Personal Data Processing Policy

1. General provisions
This personal data processing policy is compiled in accordance with the requirements of the Federal Law "On Personal Data" of 27.07.2006 No. 152-FZ (hereinafter – Personal Data Law) and defines the procedure
of processing of personal data and measures to ensure the security of personal data taken by Infomost Communications (hereinafter – the Operator).
1.1. The Operator's main purpose and condition for its actions is to ensure observance of human and civil rights and freedoms when processing their personal data, including protection of the rights to privacy,
and personal and family privacy.
1.2. The present policy of the Operator in relation to the processing of personal data (hereinafter – the Policy) applies to all information that the Operator can receive about visitors of the https://im-com.ru website.
2. Basic terms are used in the Policy
2.1. Automated processing means handling personal data using computer technology.
2.2. Blocking means temporarily suspending the processing of personal data (except when the processing
is necessary to clarify personal data).
2.3. "Website" is a complex of graphic and informational content, as well as software and databases ensuring their availability on the Internet at the https://im-com.ru web address.
2.4. "Personal data information system" is a set of personal data contained in databases of personal data
and information technology and technical means providing their processing.
2.5. "Depersonalization of personal data" is actions as a result of which it is impossible to determine, without using additional information, what personal data belongs to a particular User or another subject of personal data.
2.6. "Processing of personal data" is any action (operation) or set of actions (operations) performed, with
or without the use of automated means, 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.
2.7. "Operator" is a state authority, municipal authority, legal entity, or individual, independently or jointly with other persons, arranging and (or) carrying out the processing of personal data, as well as determining the purpose of the processing of personal data, the scope of personal data to be processed, actions (operations) performed with personal data.
2.8. "Personal data" is any information pertaining to a directly or indirectly identified or identifiable User
of the Website https://im-com.ru.
2.9. "Personal data authorized by the subject of personal data for distribution" is personal data, access
to which is provided by the personal data subject to an unlimited number of persons by giving consent
to the processing of personal data, authorized by the personal data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter - personal data authorized for distribution).
2.10. "User" is any visitor to the Website https://im-com.ru.
2.11. "Provision of personal data" is actions aimed at disclosure of personal data to a certain person
or a certain group of persons.
2.12. "Distribution of personal data" is any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or at familiarizing an unlimited range of persons with personal data, including publication of personal data in mass 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" is transfer of personal data to the territory of a foreign state
to a foreign governmental authority, a foreign natural person or a foreign legal entity.
2.14. "Destruction of personal data" is any actions as a result of which personal data is destroyed irretrievably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) as a result of which physical media of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator shall be entitled to:
– receive from the subject of personal data reliable information and/or documents containing personal data;
– to continue personal data processing without the consent of the personal data subject if there are grounds specified in the Personal Data Law, in case the personal data subject revokes consent to personal data processing;
– independently determine the composition and list of measures necessary and sufficient to ensure
the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted
in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator undertakes to:
– provide the personal data subject, upon its request, with information regarding the processing
of its personal data;
– organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
– respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– report to the authorized body for the protection of the rights of personal data subjects at the request
of this body of the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise provide unrestricted access to this Policy on personal data processing;
– 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 illegal actions with regard to personal data;
– stop transfer (distribution, provision, access) of personal data, stop processing and destroy personal data
in the manner and cases stipulated by the Personal Data Law;
– fulfill other obligations stipulated by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects shall be entitled to:
– receive information about processing of their personal data, except in cases provided for by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining
it is established by the Personal Data Law;
– demand from the Operator to clarify their personal data, block or destroy it in case the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing,
as well as to take measures provided by law to protect their rights;
– impose the condition of prior consent when processing personal data in order to promote on the goods, works and services market;
– withdraw of consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court against the unlawful actions or inactions of the Operator while processing of their personal data;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects undertake to:
– provide the Operator with reliable data about themselves;
– inform the Operator about clarification (update, change) of its personal data.
4.3 Persons who have provided the Operator with false information about themselves or information about another personal data subject without the consent of the latter shall be liable in accordance with
the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User
5.1. Surname, first name, patronymic.
5.2. E-mail address.
5.3. Phone numbers.
5.4. Information about education, profession, specialty and qualification, details of educational documents.
5.5. Information about previous held positions and work experience, military conscription, military registration.
5.6. The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics and others).
5.7. The aforementioned data are hereinafter in the text of the Policy united by the general term Personal Data.
5.8. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, intimate life.
5.9. Processing of personal data permitted for distribution from among the special categories of personal data specified in Article 10.1 of the Personal Data Law is permitted if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are observed.
5.10. The User's consent to the processing of personal data permitted for distribution is executed separately from other consents to the processing of its personal data. In this case, the conditions stipulated,
in particular, in Article 10.1 of the Personal Data Law shall be observed. The requirements for the content
of such consent shall be established by the authorized body for the protection of the rights of personal data subjects.
5.10.1 The User directly provides the Operator with the consent to the processing of personal data permitted for distribution.
5.10.2 The Operator is obliged to publish information about the conditions of processing, prohibitions
and conditions for processing of personal data permitted for distribution by an unlimited number of persons within three working days from the moment of receiving the consent of the User.
5.10.3 The transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution shall be terminated at any time at the request of the personal data subject. This request shall include the surname, first name, patronymic (if any), contact information (phone number, e-mail address
or postal address) of the personal data subject, as well as a list of personal data whose processing is subject
to termination. The personal data specified in this request may be processed only by the Operator to whom
it is sent.
5.10.4 Consent to the processing of personal data permitted for distribution cases to be valid from
the moment the Operator receives the request specified in clause 5.10.3 of this Policy.
6. Principles of personal data processing
6.1. The personal data shall be processed on a lawful and fair basis.
6.2. The processing of personal data shall be limited to achieving specific, predetermined and lawful purposes. The processing of personal data that incompatible with the purposes of personal data collection shall be not allowed.
6.3. Combining databases containing personal data processed for incompatible purposes shall be not allowed.
6.4. Only personal data that meet the purposes of their processing shall be processed.
6.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in regard to the stated purposes of their processing shall be not allowed.
6.6. While processing personal data, the accuracy of personal data, their sufficiency and, where necessary, relevance in regard to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.
6.7. The personal data shall be stored in a form that allows to identify 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 to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing
or in case of loss of necessity to achieve these purposes, unless otherwise provided for by federal law.
7. Purposes of personal data processing
7.1. The purpose of processing the User's personal data:
– to inform the User by sending e-mails;
– to provide the User with access to services, information, and/or materials published on the Website https://im-com.ru.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending
an email to the Operator's email address info@im-com.ru marked “Opt-out of notifications of new products and services and special offers”.
7.3. The Users' anonymized data collected with the help of Internet statistics services are used for collecting information about the Users' actions on the Website, improving the quality of the Website and its content.
8. Legal basis for personal data processing
8.1. The legal basis for personal data processing by the Operator are:
– the Operator's statutory (founding) documents;
– contracts concluded between the Operator and the personal data subject;
– federal laws, other regulatory legal acts in the field of personal data protection;
– the 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 the User fills in and/or sends it on their own through the special forms published on the Website https://im-com.ru or sent to the Operator via e-mail.
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 the anonymized data about the User in case it is allowed in the settings
of the User's browser (the saving of cookie files and/or the use of JavaScript technology is enabled).
8.4. The personal data subject independently decides on the provision of its personal data and gives consent freely, of its own free will and in its own interest.
9. Conditions of personal data processing
9.1. The personal data shall be processed with the consent of the personal data subject to the processing
of its personal data.
9.2. The personal data shall be processed to achieve the purposes provided for by the international treaty
of the Russian Federation or by law, to fulfill the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.
9.3. The personal data shall be processed 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.
9.4. The personal data shall be processed for the execution of an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary
or guarantor.
9.5. The personal data shall be processed for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially important purposes, provided that the rights
and freedoms of the personal data subject are not violated.
9.6. The personal data access to which by an unlimited number of persons is provided by the personal data subject or at its request (hereinafter – publicly available personal data) shall be processed.
9.7. The personal data that is subject to publication or mandatory disclosure in accordance with federal
law shall be processed.
10. Personal data collection, storage, transfer, and other processing procedures
Security of personal data processed by the Operator is ensured by implementing legal, organizational,
and technical measures necessary to meet in full the requirements of applicable legislation in the area
of personal data protection.
10.1. The Operator provides the security of personal data and takes all possible measures aimed at excluding access to personal data by unauthorized persons.
10.2. Personal data of the User will never, under no circumstances be transferred to third parties, except
in cases related to the execution of the applicable legislation or in case if the personal data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.
10.3. In case of identification of inaccuracies in personal data, the User may update them on their own
by sending a notice to the Operator's email address info@im-com.ru marked "Updating of personal data."
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is stipulated by the contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notice
by email to the Operator's email address info@im-com.ru marked "Withdrawal of consent to the processing
of personal data."
10.5. All information collected by third-party services, including payment systems, communications tools and other service providers, is stored and processed by the specified persons (the Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged
to independently and in a timely manner familiarize themselves with the specified documents. The Operator is not liable for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the personal data subject 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 shall not apply in cases of personal data processing in the state, public and other public interests defined by the legislation of the Russian Federation.
10.7. The Operator shall ensure confidentiality of personal data during personal data processing.
10.8. The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
10.9. The condition for termination of personal data processing may be the achievement of the purposes
of personal data processing, the expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, as well as detection of unlawful personal data processing.
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 automatically processes personal data with or without receiving and/or transmitting
the received information via information and telecommunication networks.
12. Cross-border personal data transfer
12.1. Before to cross-border transfer of personal data the Operator is obliged to ensure that the foreign state to the territory of which the transfer of personal data is supposed to be processed provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be processed only if the personal data subject consents in writing form
to the cross-border transfer of its personal data and/or fulfillment of an agreement to which the personal
data subject is a party.
13. Confidentiality of personal data
The Operator and other persons who have 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 for by federal law.
14. Final provisions
14.1. The User may obtain any explanations on questions of interest regarding the processing of their personal data by contacting the Operator through email at info@im-com.ru.
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 with a new version.
14.3. The updated version of the Policy is freely available on the Internet at https://im-com.ru/privacy.