Policy on data processing
1. General ProvisionsThis policy of personal data processing is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006. No. 152-FZ “On Personal Data” (hereinafter - the Personal Data Law) and defines the procedure of personal data processing and measures to ensure the security of personal data taken by Simple City Estate LLC (hereinafter - the Operator).
1.1. The Operator sets as its most important goal and condition of its activity the observance of human and citizen's rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about the visitors of the website
https://simplecity-estate.com/2. Basic Concepts Used in the Policy2.1. Automated processing of personal data - processing of personal data by means of computer equipment.
2.2. Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://simplecity-estate.com/
2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Personal data depersonalization - actions as a result of which it is impossible to determine, without using additional information, whether personal data belong to a particular User or other subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation means or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal entity or natural person, independently or jointly with other persons organizing and/or carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a certain or defined User of the website https://simplecity-estate.com/
2.9. Personal data authorized by the subject of personal data for dissemination - personal data to which access to an unlimited number of persons is granted by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data authorized for dissemination).
2.10. User - any visitor of the website https://simplecity-estate.com/
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number of persons, including disclosure 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 - transfer of personal data to the territory of a foreign country to a foreign government authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the personal data subject;
— in the event that the personal data subject withdraws consent to the processing of personal data, or sends a request demanding the cessation of personal data processing, the Operator has the right to continue processing the personal data without the subject’s consent if there are grounds specified in the Personal Data Law;
— independently determine the set and scope 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 is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedures established by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects with the necessary information within 10 days from the date of receiving such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions involving personal data;
— cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information must be provided by the Operator in an accessible form and must not contain personal data relating to other subjects, unless there are legal grounds for the disclosure of such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— request the Operator to clarify, block, or delete their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing, as well as take legal measures to protect their rights;
— require prior consent for the processing of their personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent for the processing of personal data, as well as submit a demand to cease the processing of their personal data;
— appeal to the authorized body for the protection of personal data subjects’ rights or to a court regarding unlawful actions or inaction by the Operator during the processing of their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of any clarifications (updates or changes) to their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent shall be held liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. The processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. It is not permitted to merge databases containing personal data that are processed for purposes that are incompatible with each other.
5.4. Only personal data that are relevant to the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data must correspond to the stated purposes of processing. Excessive processing of personal data in relation to the declared purposes is not permitted.
5.6. Personal data must be accurate, sufficient, and, where necessary, kept up to date in relation to the purposes of processing. The Operator shall take the necessary measures and/or ensure that such measures are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data must be stored in a form that allows the identification of the personal data subject for no longer than is required for the purposes of processing, unless a longer storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon the achievement of the purposes of processing or when the need to achieve these purposes no longer exists, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose of Processing — informing the User by sending email messages.
Personal Data:
-email address
-phone numbers
-last name and first name
Legal Basis — Federal Law No. 152-FZ “On Personal Data”
Types of Personal Data Processing: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
7. Conditions for Personal Data Processing7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the realization of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data made publicly available by the personal data subject or at their request is carried out (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure under federal law is carried out.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data ProcessingThe 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 current legislation in the field of personal data protection.
8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If any inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator's email address at info@simplecity-estate.com with the subject line "Update of 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 a different period is specified by a contract or applicable legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notice to the Operator via email at info@simplecity-estate.com with the subject line "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their own User Agreements and Privacy Policies. The personal data subject is responsible for familiarizing themselves with these documents. The Operator bears no responsibility for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer (except granting access), processing, or conditions of processing of personal data permitted for distribution do not apply when such data is processed in the interest of the state, society, or other public purposes as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than required for the purposes of personal data processing, unless a different retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for the termination of personal data processing may include the achievement of the processing purposes, expiration of the subject’s consent period, withdrawal of consent by the personal data subject, a demand to cease processing, or the identification of unlawful personal data processing.
9. List of Actions Performed by the Operator with Collected Personal Data9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the obtained information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data10.1. Prior to commencing any cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such a transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal DataThe Operator and other persons who have access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions12.1. The User may obtain any clarification regarding questions related to the processing of their personal data by contacting the Operator via email at info@simplecity-estate.com
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced with a new version.
12.3. The current version of the Policy is publicly available on the Internet at: https://simplecity-estate.com/