Personal data processing policy of VALEN LLC
1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy) adopted by VALEN Limited Liability Company (PSRN 1127746611794, TIN 7705993505, legal address: Russian Federation, 115035, Moscow, Sadovnicheskaya st., 72, building 1, floor 1 , premise III, room 5, office 44) (hereinafter – VALEN), defines the basic principles, goals, procedure and conditions for processing personal data of Site Visitors, measures to ensure the security and protection of personal data.
1.2. This Policy has been developed in accordance with the requirements of the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation in the field of personal data and is published for unlimited access on the VALEN website at: www.valen-legal.com.
1.3. The concepts used in this Policy are interpreted in accordance with their definition in the Federal Law of the Russian Federation of July 27, 2006 No. 152-FZ “On Personal Data”. 1.4. VALEN guarantees confidentiality in relation to the received personal data subject to the provisions of this Policy and undertakes to use them only for the purposes specified in the Policy.
The concept and composition of personal data 2.1. The list of personal data subject to protection in VALEN is formed in accordance with the Federal Law of the Russian Federation of July 27, 2006 No. 152-FZ „On Personal Data“.
2.2. VALEN processes and protects personal data (including last name, first name, place of work, position, contact phone number, email address, etc.) of visitors to the VALEN Website www.valen-legal.com (hereinafter referred to as the Website), as well as personal data received by to the VALEN corporate mail address ending in @valen-legal.com (hereinafter referred to as Corporate Mail), subjects who have expressed Consent to the processing of personal data (hereinafter referred to as Consent) by sending information through the selected forms (hereinafter referred to as Forms) on the pages of the Site or sending an email. The moment of acceptance of the Consent is marking the corresponding field in the Form and clicking on the button to send the Form on any page of the Site, as well as clicking on the button to send an e-mail containing the personal data of the subject to the Corporate mail address.
2.3. While browsing the VALEN Website, reading texts and downloading other information, certain data about the computer from which the Website Visitor is viewing the VALEN Website is automatically registered. When browsing the Site, VALEN collects the following information: the date and time of visiting the Site; the number of pages visited, their names, as well as the duration of viewing; IP address assigned to the device to access the Internet; type of browser and operating system; The URL of the site from which the transition was made.
- Purposes of personal data processing 3.1. The processing of personal data of the Website Visitors is carried out for such purposes as: sending reference and marketing information to the Website Visitors by sending messages to the e-mail address indicated by the Website Visitors; providing Visitors with the opportunity to provide feedback to VALEN; providing Website Visitors with advice on issues related to the services provided, for the purposes of marketing activities and supporting Website Visitors, as well as for other purposes that do not contradict the current legislation of the Russian Federation and the terms of agreements between VALEN and the relevant Website visitors.
- Principles and conditions for the processing of personal data 4.1. The processing of personal data by VALEN is based on the following principles:
- legitimacy and fairness;
- limiting the achievement of specific, predetermined and legitimate goals;
- preventing the processing of personal data that is incompatible with the purposes of collecting personal data;
- preventing the merger of databases containing – personal data, the processing of which is carried out for purposes that are incompatible with each other;
- the content and scope of the processed personal data must correspond to the stated purposes of processing;
- storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor;
- other principles provided for by the current legislation of the Russian Federation on personal data. 4.2. VALEN processes personal data in the presence of at least one of the following conditions:
- the subject of personal data has given Consent to the processing of personal data;
- the processing of personal data is necessary for the exercise of the rights and legitimate interests of VALEN to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated;
- the processing of personal data is carried out for statistical or other research purposes, subject to the mandatory depersonalization of personal data;
- other conditions stipulated by the current legislation of the Russian Federation on personal data.
- Rights and obligations of the subject of personal data 5.1. The subject of personal data has the right:
- demand clarification of their personal data, their updating, blocking or destruction;
- receive a list of their personal data processed by VALEN, the source of their receipt, information on the terms of processing their personal data, including the terms of their storage, and other information about the processing of their personal data;
- require notification of all persons who were previously informed of his incorrect or incomplete personal data about all corrections or additions made;
- appeal in the prescribed manner against illegal actions or omissions in the processing of his personal data. 5.2. Website visitors undertake to provide only reliable information about themselves. 5.3. Consent to the processing of personal data is issued by the Visitor for the entire period necessary for VALEN to achieve the purposes of processing. 5.4. Consent to the processing of personal data may be withdrawn by the Visitor by sending a written application to VALEN: 123112, Moscow, Presnenskaya embankment, building 6, structure 2, office 29 or to the Corporate mail address (firstname.lastname@example.org). 5.5. Persons who transmitted information to VALEN through the Site about another subject of personal data, without having the consent of the subject whose personal data were transferred, are liable in accordance with the legislation of the Russian Federation.
- Rights and obligations of VALEN 6.1. VALEN never asks the Site Visitor for information about his race, nationality, political views, religious and philosophical beliefs, health status, intimate life. 6.2. During the processing of personal data, VALEN has the right to carry out: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of the Visitor’s personal data. 6.3. In the case of participation of Visitors in events organized by VALEN, the latter has the right to disclose the relevant personal data of Visitors to persons participating in the organization of such an event. 6.4. VALEN is not entitled to transfer personal data of Site Visitors to a third party, with the exception of the following persons:
- authorized state bodies within their powers;
- persons to whom VALEN is obliged to transfer them in order to comply with the legislation of the Russian Federation;
- persons to whom VALEN transfers personal data in order to fulfill the contract with the subject of personal data;
- persons to whom VALEN entrusts the processing of personal data; to VALEN’s legal successors upon its reorganization;
- other persons, with the consent of the subject of personal data. 6.5. VALEN is not entitled to disclose the personal data of the Site Visitor for commercial purposes without his consent. The processing of the Visitor’s personal data in order to promote goods, works, services on the market by making direct contacts with a potential consumer using means of communication is allowed only with the prior consent of the Visitor.
6.6. VALEN undertakes to warn persons who have received the Visitor’s personal data that these data can be used only for the purposes for which they are reported, and require these persons to confirm that this rule has been observed.
6.7. Persons who have received the Visitor’s personal data are required to maintain secrecy (confidentiality). 6.8. VALEN processes and takes measures to protect the personal data of Site Visitors in accordance with the provisions of this Policy, as well as other documents issued by VALEN.
- Ensuring the protection and security of personal data 7.1. VALEN applies appropriate technological and operational security standards to protect the information provided by Site Visitors from unauthorized access, disclosure, distortion, blocking or destruction. 7.2. Measures applied in VALEN include:
- appointment of a person responsible for organizing the processing of personal data;
- application of legal, technical and organizational measures to ensure the security of personal data;
- assessment of the harm that may be caused to the subjects of personal data in case of violation of the requirements of the law, the ratio of harm and the security measures taken by VALEN;
- the use of secure premises with limited access to host servers of personal data information systems, as well as the use of lockable cabinets for storing paper media of personal data;
- familiarization of VALEN employees directly involved in the processing of personal data with the provisions of the legislation of the Russian Federation on personal data;
- control over the measures taken to ensure the security of personal data. 7.3. Access to personal data is provided only to authorized employees of VALEN, who are committed to maintaining the confidentiality of such information.
- Storage of personal data 8.1. Personal data of Site Visitors is stored for the period necessary for the purposes for which such data was provided or for the period required by law. 8.2. Upon reaching the goals / expiration of the period for the processing of personal data, the personal data of the Site Visitors are destroyed.
- Final provisions 10.1. This Policy is subject to change or addition in cases of making appropriate changes or additions to the current legislation of the Russian Federation on personal data, and may also be changed at any time at the discretion of VALEN. The current version of the Policy in VALEN is always available for viewing by an unlimited number of people on the website at the permanent address: www.valen-legal.com. 10.2. All relations with the participation of VALEN relating to the processing and protection of personal data and not directly reflected in this Policy are regulated in accordance with the provisions of the current legislation of the Russian Federation on personal data. 10.3. Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for organizing the processing of personal data VALEN.