1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by the Website Administration (hereinafter — the Operator).

1.1

The Operator's most important goal and condition of its activity is the observance of human and civil rights and freedoms when processing personal data, including the protection of the right to privacy, personal and family secrets.

1.2

This Operator's policy on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://alxpro.ru.

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 suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3

Website — a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://alxpro.ru.

2.4

Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5

Depersonalization of personal data — actions that make it 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 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.

2.7

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 personal data processing, the composition of personal data to be processed, and the 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://alxpro.ru.

2.9

User — any visitor to the website https://alxpro.ru.

2.10

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

2.11

Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an indefinite circle of persons, including publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.

2.12

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

2.13

Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and (or) material media 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 the event that the subject of personal data withdraws consent to the processing of personal data, the Operator may 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 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/her request, with information concerning the processing of his/her personal data;
  • organize the processing of personal data in accordance with 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;
  • report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;
  • publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
  • take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, 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 in 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 concerning the processing of his/her personal data, except as provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except where there are legal grounds for disclosing such personal data;
  • demand from the operator the clarification of his/her personal data, their blocking or destruction if 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 for by law to protect their rights;
  • put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
  • withdraw consent to the processing of 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 in the processing of his/her personal data;
  • 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 (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. What Data Is Processed on the Website

5.1

The website is a personal blog and does not contain registration forms, surveys, comments, or paid services. The Operator processes the minimum necessary amount of data.

5.2

When logging into the website through third-party authorization services (Google, Yandex), the Operator receives the following User data:

  • name (the display name shown in the profile);
  • email address.

This data is used only to log in to the website and is not published. The User can log out of their account at any time.

5.3

The website collects and processes depersonalized data about visitors using web analytics services:

  • Yandex Metrica (counter id 31785756);
  • Google Analytics via Google Tag Manager.

These services collect depersonalized data about the device, browser, IP address (in depersonalized form), actions on the website, and "cookies".

5.4

The Operator maintains an anonymous page view counter that is not linked to the User's identity.

5.5

When visiting the website, the User receives a session cookie (JWT) necessary to maintain the login state. This cookie is not used to track the User's activity outside the website.

5.6

The Operator does not process special categories of personal data relating to racial or national origin, political views, religious or philosophical beliefs, or intimate life.

5.7

The Operator does not collect or process the following data: full name (without logging in), phone numbers, date and place of birth, photographs, payment information.

6. Principles of Personal Data Processing

6.1

Personal data processing is carried out on a lawful and fair basis.

6.2

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

6.3

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

6.4

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

6.5

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.

6.6

When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures to delete or clarify incomplete or inaccurate data.

6.7

Personal data is stored in a form that allows the subject of personal data to be identified, no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing

7.1

Purposes of processing the User's personal data:

  • providing the User with access to services, information and/or materials contained on the website https://alxpro.ru;
  • identifying the User when logging into the website through third-party authorization services.

7.2

Depersonalized User data collected through web analytics services is used to collect information about Users' actions on the website, improve the quality of the website and its content.

8.1

The legal grounds for personal data processing by the Operator are:

  • Federal Law "On Personal Data" No. 152-FZ of 27.07.2006;
  • Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ of 27.07.2006;
  • federal laws and other regulatory legal acts in the field of personal data protection;
  • User consent to the processing of their personal data.

8.2

The Operator processes the User's personal data (name and email address) only when the User logs into the website through third-party authorization services (Google, Yandex). By logging in, the User expresses their consent to this Policy.

8.3

The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (saving "cookies" and using JavaScript technology is enabled).

8.4

The subject of personal data independently decides to provide their personal data and gives consent freely, of their own will and in their own interest.

9. Conditions for Personal Data Processing

9.1

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

9.2

Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation.

9.3

Personal data processing is necessary for the administration of justice, the execution of a court decision, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4

Personal data processing is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.

9.5

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

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

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

10.1

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

10.2

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.

10.3

If inaccuracies in personal data are detected, the User can update them independently by sending a notification to the Operator at the email address main@alxpro.ru with the note "Personal data update".

10.4

The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by an agreement or current legislation.

The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator by email at main@alxpro.ru with the note "Withdrawal of consent to the processing of personal data".

10.5

All information collected by third-party services (Yandex Metrica, Google Analytics, Google and Yandex authorization services) is stored and processed by these entities in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties.

10.6

When processing personal data, the Operator ensures the confidentiality of personal data.

10.7

The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, 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 detection of unlawful processing of personal data.

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

11.1

The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, depersonalizes, blocks, deletes and destroys personal data.

11.2

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

12. Cross-Border Transfer of Personal Data

12.1

Before starting the cross-border transfer of personal data, the Operator must make sure that the foreign state to whose territory the transfer of personal data is supposed to be carried out ensures reliable protection of the rights of subjects of personal data.

12.2

Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only with the written consent of the subject of personal data to the cross-border transfer of their personal data and/or the execution of an agreement to which the subject of personal data is a party.

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