IPM CONSULTING LLC POLICY ON PERSONAL DATA PROCESSING
1. General Provisions
1.1. This Policy on Personal Data Processing (hereinafter referred to as the Policy), adopted by IPM Consulting Limited Liability Company (OGRN: 1175007002807, INN: 5044107790, legal address: 127015, Moscow, Novodmitrovskaya St., 2, bldg. 2, floor 18, office 19) (hereinafter referred to as IPM Consulting), defines the main principles, objectives, procedures, and conditions for processing personal data of website visitors, measures to ensure the security and protection of personal data.
1.2. This Policy is developed in accordance with the Constitution of the Russian Federation, laws, and other regulatory legal acts of the Russian Federation in the field of personal data and is published for unrestricted access on the IPM Consulting website at: www.ipmconsult.ru.
1.3. The terms used in this Policy are interpreted in accordance with their definition given in the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data".
1.4. IPM Consulting guarantees the confidentiality of the received personal data in accordance with the provisions of this Policy and undertakes to use them only for the purposes specified in the Policy.
2. Concept and Composition of Personal Data
2.1. The list of personal data subject to protection at IPM Consulting is formed in accordance with the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data".
2.2. IPM Consulting processes and protects the personal data (including surname, first name, place of work, position, contact phone number, email address, and other provided data) of the visitors of the IPM Consulting website www.ipmconsult.ru (hereinafter referred to as the Website), as well as personal data received at the corporate mail addresses of IPM Consulting ending with @ipmconsult.ru (hereinafter referred to as Corporate Mail), of subjects who have given their Consent to the processing of personal data (hereinafter referred to as Consent) by sending information through selected forms (hereinafter referred to as Forms) on the Website pages or by sending an email. The moment of giving Consent is marked by ticking the appropriate field in the Form and clicking the send button of the Form on any page of the Website, as well as clicking the send button of the email containing the subject's personal data to the Corporate Mail address.
2.3. During the viewing of the IPM Consulting Website, reading texts, and downloading other information, certain data about the computer from which the Website visitor views the IPM Consulting Website is automatically registered. When viewing the IPM Consulting Website, the following information is collected:
- The date and time of the visit to the Website;
- The number of pages visited, their names, and the duration of viewing;
- The IP address assigned to the device for Internet access;
- The type of browser and operating system;
- The URL of the website from which the transition was made.
3. Objectives of Processing Personal Data
3.1. The processing of personal data of Website visitors is carried out for purposes such as:
- Providing visitors with the opportunity for feedback with IPM Consulting;
- Providing Website visitors with consultations on issues related to the services provided, for marketing activities and support of Website visitors, as well as for other purposes not contrary to the current legislation of the Russian Federation and the terms of agreements between and corresponding Website visitors.
4. Principles and Conditions for Processing Personal Data
4.1. The processing of personal data is based on the following principles:
- Legality and fair basis;
- Limitation to achieving specific, predefined, and lawful purposes;
- Prevention of processing personal data incompatible with the purposes of collecting personal data;
- The content and volume of processed personal data must correspond to the stated processing purposes;
- Storage of personal data is carried out in a form that allows identifying 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, a contract, the party of which, the beneficiary, or guarantor is the subject of personal data;
- Other principles provided by the current legislation of the Russian Federation on personal data.
4.2. The processing of personal data is carried out if at least one of the conditions is met:
- The subject of personal data has given Consent to the processing of personal data;
- Processing of personal data is necessary for the realization of the rights and legitimate interests of IPM Consulting for achieving socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
- Processing of personal data is carried out for statistical or other research purposes, provided that personal data is obligatorily depersonalized;
- Other conditions provided by the current legislation of the Russian Federation on personal data.
5. Rights and Obligations of the Personal Data Subject
5.1. The subject of personal data has the right to:
- Demand clarification of their personal data, their updating, blocking, or destruction;
- Receive a list of their personal data processed by IPM Consulting, the source of their receipt, information about the terms of processing their personal data, including the terms of their storage, and other information about the processing of their personal data;
- Demand notification of all persons to whom their incorrect or incomplete personal data were previously communicated, about all corrections or additions made;
- Appeal in the prescribed manner against unlawful actions or inactions when processing their personal data.
5.2. Website visitors are obliged to provide only accurate data about themselves.
5.3. Consent to the processing of personal data is given by the Visitor for the entire period necessary for IPM Consulting to achieve the processing objectives.
5.4. Consent to the processing of personal data can be revoked by the Visitor by sending a written statement to the address: 127015, Moscow, Novodmitrovskaya St., 2, bldg. 2, floor 18, office 19 or to the Corporate Mail address (info@ipmconsult.ru).
6. Rights and Obligations of IPM Consulting
6.1. In the course of processing personal data, IPM Consulting is entitled to carry out: collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of the Visitor's personal data.
6.2. IPM Consulting is not entitled to transfer the personal data of Website visitors to a third party except for the following persons:
- Authorized state authorities within their powers;
- Persons to whom IPM Consulting is obliged to transfer them for compliance with the legislation of the Russian Federation;
- Persons to whom IPM Consulting transfers personal data for the execution of the contract with the subject of personal data;
- Persons to whom IPM Consulting entrusts the processing of personal data, including persons providing technical support to IPM Consulting, ensuring the maintenance and use of the necessary IT systems,
- Other persons with the consent of the subject of personal data.
6.3. IPM Consulting is not entitled to disclose the personal data of the Website Visitor for commercial purposes without his consent. Processing of the Visitor's personal data for the purpose of promoting goods, works, services on the market by making direct contacts with a potential consumer using communication means is allowed only with the prior consent of the Visitor.
6.4. IPM Consulting undertakes to warn persons who have received the personal data of the Visitor that these data can be used only for the purposes for which they were communicated, and to demand from these persons confirmation that this rule is observed.
6.5. Persons who have received the personal data of the Visitor are obliged to maintain the confidentiality (confidentiality) regime.
6.6. IPM Consulting processes and conducts measures to protect the personal data of Website visitors in accordance with the provisions of this Policy, as well as other documents issued in IPM Consulting.
7. Ensuring the Protection and Security of Personal Data
7.1. IPM Consulting applies appropriate standards of technological and operational security to protect the information provided by Website visitors from unauthorized access, disclosure, distortion, blocking, or destruction.
7.2. The measures applied at IPM Consulting include:
- Appointment of a responsible person for organizing the processing of personal data;
- Application of legal, technical, and organizational measures to ensure the security of personal data;
- Assessment of the damage that may be caused to the subjects of personal data in case of violation of the requirements of the legislation, the ratio of damage, and the security measures taken by IPM Consulting;
- Use of protected premises for placing servers of personal data information systems, as well as the use of lockable cabinets for storing paper carriers of personal data;
- Familiarization of IPM Consulting employees who directly process personal data with the provisions of the legislation of the Russian Federation on personal data;
- Control over the measures taken to ensure the security of personal data.
7.3. Access to personal data is provided only to authorized employees of IPM Consulting who have taken on the obligation to keep such information confidential.
8. Storage of Personal Data
8.1. Personal data of Website visitors are stored for the period necessary for the purposes for which such data were provided or for the period provided by legislation.
8.2. Upon achieving the objectives/expiry of the period for processing personal data, the personal data of Website visitors are destroyed.
9. Log Information, "Cookies" and "Web Beacons" Technologies
9.1. The IPM Consulting Website collects standard log session information, including the IP address, type and language of the browser, as well as data about the time of the visit and the addresses of websites from which the transition was made by links. In order to ensure effective management of the Website and assist in setting up the user interface, IPM Consulting may
use cookies (small-sized text files stored in the visitor's browser) or web beacons (web beacons - electronic images) together with tracking pixels, allowing the Website to count the number of visitors who have entered a certain page and provide access to certain cookie files.
The collected standard information is used exclusively for statistical purposes. IPM Consulting does not use personal data for the purpose of personally identifying anyone from the Visitors.
9.2. By using the Website, the Visitor agrees that IPM Consulting may download cookie files to the Visitor's device according to the conditions described above.
9.3. The Visitor has the opportunity to manage cookie files by accessing the browser settings. In case of deletion of cookie files, all data about the Visitor's preferences, including the preference to refuse the use of cookie files, will be deleted. In case of blocking cookie files, changes may affect the user interface, and some components of the Website may become unavailable.
10. Final Provisions
10.1. This Policy is subject to change or supplement in cases of making appropriate changes or additions to the current legislation of the Russian Federation on personal data, as well as may be changed at any time at the discretion of IPM Consulting. The current edition of the Policy in IPM Consulting is always available for viewing by an unlimited number of people on the website at the permanent address: www.ipmconsult.ru.
10.2. All relations involving IPM Consulting concerning the processing and protection of personal data and not receiving direct reflection in this Policy are regulated according to the provisions of the current legislation of the Russian Federation on personal data.
10.3. Control over the implementation of the requirements of this Policy is carried out by the General Director of IPM Consulting.
1.1. This Policy on Personal Data Processing (hereinafter referred to as the Policy), adopted by IPM Consulting Limited Liability Company (OGRN: 1175007002807, INN: 5044107790, legal address: 127015, Moscow, Novodmitrovskaya St., 2, bldg. 2, floor 18, office 19) (hereinafter referred to as IPM Consulting), defines the main principles, objectives, procedures, and conditions for processing personal data of website visitors, measures to ensure the security and protection of personal data.
1.2. This Policy is developed in accordance with the Constitution of the Russian Federation, laws, and other regulatory legal acts of the Russian Federation in the field of personal data and is published for unrestricted access on the IPM Consulting website at: www.ipmconsult.ru.
1.3. The terms used in this Policy are interpreted in accordance with their definition given in the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data".
1.4. IPM Consulting guarantees the confidentiality of the received personal data in accordance with the provisions of this Policy and undertakes to use them only for the purposes specified in the Policy.
2. Concept and Composition of Personal Data
2.1. The list of personal data subject to protection at IPM Consulting is formed in accordance with the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data".
2.2. IPM Consulting processes and protects the personal data (including surname, first name, place of work, position, contact phone number, email address, and other provided data) of the visitors of the IPM Consulting website www.ipmconsult.ru (hereinafter referred to as the Website), as well as personal data received at the corporate mail addresses of IPM Consulting ending with @ipmconsult.ru (hereinafter referred to as Corporate Mail), of subjects who have given their Consent to the processing of personal data (hereinafter referred to as Consent) by sending information through selected forms (hereinafter referred to as Forms) on the Website pages or by sending an email. The moment of giving Consent is marked by ticking the appropriate field in the Form and clicking the send button of the Form on any page of the Website, as well as clicking the send button of the email containing the subject's personal data to the Corporate Mail address.
2.3. During the viewing of the IPM Consulting Website, reading texts, and downloading other information, certain data about the computer from which the Website visitor views the IPM Consulting Website is automatically registered. When viewing the IPM Consulting Website, the following information is collected:
- The date and time of the visit to the Website;
- The number of pages visited, their names, and the duration of viewing;
- The IP address assigned to the device for Internet access;
- The type of browser and operating system;
- The URL of the website from which the transition was made.
3. Objectives of Processing Personal Data
3.1. The processing of personal data of Website visitors is carried out for purposes such as:
- Providing visitors with the opportunity for feedback with IPM Consulting;
- Providing Website visitors with consultations on issues related to the services provided, for marketing activities and support of Website visitors, as well as for other purposes not contrary to the current legislation of the Russian Federation and the terms of agreements between and corresponding Website visitors.
4. Principles and Conditions for Processing Personal Data
4.1. The processing of personal data is based on the following principles:
- Legality and fair basis;
- Limitation to achieving specific, predefined, and lawful purposes;
- Prevention of processing personal data incompatible with the purposes of collecting personal data;
- The content and volume of processed personal data must correspond to the stated processing purposes;
- Storage of personal data is carried out in a form that allows identifying 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, a contract, the party of which, the beneficiary, or guarantor is the subject of personal data;
- Other principles provided by the current legislation of the Russian Federation on personal data.
4.2. The processing of personal data is carried out if at least one of the conditions is met:
- The subject of personal data has given Consent to the processing of personal data;
- Processing of personal data is necessary for the realization of the rights and legitimate interests of IPM Consulting for achieving socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
- Processing of personal data is carried out for statistical or other research purposes, provided that personal data is obligatorily depersonalized;
- Other conditions provided by the current legislation of the Russian Federation on personal data.
5. Rights and Obligations of the Personal Data Subject
5.1. The subject of personal data has the right to:
- Demand clarification of their personal data, their updating, blocking, or destruction;
- Receive a list of their personal data processed by IPM Consulting, the source of their receipt, information about the terms of processing their personal data, including the terms of their storage, and other information about the processing of their personal data;
- Demand notification of all persons to whom their incorrect or incomplete personal data were previously communicated, about all corrections or additions made;
- Appeal in the prescribed manner against unlawful actions or inactions when processing their personal data.
5.2. Website visitors are obliged to provide only accurate data about themselves.
5.3. Consent to the processing of personal data is given by the Visitor for the entire period necessary for IPM Consulting to achieve the processing objectives.
5.4. Consent to the processing of personal data can be revoked by the Visitor by sending a written statement to the address: 127015, Moscow, Novodmitrovskaya St., 2, bldg. 2, floor 18, office 19 or to the Corporate Mail address (info@ipmconsult.ru).
6. Rights and Obligations of IPM Consulting
6.1. In the course of processing personal data, IPM Consulting is entitled to carry out: collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of the Visitor's personal data.
6.2. IPM Consulting is not entitled to transfer the personal data of Website visitors to a third party except for the following persons:
- Authorized state authorities within their powers;
- Persons to whom IPM Consulting is obliged to transfer them for compliance with the legislation of the Russian Federation;
- Persons to whom IPM Consulting transfers personal data for the execution of the contract with the subject of personal data;
- Persons to whom IPM Consulting entrusts the processing of personal data, including persons providing technical support to IPM Consulting, ensuring the maintenance and use of the necessary IT systems,
- Other persons with the consent of the subject of personal data.
6.3. IPM Consulting is not entitled to disclose the personal data of the Website Visitor for commercial purposes without his consent. Processing of the Visitor's personal data for the purpose of promoting goods, works, services on the market by making direct contacts with a potential consumer using communication means is allowed only with the prior consent of the Visitor.
6.4. IPM Consulting undertakes to warn persons who have received the personal data of the Visitor that these data can be used only for the purposes for which they were communicated, and to demand from these persons confirmation that this rule is observed.
6.5. Persons who have received the personal data of the Visitor are obliged to maintain the confidentiality (confidentiality) regime.
6.6. IPM Consulting processes and conducts measures to protect the personal data of Website visitors in accordance with the provisions of this Policy, as well as other documents issued in IPM Consulting.
7. Ensuring the Protection and Security of Personal Data
7.1. IPM Consulting applies appropriate standards of technological and operational security to protect the information provided by Website visitors from unauthorized access, disclosure, distortion, blocking, or destruction.
7.2. The measures applied at IPM Consulting include:
- Appointment of a responsible person for organizing the processing of personal data;
- Application of legal, technical, and organizational measures to ensure the security of personal data;
- Assessment of the damage that may be caused to the subjects of personal data in case of violation of the requirements of the legislation, the ratio of damage, and the security measures taken by IPM Consulting;
- Use of protected premises for placing servers of personal data information systems, as well as the use of lockable cabinets for storing paper carriers of personal data;
- Familiarization of IPM Consulting employees who directly process personal data with the provisions of the legislation of the Russian Federation on personal data;
- Control over the measures taken to ensure the security of personal data.
7.3. Access to personal data is provided only to authorized employees of IPM Consulting who have taken on the obligation to keep such information confidential.
8. Storage of Personal Data
8.1. Personal data of Website visitors are stored for the period necessary for the purposes for which such data were provided or for the period provided by legislation.
8.2. Upon achieving the objectives/expiry of the period for processing personal data, the personal data of Website visitors are destroyed.
9. Log Information, "Cookies" and "Web Beacons" Technologies
9.1. The IPM Consulting Website collects standard log session information, including the IP address, type and language of the browser, as well as data about the time of the visit and the addresses of websites from which the transition was made by links. In order to ensure effective management of the Website and assist in setting up the user interface, IPM Consulting may
use cookies (small-sized text files stored in the visitor's browser) or web beacons (web beacons - electronic images) together with tracking pixels, allowing the Website to count the number of visitors who have entered a certain page and provide access to certain cookie files.
The collected standard information is used exclusively for statistical purposes. IPM Consulting does not use personal data for the purpose of personally identifying anyone from the Visitors.
9.2. By using the Website, the Visitor agrees that IPM Consulting may download cookie files to the Visitor's device according to the conditions described above.
9.3. The Visitor has the opportunity to manage cookie files by accessing the browser settings. In case of deletion of cookie files, all data about the Visitor's preferences, including the preference to refuse the use of cookie files, will be deleted. In case of blocking cookie files, changes may affect the user interface, and some components of the Website may become unavailable.
10. Final Provisions
10.1. This Policy is subject to change or supplement in cases of making appropriate changes or additions to the current legislation of the Russian Federation on personal data, as well as may be changed at any time at the discretion of IPM Consulting. The current edition of the Policy in IPM Consulting is always available for viewing by an unlimited number of people on the website at the permanent address: www.ipmconsult.ru.
10.2. All relations involving IPM Consulting concerning the processing and protection of personal data and not receiving direct reflection in this Policy are regulated according to the provisions of the current legislation of the Russian Federation on personal data.
10.3. Control over the implementation of the requirements of this Policy is carried out by the General Director of IPM Consulting.
