1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter - the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "GORAZH GROUP LIMITED" (hereinafter - the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can receive about visitors to the website https://finance.gorazh.group.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology.

2.2. Blocking of personal data - temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website - a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://finance.gorazh.group.

2.4. Information system of personal data - a set of personal data contained in databases and ensuring their processing of information technologies and technical means.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without using additional information the ownership of personal data to 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 using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), 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, actions (operations) performed with personal data.

2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://finance.gorazh.group.

2.9. Personal data permitted by the subject of personal data for distribution - personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data permitted for distribution).

2.10. User - any visitor to the website https://finance.gorazh.group.

2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Distribution 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 media, posting in information and telecommunication networks or providing access to personal data in any other way.

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.

2.14. Destruction of personal data - any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the information system of personal data and/or material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right:
— to receive from the subject of personal data reliable information and/or documents containing personal data;
— in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending an appeal with a requirement to stop processing 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 Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and 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 obliged:
— to provide the subject of personal data at his request with information relating to the processing of his personal data; — organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to appeals and requests of subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
— inform the authorized body for the protection of the rights of subjects of personal data at the request of this body with the necessary information within 10 days from the date of receipt of such a request; — publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
— fulfill other obligations provided for by the Law on Personal Data.

4. Basic rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right:
— to receive information relating to the processing of his personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
— to demand from the operator to clarify his personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— put forward a condition of preliminary 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, as well as to send a requirement to stop processing personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or in court the unlawful actions or inaction of the Operator when processing his personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged:
— to provide the Operator with reliable data about themselves;
— inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with unreliable 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. Principles of processing personal data

5.1. Processing of personal data is carried out on a legal and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined and lawful goals. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

5.4. Only personal data that meets the purposes of their processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. 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.

5.7. Storage of personal data is carried out in a form that allows to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, contract, party to which, beneficiary or guarantor for which is the subject of personal data. Processed personal data are destroyed or depersonalized upon achieving the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6. Purposes of processing personal data

Purpose of processing:
- informing the User by sending emails
Personal data:
- email address
- phone numbers
Legal grounds:
- statutory (constituent) documents of the Operator
- contracts concluded between the operator and the subject of personal data
Types of processing personal data:
- Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
- Sending information letters to the email address

7. Conditions for processing personal data

7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, for the implementation of functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, 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.

7.4. Processing of personal data is necessary for the execution of an agreement, a party to which or a beneficiary or guarantor for which is the subject of personal data, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary for the exercise of 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.

7.6. Processing of personal data is carried out, unlimited access to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data).

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for collecting, storing, transferring and other types of processing 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 current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.

8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or in case 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.

8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the email address of the Operator finance@gorazh.group with the note "Updating personal data".

8.4. The term of processing personal data is determined by achieving the goals for which personal data were collected, unless otherwise provided by the contract or current legislation. The User can at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the email address of the Operator finance@gorazh.group with the note "Withdrawal of consent to the processing of personal data".

8.5. All information that is 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. Subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, contract, party to which, beneficiary or guarantor for which is the subject of personal data.

8.9. The condition for terminating the processing of personal data may be achieving the goals of processing personal data, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or requirement to stop processing personal data, as well as detection of unlawful processing of personal data.

9. List of actions performed by the Operator with the received personal data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with receiving and/or transferring the received information via information and telecommunication networks or without such.

10. Cross-border transfer of personal data

10.1. Before starting activities for cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data 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 processing of personal data).

10.2. Before submitting the above notification, the Operator is obliged to receive from the authorities of a foreign state, foreign individuals, foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information.

11. Confidentiality of personal data

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 subject of personal data, unless otherwise provided by federal law.

12. Final provisions

12.1. The User can get any clarification on issues of interest relating to the processing of his personal data by contacting the Operator via email finance@gorazh.group.

12.2. 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.

12.3. The current version of the Policy is freely available on the Internet at https://finance.gorazh.group/politics.html/.