Privacy Policy for Personal Data Processing
1. General Provisions
This Personal Data Processing Policy is developed in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by the Limited Liability Company "Information Systems InterMed" (TIN/KPP 1685007060/168501001, OGRN 1221600080349) (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to ensure the rights and freedoms of individuals in the processing of their personal data, including the protection of rights to privacy, personal, and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://telepacs.ru/.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except in cases where processing is required to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases that ensure their accessibility via the internet at the web address https://telepacs.ru/.
2.4. Personal data information system — a collection of personal data contained in databases and the information technology and technical means ensuring their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine, without the use of additional information, to which specific user or other personal data subject the data pertains.
2.6. Processing of personal data — any action (operation) or a series of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state or municipal authority, legal or natural person, independently or jointly with others, organizing and/or performing personal data processing, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data — any information related directly or indirectly to a specific or identifiable visitor of the website https://telepacs.ru/.
2.9. Personal data authorized by the data subject for dissemination — personal data to which an unrestricted circle of individuals is granted access by the data subject through consent to the processing of personal data authorized for dissemination in accordance with the Personal Data Law.
2.10. User — any visitor to the website https://telepacs.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of individuals.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of individuals (transfer of personal data) or making personal data available to an unlimited number of people, including publication in the media, posting in information and telecommunications networks, or granting access to personal data in any other way.
2.13. Transboundary transfer of personal data — the transfer of personal data to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of the personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the data subject;
— if the data subject withdraws consent for the processing of personal data or submits a request to cease processing personal data, the Operator may continue processing personal data without the data subject’s consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list 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 data subject with information regarding the processing of their personal data upon request;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of data subjects in response to this body’s request within 10 days from the date of receipt of the request;
— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions;
— cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data as prescribed by the Personal Data Law;
— perform other duties as stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
— obtain information regarding the processing of their personal data, except in cases provided by federal laws. The information should be provided in an accessible form and should not contain personal data related to other data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for its obtaining are established by the Personal Data Law;
— require the Operator to correct, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, as well as take measures to protect their rights;
— set a condition for prior consent when personal data is processed for marketing purposes;
— withdraw consent for the processing of personal data, as well as submit a request to cease processing personal data;
— appeal to the authorized body for the protection of data subjects' rights or to a court regarding unlawful actions or omissions by the Operator in processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of any changes (updates, modifications) to their personal data.
4.3. Individuals who provide the Operator with inaccurate data about themselves or about another data subject without their consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-determined, and lawful purposes. Personal data processing incompatible with the purposes for which it was collected is not allowed.
5.3. The merging of databases containing personal data for processing purposes that are incompatible with each other is not allowed.
5.4. Only personal data that is relevant to the purposes of processing is processed.
5.5. The content and scope of processed personal data correspond to the stated processing purposes. The processing of personal data that is excessive in relation to the stated purposes is not allowed.
5.6. Personal data processing ensures the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the processing goals. The Operator takes necessary measures to delete or correct incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the data subject no longer than is necessary to achieve the processing goals, unless the retention period is established by federal law, contract, or by the data subject’s rights. Processed personal data is destroyed or anonymized once the processing goals are achieved or if the need to achieve these goals ceases, unless otherwise provided by federal law.
6.Purposes of Personal Data Processing
Purpose of processing:
Providing the User with access to services, information, and/or materials contained on the website.
Legal grounds
6. Types of Personal Data Processing
The types of personal data processing include:
- Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
- Sending informational emails to the email address provided by the data subject.
7. Conditions for Processing Personal Data
7.1. Personal data is processed with the consent of the data subject for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals stipulated by international treaties of the Russian Federation or laws, to exercise functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Personal data processing is necessary for the administration of justice, execution of a court decision, or an act of another body or official, subject to execution under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the data subject is a party, or a contract in which the data subject is a beneficiary or surety, as well as for the conclusion of a contract initiated by the data subject or for a contract in which the data subject will be a beneficiary or surety.
7.5. Personal data processing is necessary for the protection of rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data processing is carried out for personal data, the access to which is provided by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out if personal data is subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collecting, Storing, Transmitting, 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 current legislation on personal data protection.
8.1. The operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data by unauthorized persons.
8.2. The personal data of the user will never, under any circumstances, be transferred to third parties, except in cases required by applicable law or if the data subject has given consent to the operator for the transfer of their data to a third party for the performance of obligations under a civil law contract.
8.3. If any inaccuracies in personal data are identified, the user can update it independently by sending a notification to the operator’s email address info@misintermed.ru with the subject line "Personal Data Update".
8.4. The term of personal data processing is determined by the achievement of the goals for which the personal data was collected, unless a different term is provided by the contract or applicable legislation.
The user can revoke their consent for the processing of personal data at any time by sending a notification to the operator via email at info@misintermed.ru with the subject line "Revocation of Consent to Process Personal Data".
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreement and Privacy Policy. The operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Restrictions imposed by the data subject on the transfer (except for providing access) or the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination 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 during processing.
8.8. The operator stores personal data in a form that allows identification of the data subject for no longer than necessary to achieve the purposes of personal data processing unless the storage period is set by federal law, a contract to which the data subject is a party, or a beneficiary or surety.
8.9. The processing of personal data may cease once the processing goals have been achieved, the consent period expires, the consent is revoked by the data subject, or a requirement to cease processing personal data is received, or in the case of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data
9.1. The operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The operator performs automated processing of personal data with the receipt and/or transmission of the information received through information and telecommunication networks or without such transmission.
10. Cross-border Transfer of Personal Data
10.1. Before beginning cross-border personal data transfer activities, the operator must notify the authorized body for the protection of personal data subjects' rights about their intention to carry out the cross-border transfer of personal data (such notification is submitted separately from the notification about the intention to process personal data).
10.2. Before submitting the notification mentioned above, the operator must obtain the relevant information from foreign state bodies, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The operator and other persons who gain access to personal data are required not to disclose or distribute personal data to third parties without the consent of the data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. The user may receive any clarifications regarding the processing of their personal data by contacting the operator via email at info@misintermed.ru.
12.2. Any changes to the operator's personal data processing policy will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://telepacs.ru/privacy.
1. General Provisions
This Personal Data Processing Policy is developed in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by the Limited Liability Company "Information Systems InterMed" (TIN/KPP 1685007060/168501001, OGRN 1221600080349) (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to ensure the rights and freedoms of individuals in the processing of their personal data, including the protection of rights to privacy, personal, and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://telepacs.ru/.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except in cases where processing is required to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases that ensure their accessibility via the internet at the web address https://telepacs.ru/.
2.4. Personal data information system — a collection of personal data contained in databases and the information technology and technical means ensuring their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine, without the use of additional information, to which specific user or other personal data subject the data pertains.
2.6. Processing of personal data — any action (operation) or a series of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state or municipal authority, legal or natural person, independently or jointly with others, organizing and/or performing personal data processing, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data — any information related directly or indirectly to a specific or identifiable visitor of the website https://telepacs.ru/.
2.9. Personal data authorized by the data subject for dissemination — personal data to which an unrestricted circle of individuals is granted access by the data subject through consent to the processing of personal data authorized for dissemination in accordance with the Personal Data Law.
2.10. User — any visitor to the website https://telepacs.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of individuals.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of individuals (transfer of personal data) or making personal data available to an unlimited number of people, including publication in the media, posting in information and telecommunications networks, or granting access to personal data in any other way.
2.13. Transboundary transfer of personal data — the transfer of personal data to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of the personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the data subject;
— if the data subject withdraws consent for the processing of personal data or submits a request to cease processing personal data, the Operator may continue processing personal data without the data subject’s consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list 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 data subject with information regarding the processing of their personal data upon request;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of data subjects in response to this body’s request within 10 days from the date of receipt of the request;
— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions;
— cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data as prescribed by the Personal Data Law;
— perform other duties as stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
— obtain information regarding the processing of their personal data, except in cases provided by federal laws. The information should be provided in an accessible form and should not contain personal data related to other data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for its obtaining are established by the Personal Data Law;
— require the Operator to correct, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, as well as take measures to protect their rights;
— set a condition for prior consent when personal data is processed for marketing purposes;
— withdraw consent for the processing of personal data, as well as submit a request to cease processing personal data;
— appeal to the authorized body for the protection of data subjects' rights or to a court regarding unlawful actions or omissions by the Operator in processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of any changes (updates, modifications) to their personal data.
4.3. Individuals who provide the Operator with inaccurate data about themselves or about another data subject without their consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-determined, and lawful purposes. Personal data processing incompatible with the purposes for which it was collected is not allowed.
5.3. The merging of databases containing personal data for processing purposes that are incompatible with each other is not allowed.
5.4. Only personal data that is relevant to the purposes of processing is processed.
5.5. The content and scope of processed personal data correspond to the stated processing purposes. The processing of personal data that is excessive in relation to the stated purposes is not allowed.
5.6. Personal data processing ensures the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the processing goals. The Operator takes necessary measures to delete or correct incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the data subject no longer than is necessary to achieve the processing goals, unless the retention period is established by federal law, contract, or by the data subject’s rights. Processed personal data is destroyed or anonymized once the processing goals are achieved or if the need to achieve these goals ceases, unless otherwise provided by federal law.
6.Purposes of Personal Data Processing
Providing the User with access to services, information, and/or materials contained on the website.
- Personal data:
- - Last name, first name, patronymic
- - Email address
- - Phone numbers
- - Details of identity document
- - Social insurance certificate number, date of registration in the mandatory pension insurance system
- - Mandatory health insurance policy number
- - Information about education, profession, specialty, and qualifications, details of education documents
- - Information about previous positions held and work experience, military service obligations, military registration
- Charter (founding) documents of the Operator
- Agreements concluded between the operator and the data subject
The types of personal data processing include:
- Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
- Sending informational emails to the email address provided by the data subject.
7. Conditions for Processing Personal Data
7.1. Personal data is processed with the consent of the data subject for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals stipulated by international treaties of the Russian Federation or laws, to exercise functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Personal data processing is necessary for the administration of justice, execution of a court decision, or an act of another body or official, subject to execution under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the data subject is a party, or a contract in which the data subject is a beneficiary or surety, as well as for the conclusion of a contract initiated by the data subject or for a contract in which the data subject will be a beneficiary or surety.
7.5. Personal data processing is necessary for the protection of rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data processing is carried out for personal data, the access to which is provided by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out if personal data is subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collecting, Storing, Transmitting, 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 current legislation on personal data protection.
8.1. The operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data by unauthorized persons.
8.2. The personal data of the user will never, under any circumstances, be transferred to third parties, except in cases required by applicable law or if the data subject has given consent to the operator for the transfer of their data to a third party for the performance of obligations under a civil law contract.
8.3. If any inaccuracies in personal data are identified, the user can update it independently by sending a notification to the operator’s email address info@misintermed.ru with the subject line "Personal Data Update".
8.4. The term of personal data processing is determined by the achievement of the goals for which the personal data was collected, unless a different term is provided by the contract or applicable legislation.
The user can revoke their consent for the processing of personal data at any time by sending a notification to the operator via email at info@misintermed.ru with the subject line "Revocation of Consent to Process Personal Data".
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreement and Privacy Policy. The operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Restrictions imposed by the data subject on the transfer (except for providing access) or the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination 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 during processing.
8.8. The operator stores personal data in a form that allows identification of the data subject for no longer than necessary to achieve the purposes of personal data processing unless the storage period is set by federal law, a contract to which the data subject is a party, or a beneficiary or surety.
8.9. The processing of personal data may cease once the processing goals have been achieved, the consent period expires, the consent is revoked by the data subject, or a requirement to cease processing personal data is received, or in the case of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data
9.1. The operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The operator performs automated processing of personal data with the receipt and/or transmission of the information received through information and telecommunication networks or without such transmission.
10. Cross-border Transfer of Personal Data
10.1. Before beginning cross-border personal data transfer activities, the operator must notify the authorized body for the protection of personal data subjects' rights about their intention to carry out the cross-border transfer of personal data (such notification is submitted separately from the notification about the intention to process personal data).
10.2. Before submitting the notification mentioned above, the operator must obtain the relevant information from foreign state bodies, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The operator and other persons who gain access to personal data are required not to disclose or distribute personal data to third parties without the consent of the data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. The user may receive any clarifications regarding the processing of their personal data by contacting the operator via email at info@misintermed.ru.
12.2. Any changes to the operator's personal data processing policy will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://telepacs.ru/privacy.
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