Personal Data Processing Policy

1. General

This Personal Data Processing Policy follows the requirements of Federal Law 152-FZ dd. 27.07.2006 On Personal Data (hereinafter the Personal Data Law), establishing the personal data processing procedure and the measures to ensure their safety taken by recmoney.com (hereinafter the Operator).

The Operator′s key objective and the main operational condition is to preserve rights and freedoms of people and citizens while processing their personal data, including the right to privacy, personal and family secrets.
This Personal Data Processing Policy of the Operator (hereinafter the Policy) covers all data the Operator may collect about users of https://recmoney.com.

2. Key terms used in this Policy

Automated personal data processing means processing of personal data using computers.
Personal data blocking means temporary suspension of personal data processing (other than in cases when processing is needed to adjust personal data).
Website means an aggregation of graphics and information, along with software programs and databases that make them accessible in the Internet at: https://recmoney.com.
Personal data information system means an array of personal data contained in the databases, along with information technologies and technical means that ensure their processing.
Depersonalization of personal data means actions that make it sure the personal data cannot be attributed to a certain User or other personal data subject without using some extra information.
Personal data processing means any action (operation) upon personal data or an aggregation of the same, done automatically or manually, including collection, recording, classification, accumulation, storage, adjustments (updating, altering), retrieval, use, transfer (dissemination, disclosure, access), depersonalization, blocking, deletion or destruction of personal data.
Operator means a government or a municipal body, a legal person or an individual that, independently or together with other persons, organizes and/or performs personal data processing, as well as defines the purpose of personal data processing, the composition of data to be processed and the actions (operations) to be performed upon personal data.
Personal data means any information, directly or indirectly related to any identified or identifiable User of https://recmoney.com.
Personal data approved for dissemination by the personal data subject means personal data unrestricted access to which was provided by the personal data subject by giving consent to processing personal data the personal data subject approved for dissemination according to the procedure provided by the Personal Data Law (hereinafter Personal Data Approved for Dissemination).
User means anyone who visits https://recmoney.com.
Personal data provision means actions focused on disclosing personal data to a certain person or a category pf persons.
Personal data dissemination means any actions focused on disclosing personal data to an unlimited number of persons (personal data transfer), or offering personal data for perusal to an unlimited number of persons (including through media, information and communication networks or in any other way).
International personal data transfer means transfer of personal data to a foreign territory, to a foreign government body, a foreign legal person or a foreign national.
Personal data destruction means any actions causing personal data to be irretrievably destroyed so that its restoration within the information system is impossible, and/or physical destruction of its storage medium.

3. Key rights and obligations of the Operator

The Operator has the right:
– to receive authentic information and/or documents containing personal data, from personal data subjects;
– if the personal data subject withdraws their consent for personal data processing, the Operator has the right to continue processing data without such consent providing that grounds outlined in the Personal Data Law is present;
– to independently define the composition and the nomenclature of measures necessary and sufficient to fulfill obligations outlined in the Personal Data Law and its subordinate legislation, if the Personal Data Law or other federal laws do not provide otherwise.
The Operator shall:
– provide the personal data subject, on their request, with information related to processing their personal data;
– set up personal data processing according to the procedure provided by the current Russian laws;
– respond to requests and inquiries submitted by personal data subjects or their representatives in law, as the Personal Data Law requires;
– on request, provide an authorized body responsible for protecting personal data subjects′ rights, with any and all required data within 30 days of receiving such a request;
– publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
– take legal, organizational and technical measures to protect personal data from wrongful or accidental access, destruction, altering, blocking, copying, provision, dissemination or from other wrongful actions in relation to personal data;
– cease transfer (dissemination, provision, access to) personal data, cease processing and destroy the personal data in cases and according to the procedure provided in the Personal Data Law;
– fulfill other obligations provided in the Personal Data Law.

4. Key rights and obligations of personal data subjects

Personal data subjects have the right:
– to receive information related to processing their personal data, save for the cases provided by the federal laws. Information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain any personal data related to other personal data subjects, save if there are lawful grounds for disclosure of such personal data; The list of information and the procedure for its provision are outlined in the Personal Data Law;
– to require the Operator to update, block or delete the personal data in cases when it is found to be incomplete, out of date, incorrect, wrongfully acquired or unnecessary for the stated processing purpose, as well as to take measures, afforded by the law, to protect their lawful rights;
– to set up a condition requiring preliminary consent to personal data processing in order to promote goods, works or services at the market;
– to withdraw consent to personal data processing;
– to appeal to an authorized body responsible for protecting personal data subjects′ rights or through court action against any wrongful action or inaction by the Operator while processing personal data subject′s personal data;
– to enforce other rights granted by the Russian law.
Personal data subjects shall:
– provide the Operator with authentic data;
– inform the Operator about any adjustments (updates, alterations) to their personal data.
Persons providing the Operator with false data about themselves or about another personal data subject without the latter′s consent shall be responsible according to the Russian law.

5. The Operator may process the following personal data from each User:

Last name, first name, patronymic.
E-mail address.
Phone numbers.
In addition, the website collects and processes depersonalized visitor data (incl. cookies) using web statistics services such as Yandex.Metrics, Google Analytics, etc.
Hereinafter in this Policy, all that data is collectively called the Personal data.
The Operator does not process special personal data categories such as race, ethnicity, political views, religious or philosophical beliefs, sexual life.
Processing personal data permitted for dissemination but falling under one of the special categories listed in Pt. 1 Art. 10, Personal Data Law, is allowed subject to restrictions and conditions provided in Art. 10.1, Personal Data Law.
User consent to processing personal data permitted for dissemination shall be provided separately from other personal data processing consents. Furthermore, the conditions provided, in particular, in Art. 10.1, Personal Data Law, shall be met. The requirements for a consent outlined above are set by an authorized body responsible for protecting personal data subjects′ rights.
1. Consent to process personal data approved for dissemination shall be provided by a User to the Operator directly.
2. The Operator shall, no later than three business days after receiving the aforementioned User consent, publish information pertaining to processing conditions, limits and provisions for processing personal data approved for dissemination by unlimited number of persons.
3. Transfer of (dissemination, provision of, access to) personal data approved for dissemination by the personal data subject shall cease at any time at the personal data subject′s request. The request in question covers last name, first name, patronymic (if any), contact details (phone number, e-pail or postal address) of the personal data subject, along with the list of data not to be processed any longer. The data stated in the request may only be processed by the Operator receiving that request.
4. A consent to process personal data approved for dissemination becomes invalid at the moment the Operator receives a request specified in cl. 5.8.3 of this Personal Data Processing Policy.

6. Personal data processing principles

Personal data is processed lawfully and fairly.
Personal data processing shall be limited to achieving specific, pre-defined and lawful objectives. Any personal data processing incompatible with the personal data processing objectives is not allowed.
Merging databases containing personal data to be processed for purposes incompatible with each other is not allowed.
Only the personal data that conforms to the processing objectives is to be processed.
The content and the amount of personal data to be processed shall be in line with the stated processing objectives. Processing data in excess of the stated processing objectives is not allowed.
Personal data processing shall ensure that the personal data is accurate, sufficient and, if needed, up to date with regards to the personal data processing objectives. The Operator shall take and/or ensure taking all the necessary steps aimed at deleting or adjusting inaccurate or incomplete data.
Personal data shall be stored in a form that would allow identifying the personal data subject for no longer than is needed for the data processing objectives to be achieved, if another personal data storage term has not been established by federal laws or a contract which the personal data subject is a party to, a beneficiary or a guarantor under. After the processing objectives are achieved, or if there′s no need to achieve them any longer, the personal data to be processed is to be destroyed or depersonalized, if federal laws do not require otherwise.

7. Personal data processing objectives

The objective of personal User data processing is:
– to provide the User with access to services, information and/or materials hosted at https://recmoney.com.
The Operator also may notify the User about new products and services, special offers and various events. The User can decline getting further notifications at any time by sending a message to the Operator at info@recmoney.com marked «Decline further notifications on new products, services or special offers».
Depersonalized User data collected via web statistics services help collect information about User actions at the website and improve the website and its content quality.

8. Legal basis for processing personal data

The legal basis for processing personal data is:
– contracts signed by and between the Operator and the personal data subject;
– federal laws or other regulation pertaining to personal data protection;
– User consent to process personal data approved for dissemination.
The Operator processes personal User data only if the User filled in and/or provided it personally using dedicated forms available at https://recmoney.com, or sent it to the Operator via e-mail. The User consents to the terms of this Policy by filling in the required forms and/or sending their personal data to the Operator.
The Operator processes depersonalized User data if such an option has been enabled in the in the User browser settings (cookie saving and JavaScript technology on).
A personal data subject independently decides to provide or not provide personal data and gives consent freely, for their own benefit and interest.

9. Personal data processing conditions

Personal data is processed with the personal data subject′s consent to such processing.
Personal data processing is done to achieve objectives provided by an international treaty the Russian Federation is a party to, or by law, in order to perform functions, realize powers or fulfill obligations imposed by the Russian law on the Operator.
Personal data processing is done to promote justice or follow a court order or an order issued by another public body or official, to be enforced according to the Russian enforcement proceedings law.
Personal data processing is done to fulfill a contract the personal data subject is a party to, a beneficiary or a guarantor under, or to sign a contract initiated by the personal data subject, or a contract under which the personal data subject is supposed to be a beneficiary or a guarantor.
Personal data processing is done to enforce the rights and lawful interests of the Operator or of any third persons, or to achieve socially significant goals, provided that the personal data subject′s rights and freedoms are not violated.
Personal data processing is done in relation to the data which the personal data subject has provided (or requested to be provided) access to for an unlimited number of persons (hereinafter the general access personal data).
Personal data processing is done in relation to the data to be published or disclosed according to federal laws.

10. Procedure for personal data collection, storage, transfer and other processing

Security of data to be processed by the Operator is ensured through legal, organizational and technical measures required to fully meet the requirements of the personal data protection law in effect.

The Operator ensures security of personal data and takes all the possible steps to ensure that unauthorized persons do not have access to the data.
Personal User data can never and under no circumstances be transferred to any third parties, except if such transfer is required to ensure compliance with current laws or in cases when the personal data subject gives consent to the Operator to provide their data to a third party in order to fulfill their obligations under a civil law contract.
If any discrepancies are detected in personal data, the User can bring it up to date on their own by sending an e-mail message marked «Personal data update» to the Operator at info@recmoney.com.
The deadline for personal data processing depends on the objectives personal data has been collected to achieve, if current laws or a contract do not provide for another term.
The User may withdraw their consent to personal data processing at any moment by sending an e-mail message marked «Personal data processing consent withdrawal» to the Operator at info@recmoney.com.
All information collected by third party services, including payment systems, communication and other service providers, is stored and processed by those third parties (Operators) according to their user agreements and privacy policies. It′s the personal data subject and/or User′s responsibility to read those documents on their own and in time. The Operator is not responsible for any actions of third persons, including the service providers mentioned in this clause.
Limits on transfer (other than access provision) and processing or processing conditions (other than obtaining access) of personal data approved for dissemination set by the personal data subject do not apply in cases when personal data is being processed in pursuit of government or public interests stated by Russian laws.
When processing personal data, the Operator ensures its confidentiality.
The Operator stores personal data in a form that would allow identifying the personal data subject for no longer than is needed for the data processing objectives to be achieved, if another personal data storage term has not been established by federal laws or a contract which the personal data subject is a party to, a beneficiary or a guarantor under.
A condition for cessation of personal data processing may be achieving the objectives of such processing, expiry of the personal data subject′s consent to the same or withdrawal of such consent, as well of detection of personal data processing being done wrongfully.

11. The Operator′s actions over the data it receives

The Operator carries out collection, recording, classification, accumulation, storage, adjustment (updating, altering), retrieval, use, transfer (dissemination, disclosure, access), depersonalization, blocking, deletion or destruction of personal data.
The Operator carries out automated personal data processing that involve reception and/or transmission of the resulting information over the information and telecommunication networks or without the same.

12. International personal data transfer

Before starting international transfer of personal data, the Operator shall ensure that the foreign state to which territory the data is to be transferred to, provides for robust protection of personal data subjects′ rights.
International personal data transfer to states that do not meet the aforementioned requirements shall only be done if the personal data subject provides a written consent to transfer of their personal data and/or discharge of the contract the personal data subject is a party to.

13. Personal data privacy

The Operator and other persons with access to personal data shall not disclose such data to any third person or disseminate it without the personal data subject′s consent, if federal laws do not provide otherwise.

14. Final provisions

The User may clarify any issues related to processing their personal data by contacting the Operator at info@recmoney.com.
This document will reflect any changes to the Operator′s personal data processing policy. This Policy is valid indefinitely until it′s replaced by a new version.
See an up-to-date, free-access Policy version at: https://recmoney.com/privacy-policy/.