
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<div>
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<strong>2.2.</strong> Blocking of personal data - temporary cessation of processing of personal data
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(except in cases where processing is necessary to clarify personal data).
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</div>
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<div>
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<strong>2.3.</strong> Website - a set of graphic and informational materials, as well as computer
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programs and databases that ensure their availability on the Internet at the network address
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https://spatialsystems.ru.
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</div>
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<div>
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<strong>2.4.</strong> Personal data information system - a set of personal data contained in
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databases and ensuring their processing information technologies and technical means.
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</div>
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<div>
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<strong>2.5.</strong> Depersonalization of personal data - actions as a result of which it is
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impossible to determine, without the use of additional information, the belonging of personal data
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to a specific User or other subject of personal data.
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</div>
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<div>
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<strong>2.6.</strong> Processing of personal data - any action (operation) or set of actions
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(operations) performed with or without the use of automation tools with personal data, including
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collection, recording, systematization, accumulation, storage, clarification (updating, changing),
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extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion,
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destruction of personal data.
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</div>
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<div>
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<strong>2.7.</strong> Operator - a state body, municipal body, legal entity or individual,
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independently or jointly with other persons organizing and/or carrying out the processing of
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personal data, as well as determining the purposes of processing personal data, the composition of
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personal data to be processed, actions (operations) performed with personal data.
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</div>
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<div>
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<strong>2.8.</strong> Personal data - any information relating directly or indirectly to a specific
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or identifiable User of the website https://spatialsystems.ru.
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</div>
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<div>
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<strong>2.9.</strong> Personal data permitted by the subject of personal data for dissemination -
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personal data, access to which is provided to an unlimited number of persons by the subject of
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personal data by giving consent to the processing of personal data permitted by the subject of
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personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter
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referred to as personal data permitted for dissemination).
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</div>
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<div>
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<strong>2.10.</strong> User - any visitor to the website https://spatialsystems.ru.
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</div>
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<div>
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<strong>2.11.</strong> Provision of personal data - actions aimed at disclosing personal data to a
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certain person or a certain circle of persons.
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</div>
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<div>
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<strong>2.12.</strong> Dissemination of personal data - any actions aimed at disclosing personal
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data to an indefinite circle of persons (transfer of personal data) or at familiarizing with
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personal data of an unlimited number of persons, including the publication of personal data in the
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media, posting in information and telecommunication networks or providing access to personal data in
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any other way.
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</div>
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<div>
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<strong>2.13.</strong> Cross-border transfer of personal data - transfer of personal data to the
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territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign
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legal entity.
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</div>
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<div>
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<strong>2.14.</strong> Destruction of personal data - any actions as a result of which personal data
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are destroyed irrevocably with the impossibility of further restoration of the content of personal
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data in the personal data information system and/or material carriers of personal data are
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destroyed.
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</div>
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</div>
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</section>
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<section>
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<h2>3. Basic Rights and Obligations of the Operator</h2>
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<div>
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<div>
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<strong>3.1.</strong> The Operator has the right:
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<ul>
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<li>Receive from the subject of personal data reliable information and/or documents containing
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personal data;</li>
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<li>In case the subject of personal data withdraws consent to the processing of personal data,
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as well as, sends an appeal with a request to terminate the processing of personal data, the
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Operator has the right to continue processing personal data without the consent of the
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subject of personal data if there are grounds specified in the Personal Data Law;</li>
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<li>Independently determine the composition and list of measures necessary and sufficient to
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ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory
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legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law
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or other federal laws.</li>
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</ul>
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</div>
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<div>
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<strong>3.2.</strong> The Operator is obliged:
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<ul>
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<li>Provide the subject of personal data, upon his request, with information regarding the
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processing of his personal data;</li>
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<li>Organize the processing of personal data in the manner established by the current
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legislation of the Russian Federation;</li>
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<li>Respond to appeals and requests from personal data subjects and their legal representatives
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in accordance with the requirements of the Personal Data Law;</li>
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<li>Report to the authorized body for the protection of the rights of personal data subjects,
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upon the request of this body, the necessary information within 10 days from the date of
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receipt of such request;</li>
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<li>Publish or otherwise provide unrestricted access to this Policy regarding the processing of
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personal data;</li>
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<li>Take legal, organizational and technical measures to protect personal data from unauthorized
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or accidental access, destruction, modification, blocking, copying, provision, distribution
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of personal data, as well as from other unlawful actions in relation to personal data;</li>
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<li>Cease the transfer (distribution, provision, access) of personal data, stop processing and
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destroy personal data in the manner and cases provided for by the Personal Data Law;</li>
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<li>Perform other duties provided for by the Personal Data Law.</li>
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</ul>
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</div>
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</div>
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</section>
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<section>
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<h2>4. Basic Rights and Obligations of Personal Data Subjects</h2>
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<div>
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<div>
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<strong>4.1.</strong> Personal data subjects have the right:
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<ul>
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<li>Receive information regarding the processing of his personal data, except in cases provided
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for by federal laws. The information is provided to the personal data subject by the
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Operator in an accessible form, and it should not contain personal data relating to other
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personal data subjects, except in cases where there are legal grounds for disclosing such
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personal data. The list of information and the procedure for obtaining it is established by
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the Personal Data Law;</li>
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<li>Require the operator to clarify his personal data, block or destroy them if the personal
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data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the
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stated purpose of processing, as well as take legal measures to protect their rights;</li>
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<li>Put forward a condition of prior consent when processing personal data for the purpose of
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promoting goods, works, services on the market;</li>
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<li>To withdraw consent to the processing of personal data, as well as, to send a request to
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terminate the processing of personal data;</li>
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<li>Appeal to the authorized body for the protection of the rights of personal data subjects or
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in court against unlawful actions or inaction of the Operator when processing his personal
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data;</li>
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<li>To exercise other rights provided for by the legislation of the Russian Federation.</li>
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</ul>
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</div>
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<div>
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<strong>4.2.</strong> Personal data subjects are obliged:
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<ul>
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<li>Provide the Operator with reliable data about themselves;</li>
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<li>Inform the Operator about the clarification (update, change) of their personal data.</li>
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</ul>
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</div>
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<div>
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<strong>4.3.</strong> Persons who have provided the Operator with inaccurate information about
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themselves, or information about another personal data subject without the consent of the latter,
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are liable in accordance with the legislation of the Russian Federation.
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</div>
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</div>
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</section>
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<section>
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<h2>5. Principles of Personal Data Processing</h2>
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<div>
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<div>
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<strong>5.1.</strong> The processing of personal data is carried out on a lawful and fair basis.
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</div>
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<div>
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<strong>5.2.</strong> The processing of personal data is limited to the achievement of specific,
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predetermined and lawful purposes. Processing of personal data that is incompatible with the
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purposes of collecting personal data is not allowed.
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</div>
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<div>
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<strong>5.3.</strong> It is not allowed to combine databases containing personal data, the
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processing of which is carried out for purposes that are incompatible with each other.
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</div>
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<div>
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<strong>5.4.</strong> Only personal data that meet the purposes of their processing are subject to
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processing.
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</div>
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<div>
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<strong>5.5.</strong> The content and volume of the processed personal data correspond to the stated
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purposes of processing. Redundancy of the processed personal data in relation to the stated purposes
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of their processing is not allowed.
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</div>
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<div>
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<strong>5.6.</strong> When processing personal data, the accuracy of personal data, their
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sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data
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are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or
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clarify incomplete or inaccurate data.
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</div>
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<div>
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<strong>5.7.</strong> The storage of personal data is carried out in a form that allows identifying
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the subject of personal data, no longer than required by the purposes of processing personal data,
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if the storage period for personal data is not established by federal law, an agreement to which the
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subject of personal data is a party, beneficiary or guarantor. Processed personal data are destroyed
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or depersonalized upon achievement of the processing purposes or in case of loss of the need to
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achieve these purposes, unless otherwise provided by federal law.
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</div>
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</div>
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</section>
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<section>
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<h2>6. Purposes of Personal Data Processing</h2>
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<table border="1">
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<tbody>
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<tr>
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<th>Purpose of processing</th>
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<td>providing the User with access to services, information and/or materials contained on the
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website</td>
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</tr>
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<tr>
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<th>Personal data</th>
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<td>
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<ul>
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<li>email address</li>
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<li>name</li>
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</ul>
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</td>
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</tr>
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<tr>
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<th>Legal grounds</th>
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<td>
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<ul>
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<li>Federal Law "On Information, Information Technologies and Information Protection"
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dated July 27, 2006 N 149-FZ</li>
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</ul>
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</td>
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</tr>
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<tr>
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<th>Types of personal data processing</th>
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<td>
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<ul>
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<li>Collection, recording, systematization, accumulation, storage, destruction and
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depersonalization of personal data</li>
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<li>Sending informational emails to the email address</li>
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</ul>
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</td>
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</tr>
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</tbody>
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</table>
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</section>
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<section>
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<h2>7. Conditions for Personal Data Processing</h2>
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<div>
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<div>
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<strong>7.1.</strong> The processing of personal data is carried out with the consent of the
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personal data subject to the processing of his personal data.
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</div>
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<div>
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<strong>7.2.</strong> The processing of personal data is necessary to achieve the purposes provided
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for by an international treaty of the Russian Federation or law, for the implementation of the
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functions, powers and duties imposed by the legislation of the Russian Federation on the operator.
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</div>
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<div>
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<strong>7.3.</strong> The processing of personal data is necessary for the administration of
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justice, the execution of a judicial act, an act of another body or official subject to execution in
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accordance with the legislation of the Russian Federation on enforcement proceedings.
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</div>
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<div>
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<strong>7.4.</strong> The processing of personal data is necessary for the performance of a contract
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to which the personal data subject is a party or beneficiary or guarantor, as well as for the
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conclusion of a contract on the initiative of the personal data subject or a contract under which
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the personal data subject will be the beneficiary or guarantor.
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</div>
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<div>
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<strong>7.5.</strong> The processing of personal data is necessary for the exercise of the rights
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and legitimate interests of the operator or third parties or for the achievement of socially
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significant goals, provided that the rights and freedoms of the personal data subject are not
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violated.
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</div>
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<div>
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<strong>7.6.</strong> The processing of personal data is carried out, access to which is provided to
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an unlimited number of persons by the personal data subject or at his request (hereinafter referred
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to as publicly available personal data).
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</div>
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<div>
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<strong>7.7.</strong> The processing of personal data subject to publication or mandatory disclosure
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in accordance with federal law is carried out.
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</div>
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</div>
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</section>
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<section>
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<h2>8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing</h2>
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<p>
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The security of personal data processed by the Operator is ensured through the implementation of legal,
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organizational and technical measures necessary to fully comply with the requirements of the current
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legislation in the field of personal data protection.
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</p>
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<div>
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<div>
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<strong>8.1.</strong> The Operator ensures the safety of personal data and takes all possible
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measures to exclude access to personal data by unauthorized persons.
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</div>
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<div>
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<strong>8.2.</strong> The User's personal data will never, under any circumstances, be transferred
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to third parties, except in cases related to the implementation of current legislation or in the
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case that the personal data subject has given consent to the Operator to transfer data to a third
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party to fulfill obligations under a civil law contract.
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</div>
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<div>
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<strong>8.3.</strong> In case of inaccuracies in personal data, the User can update them
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independently by sending a notification to the Operator to the email address
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info@spatialsystems.ru with the note "Updating personal data".
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</div>
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<div>
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<strong>8.4.</strong> The term for processing personal data is determined by the achievement of the
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purposes for which the personal data were collected, unless another term is provided for by the
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contract or current legislation.
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<br>
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The User can at any time withdraw his consent to the processing of personal data by sending a
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notification to the Operator via email to the Operator's email address
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info@spatialsystems.ru with the note "Withdrawal of consent to the processing of
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personal data".
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</div>
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<div>
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<strong>8.5.</strong> All information that is collected by third-party services, including payment
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systems, communication means and other service providers, is stored and processed by the specified
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persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data
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subject and/or with the specified documents. The Operator is not responsible for the actions of
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third parties, including the service providers specified in this clause.
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</div>
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<div>
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<strong>8.6.</strong> The prohibitions established by the personal data subject on the transfer
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(except for providing access), as well as on the processing or conditions of processing (except for
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obtaining access) of personal data permitted for dissemination, do not apply in cases of processing
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personal data in state, public and other public interests determined by the legislation of the
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Russian Federation.
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</div>
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<div>
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<strong>8.7.</strong> The Operator, when processing personal data, ensures the confidentiality of
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personal data.
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</div>
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<div>
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<strong>8.8.</strong> The Operator stores personal data in a form that allows identifying the
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subject of personal data, no longer than required by the purposes of processing personal data, if
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the storage period for personal data is not established by federal law, an agreement to which the
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subject of personal data is a party, beneficiary or guarantor.
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</div>
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<div>
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<strong>8.9.</strong> The condition for terminating the processing of personal data may be the
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achievement of the purposes of processing personal data, the expiration of the consent of the
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personal data subject, the withdrawal of consent by the personal data subject or a requirement to
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terminate the processing of personal data, as well as the identification of unlawful processing of
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personal data.
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</div>
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</div>
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</section>
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<section>
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<h2>9. List of Actions Performed by the Operator with Received Personal Data</h2>
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<div>
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<div>
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<strong>9.1.</strong> The Operator carries out collection, recording, systematization, accumulation,
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storage, clarification (updating, changing), extraction, use, transfer (distribution, provision,
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access), depersonalization, blocking, deletion and destruction of personal data.
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</div>
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<div>
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<strong>9.2.</strong> The Operator carries out automated processing of personal data with the
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receipt and/or transfer of the received information via information and telecommunication networks
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or without it.
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</div>
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</div>
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</section>
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<section>
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<h2>10. Cross-Border Transfer of Personal Data</h2>
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<div>
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<div>
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<strong>10.1.</strong> The Operator, before starting activities on the cross-border transfer of
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personal data, is obliged to notify the authorized body for the protection of the rights of personal
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data subjects of its intention to carry out cross-border transfer of personal data (such
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notification is sent separately from the notification of the intention to carry out personal data
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processing).
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</div>
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<div>
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<strong>10.2.</strong> The Operator, before submitting the above notification, is obliged to obtain
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relevant information from the authorities of a foreign state, foreign individuals, foreign legal
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entities to whom the cross-border transfer of personal data is planned.
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</div>
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</div>
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</section>
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|
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<section>
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<h2>11. Confidentiality of Personal Data</h2>
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<p>
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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 personal data subject,
|
|
unless otherwise provided by federal law.
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|
</p>
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</section>
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|
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<section>
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|
<h2>12. Final Provisions</h2>
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|
<div>
|
|
<div>
|
|
<strong>12.1.</strong> The User can receive any clarifications on issues of interest regarding the
|
|
processing of his personal data by contacting the Operator via email
|
|
info@spatialsystems.ru.
|
|
</div>
|
|
<div>
|
|
<strong>12.2.</strong> This document will reflect any changes to the personal data processing policy
|
|
by the Operator. The Policy is valid indefinitely until it is replaced by a new version.
|
|
</div>
|
|
<div>
|
|
<strong>12.3.</strong> The current version of the Policy is freely available on the Internet at
|
|
https://spatialsystems.ru/privacy/.
|
|
</div>
|
|
</div>
|
|
</section>
|
|
</div>
|
|
</body>
|
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</html> |