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Privacy Policy on Personal Data Processing
  1. General Provisions
  2. This Privacy Policy on Personal Data Processing has been 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 defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Kodi Management (hereinafter referred to as the Operator).
  3. 1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of man and citizen in the processing of their personal data, including the protection of the rights to inviolability of private life, personal and family secrets.
  4. 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 obtain about visitors to the website https://kodimanagement.com
  5. Key Concepts Used in the Policy
  6. 2.1. Automated processing of personal data — processing of personal data using computer equipment.
  7. 2.2. Blocking of personal data — temporary suspension of processing of personal data (except in cases where processing is necessary to clarify personal data).
  8. 2.3. Website — a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet under the network address https://kodimanagement.com
  9. 2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
  10. 2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific User or other subject of personal data.
  11. 2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation tools or without the use of such 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.
  12. 2.7. Operator — a state body, municipal body, legal or natural person that independently or jointly with other persons 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 to be processed, actions (operations) performed with personal data.
  13. 2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://kodimanagement.com
  14. 2.9. Personal data permitted by the subject of personal data for dissemination — personal data to which an unlimited circle of persons has been granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).
  15. 2.10. User — any visitor to the website https://kodimanagement.com
  16. 2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
  17. 2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including publishing personal data in the mass media, posting in information and telecommunications networks or providing access to personal data in any other way.
  18. 2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.
  19. 2.14. Destruction of personal data — any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
  20. Main Rights and Obligations of the Operator
  21. 3.1. The Operator has the right:
  22. — to receive from the subject of personal data reliable information and/or documents containing personal data;
  23. — in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as upon receipt of a request to terminate 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;
  24. — to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the duties provided for by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
  25. 3.2. The Operator is obliged:
  26. — to provide the subject of personal data, upon request, with information regarding the processing of his personal data;
  27. — to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
  28. — to respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
  29. — to inform the authorized body for the protection of the rights of personal data subjects, upon request of this body, with the necessary information within 10 days from the date of receipt of such request;
  30. — to publish or otherwise ensure unrestricted access to this Privacy Policy on Personal Data Processing;
  31. — to take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
  32. — to cease the transfer (dissemination, provision, access) of personal data, to cease processing and to destroy personal data in the manner and cases provided for by the Personal Data Law;
  33. — to fulfill other duties provided for by the Personal Data Law.
  34. Main Rights and Obligations of Personal Data Subjects
  35. 4.1. Personal data subjects have the right:
  36. — to receive information regarding the processing of their personal data, except for cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it 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 Personal Data Law;
  37. — to demand from the operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, as well as to take the measures provided for by law to protect their rights;
  38. — to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
  39. — to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
  40. — to appeal to the authorized body for the protection of the rights of personal data subjects or in court the unlawful actions or inaction of the Operator in processing their personal data;
  41. — to exercise other rights provided for by the legislation of the Russian Federation.
  42. 4.2. Personal data subjects are obliged:
  43. — to provide the Operator with accurate data about themselves;
  44. — to inform the Operator about clarification (updating, modification) of their personal data.
  45. 4.3. Persons who have provided the Operator with unreliable information about themselves or information about another personal data subject without the consent of the latter shall bear responsibility in accordance with the legislation of the Russian Federation.
  46. Principles of Personal Data Processing
  47. 5.1. Processing of personal data is carried out on a legal and fair basis.
  48. 5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
  49. 5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
  50. 5.4. Only personal data that meets the purposes of their processing is subject to processing.
  51. 5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed.
  52. 5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their taking to delete or clarify incomplete or inaccurate data.
  53. 5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, a party to which, beneficiary or guarantor under which is the personal data subject. Processed personal data is 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.
  54. Purposes of Personal Data Processing
  55. Purpose of processing: Informing the User by sending emails
  56. Personal data:
  57. surname, first name, patronymic
  58. email address
  59. phone numbers
  60. height
  61. photographs
  62. Legal basis:
  63. Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ of July 27, 2006
  64. Types of personal data processing:
  65. Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
  66. Sending informational emails to the email address
  67. Conditions for Processing Personal Data
  68. 7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
  69. 7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to exercise the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
  70. 7.3. 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.
  71. 7.4. Processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or beneficiary or guarantor under it, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
  72. 7.5. 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 personal data subject are not violated.
  73. 7.6. Processing of personal data to which an unlimited circle of persons has been granted access by the personal data subject or at their request (hereinafter — publicly available personal data) is carried out.
  74. 7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
  75. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
  76. The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
  77. 8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
  78. 8.2. The User's personal data will never be transferred to third parties under any circumstances, except for cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
  79. 8.3. In case of detection of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the Operator's email address kodimodelmanagement@gmail.com with the note "Personal Data Update".
  80. 8.4. The processing period of personal data is determined by achieving the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation.
  81. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at the Operator's email address kodimodelmanagement@gmail.com with the note "Withdrawal of Consent to Personal Data Processing".
  82. 8.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
  83. 8.6. Prohibitions established by the personal data subject on transfer (except for provision of access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
  84. 8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
  85. 8.8. The Operator carries out storage of personal data in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, a party to which, beneficiary or guarantor under which is the personal data subject.
  86. 8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or a request to terminate personal data processing, as well as detection of unlawful processing of personal data.
  87. List of Actions Performed by the Operator with the Obtained Personal Data
  88. 9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
  89. 9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the obtained information via information and telecommunications networks or without it.
  90. Cross-Border Transfer of Personal Data
  91. 10.1. Before starting activities for cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to carry out personal data processing).
  92. 10.2. Before submitting the above notification, the Operator must obtain from the foreign state authorities, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.
  93. Confidentiality of Personal Data
  94. The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
  95. Final Provisions
  96. 12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email kodimodelmanagement@gmail.com
  97. 12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
  98. 12.3. The current version of the Policy is freely available on the Internet at https://kodimanagement.com/private_policy-en and https://kodimanagement.com/private_policy-ru