Politik zur Verarbeitung personenbezogener Daten

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of the July 27, 2006 Federal Law No. 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Freedom International Group (hereinafter referred to as the Operator).

1.1. For the implementation of its activities, the Operator sets as its most important goal and condition the observance of the rights and freedoms of a person and a citizen in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This current Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the https://freedomgroupint.com/en/ website.

2. Basic terms used in the Policy

2.1. Automated processing of personal data: the processing of personal data using computer technology.

2.2. Blocking of personal data: the temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).

2.3. Website: the set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the https://freedomgroupint.com/en/ network address.

2.4. Personal data information system: the set of personal data contained in databases, and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data: actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.

2.6. Processing of personal data: any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator: a state body, municipal body, legal entity or individual, 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, the actions (operations) performed with personal data.

2.8. Personal data: any information directly or indirectly relating to a specific or identifiable User of the https://freedomgroupint.com/en/ website.

2.9 Personal data authorized by the subject of personal data for distribution: personal data to which the subject of personal data has granted access to an unlimited circle of persons by giving consent to the processing of personal data that the subject of personal data is permitted to distribute in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data allowed for distribution).

2.10. User: any visitor to the https://freedomgroupint.com/en/ website.

2.11. Providing personal data: actions aimed at disclosing personal data to a certain person or a certain circle of persons.

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 with personal data of an unlimited number of persons, including the 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: the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data: any actions as a result of which personal data is irretrievably destroyed with the impossibility of further restoration of the content of personal data in the information system of personal data and/or the physical media carriers of personal data are destroyed.

3. The Operator’s main rights and obligations

3.1. The Operator has the right:

- to receive reliable information and/or documents containing personal data from the subject of personal data;

- in the event that 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 to do so specified in the Law on Personal Data;

- to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obligated:

- to provide the subject of personal data, at their request, information regarding the processing of their personal data;

- to organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;

- to respond to appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;

- to report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;

- to publish or otherwise provide unrestricted access to this Policy Regarding the Processing of Personal Data;

- to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

- to 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;

- to perform other duties provided for by the Law on Personal Data.

4. The Subject of Personal Data’s main rights and obligations

4.1. The Subjects of Personal Data have the right:

- to receive information regarding the processing of their personal data, except as otherwise 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, unless 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;

- to require the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;

- to put forth the condition of prior consent when processing personal data in order to promote goods, works and services on the market;

- to withdraw consent to the processing of personal data;

- to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or inaction by the Operator when processing their personal data;

- to exercise other rights provided by the legislation of the Russian Federation.

4.2. The Subjects of Personal Data are obligated:

- to provide the Operator with accurate data about themselves;

- to inform the Operator about clarifications (updates, changes) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the consent of the latter are liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1 Full name.

5.2. Email address.

5.3. Phone numbers.

5.4. The site also collects and processes anonymous data about visitors (including cookies) using Internet statistics services (Yandex Metrika, Google Analytics and others).

5.5. Further in the text of the Policy, the above data will be united by the general term Personal Data.

5.6. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.

5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data is allowed if the prohibitions and conditions provided in Art. 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 issued separately from other consents to the processing of their personal data. At the same time, the conditions provided for, in particular, Art. 10.1 of the Personal Data Law, are observed. 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 directly provides the Operator with consent to the processing of personal data permitted for distribution.

5.8.2 The Operator is obligated, 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 existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.

5.8.3 The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement should include the last name, first name, patronymic (if any), contact information (telephone number, email address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request can be processed only by the Operator to whom it is sent.

5.8.4 Consent to the processing of personal data permitted for distribution terminates 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. The processing of personal data is carried out on a legal and fair basis.

6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. It is not permitted to process personal data that is incompatible with the purposes of personal data collection.

6.3. It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes that are 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 scope of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, is ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

6.7. If the period for storing personal data is not established by federal law or an agreement to which the subject of personal data is a party, beneficiary or guarantor, then the storage of personal data is carried out in a form that allows determining the subject of personal data for a period no longer than that required by the purposes of processing personal data,. The processed personal data is destroyed or depersonalized upon reaching the purposes of processing or in the case of loss of the need to achieve these purposes, unless otherwise provided for by federal law.

7. Purposes of Personal Data Processing

7.1. 7.1. The purpose of processing the User's personal data is:

- the conclusion, execution and termination of civil law contracts.

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 opt out of receiving informational messages by sending an email to the Operator at info@freedomgroupint.com with the note "Opt out of notifications about new products and services and special offers."

7.3. Users’ anonymized data, collected using Internet statistics services, are used to collect information about the actions of Users on the site to improve the quality of the site and its content.

8. Legal Grounds for the Processing of Personal Data

8.1. The legal grounds for the processing of personal data by the Operator are:

- statutory (constituent) documents of the Operator;

- agreements concluded between the Operator and the subject of personal data;

- federal laws, other regulatory legal acts in the field of personal data protection;

- Users' consent 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 https://freedomgroupint.com/en/ website 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 anonymized data about the User if it is allowed in the User's browser settings (saving cookies and using JavaScript technology is enabled).

8.4. The subject of personal data independently decides on the provision of their personal data and gives consent freely, by their own will and in their own interest.

9. Conditions for the Processing of Personal Data

9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

9.2. The processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or the law, to carry out the functions, powers and obligations assigned to the Operator by the legislation of the Russian Federation.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as to conclude an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or 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 The subject of personal data provides access, or access is provided at their request, to an unlimited circle of persons to the processing of personal data (hereinafter referred to as Publicly Available Personal Data)

9.7. The processing of personal data subject to publication or mandatory disclosure, in accordance with federal law, is carried out.

10. The procedure for collecting, storing, transferring and other types of 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 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.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law 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 the case of detection of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address info@freedomgroupint.com marked as "Updating personal data."

10.4. The term for the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the contract or applicable law.

The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification by email to the Operator's email address info@freedomgroupint.com marked as "Withdrawal of consent to the processing of personal data."

10.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The Subject of Personal Data and/or the User is obligated to independently familiarize themselves with the specified documents in a timely manner. 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 granting 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 the processing of 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. If the period for storing personal data is not established by federal law or an agreement to which the subject of personal data is a party, beneficiary or guarantor, then the Operator stores the personal data in a form that allows to determine the subject of personal data for no longer than required by the purposes of processing personal data.

10.9. A 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 or the withdrawal of consent by the subject of personal data, as well as 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), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

11.2. The operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without them.

12. Cross-Border Transfer of Personal Data

12.1. Before the start of the cross-border transfer of personal data, the Operator is obligated to make sure that the foreign state, to whose territory the transfer of personal data is supposed to be carried out, provides reliable protection of the rights of subjects of personal data.

12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is written consent from the subject of personal data to the cross-border transfer of their personal data and/or the execution of an agreement to which the subject of personal data is a party.

13. Privacy of Personal Data

The Operator and other persons who have gained access to the personal data are obligated 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 can receive any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator via email at info@freedomgroupint.com.

14.2. This document will reflect any changes in the Personal Data Processing Policy by the Operator. The Policy is valid indefinitely until it is replaced by a new version.

14.3. The current freely available version of the Policy is located on the Internet at https://freedomgroupint.com/privacy.