Privacy Policy and Personal Data Processing

Please note: Only the Russian version of this document is legally binding. Translations into other languages are provided for user convenience only. You can find the Russian version here.

1. Basic Concepts Used in the Policy

1.1. Automated processing of personal data — processing of personal data using computer technology.

1.2. Blocking of personal data — temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

1.3. Website — a set of graphic and informational materials, as well as software and databases, ensuring their availability on the internet at the network address https://spez.pro.

1.4. Information system of personal data — a set of personal data contained in databases and ensuring their processing through information technologies and technical means.

1.5. Depersonalization of personal data — actions that result in the impossibility of determining, without using additional information, the affiliation of personal data to a specific User or other subject of personal data.

1.6. Processing of personal data — any action (operation) or 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.

1.7. Operator — a state body, municipal body, legal entity, or individual who, 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 subject to processing, actions (operations) performed with personal data.

1.8. Personal data — any information related directly or indirectly to a specific or identifiable User of the website https://spez.pro.

1.9. Personal data allowed by the subject of personal data for distribution — personal data to which an unlimited number of people have access, provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data allowed for distribution).

1.10. User — any visitor to the website https://spez.pro.

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

1.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an indefinite number of persons with personal data, including publication of personal data in the media, placement in information and telecommunications networks, or providing access to personal data in any other way.

1.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual, or a foreign legal entity.

2. General Provisions

This policy for the processing of personal data is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. № 152-FZ "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 the company "Spez" (hereinafter — the Operator).

2.1. 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 privacy, personal and family secrets.

2.2. This Operator's policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://spez.pro.

3. Main Rights and Duties 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 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 Law on Personal Data;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the duties provided for by the Law on Personal Data and the adopted regulatory legal acts, 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 their request, with information regarding the processing of their personal data;
• organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
• notify the authorized body for the protection of the rights of subjects of personal data, at their request, of the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
• terminate 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 duties provided for by the Law on Personal Data.

4. Main Rights and Duties of Subjects of Personal Data

4.1. Subjects of personal data have the right to:

• receive information regarding the processing of their 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 it 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;
• request the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the declared purpose of processing, as well as take the measures provided by law to protect their rights;
• set a condition of prior consent when processing personal data for the promotion of goods, works, and services on the market;
• withdraw consent to the processing of personal data, as well as send a request to terminate the processing of personal data;
• complain to the authorized body for the protection of the rights of subjects of personal data or in court about illegal actions or inaction of the Operator in the processing of their personal data;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

• provide the Operator with reliable data about themselves;
• notify the Operator of the clarification (updating, changing) of their personal data.

4.3. Persons who have provided the Operator with false 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 Personal Data Processing

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

5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. The combination of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

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

5.5. The content and volume of processed personal data correspond to the declared purposes of processing. The redundancy of processed personal data concerning the declared purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, in necessary cases, their relevance concerning 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. The 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 unless the period for storing personal data is established by federal law, an agreement to which the subject of personal data is a party, a beneficiary, or a guarantor. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

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

• informing the User by sending emails;
• concluding, executing, and terminating civil law contracts;

6.2. 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 refuse to receive informational messages by sending an email to the Operator at info@spez.pro with the note "Refusal of notifications about new products and services and special offers".

6.3. Depersonalized data of Users collected through internet statistics services are used to collect information about Users' actions on the site, improve the quality of the site, and its content.

6. Purposes of Personal Data Processing

6.1. Informing the User by sending emails.

• Personal data:
  1. email address.
• Legal grounds:
  1. Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 N 149-FZ.
• Types of personal data processing:
  1. Sending informational emails to the email address.

6.2. Providing the User with access to services, information, and/or materials available on the website.

• Personal data:
  1. surname, first name, patronymic,
  2. email address,
  3. phone numbers,
  4. date of birth,
  5. photographs.
• Legal grounds:
  1. Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 N 149-FZ.
• Types of personal data processing:
  1. Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
  2. Sending informational emails to the email address.
  3. Communication with the client by phone.
  4. Processing of photographs of objects and documents sent by the client to the personal account.

6.3. Collection of statistical data to improve the website's performance

• Personal data:
  1. IP address and other technical parameters of the device from which the Subjects of personal data visit the website https://spez.pro.
• Legal grounds:
  1. Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 N 149-FZ.
• Types of personal data processing:
  1. Collection of statistical data

7. Conditions for Processing Personal Data

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

7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or law, for the implementation and fulfillment of the functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.

7.3. 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.

7.4. 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 for the conclusion of an agreement initiated by the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. The processing of personal data is carried out, access to which is granted to an unlimited number of persons by the subject of personal data or at their request (hereinafter — publicly available personal data).

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

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

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.

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

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@spez.pro with the note "Updating personal data".

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or applicable law.

The User can withdraw their consent to the processing of personal data at any time by sending a notification via email to the Operator's email address info@spez.pro with the note "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the specified service providers.

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

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 determining the subject of personal data, no longer than required by the purposes of processing personal data unless the period for storing personal data is established by federal law, an agreement to which the subject of personal data is a party, a beneficiary, or a guarantor.

8.9. The 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.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs the automated processing of personal data with the receipt and/or transfer of received information via information and telecommunications networks or without it.

10. Cross-Border Transfer of Personal Data

10.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is intended to be transferred provides reliable protection of the rights of subjects of personal data.

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

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 receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email info@spez.pro.

12.2. 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.

12.3. The current version of the Policy is freely available on the internet at https://spez.pro/privacy_policy/.