Personal data processing policy
1. General provisions
This personal data processing policy has been drawn up in accordance with Federal Law of 27.07.2006 No. 152-ФЗ ‘On Personal Data’ (the Personal Data Law) and defines the personal data processing procedure and the measures taken by Get Leads (the Operator) to ensure the security of personal data.
1.1. The Operator considers respect for human and civil rights and freedoms when processing personal data, including the protection of privacy and personal and family confidentiality, to be its most important objective and a condition of its activities.
1.2. This Operator's personal data processing policy (the Policy) applies to all information the Operator may receive about visitors to https://getleads.red.
2. Basic terms used in the Policy
2.1. Automated processing of personal data means processing personal data using computing equipment.
2.2. Blocking personal data means temporarily suspending processing, except where processing is necessary to clarify personal data.
2.3. Website means a collection of graphic and informational materials, computer programs and databases that make them available on the internet at https://getleads.red.
2.4. Personal data information system means the personal data held in databases together with the information technologies and technical equipment used to process it.
2.5. Anonymization of personal data means actions that make it impossible, without additional information, to determine whether personal data belongs to a particular User or another personal data subject.
2.6. Processing of personal data means any action or set of actions performed on personal data, with or without automation, including collection, recording, systematization, accumulation, storage, clarification (updating or alteration), retrieval, use, transfer (dissemination, provision or access), anonymization, blocking, deletion and destruction.
2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with others, organizes and/or performs personal data processing and determines its purposes, the personal data to be processed and the actions to be performed on that data.
2.8. Personal data means any information directly or indirectly relating to an identified or identifiable User of https://getleads.red.
2.9. Personal data authorized for dissemination by the data subject means personal data to which the data subject has granted access to an unlimited number of people by consenting to the processing of personal data authorized for dissemination in accordance with the Personal Data Law (data authorized for dissemination).
2.10. User means any visitor to https://getleads.red.
2.11. Provision of personal data means actions aimed at disclosing personal data to a particular person or defined group of people.
2.12. Dissemination of personal data means any action aimed at disclosing personal data to an indefinite group of people (transfer of personal data) or making personal data available to an unlimited number of people, including publication in the media, placement on information and telecommunications networks or providing access by any other means.
2.13. Cross-border transfer of personal data means transferring personal data to a foreign state, to a foreign state authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data means any action that irreversibly destroys personal data so that its content cannot subsequently be restored in a personal data information system and/or destroys physical media containing personal data.
3. Principal 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;
— continue processing personal data without the data subject's consent when the subject withdraws consent or requests that processing stop, if grounds provided by the Personal Data Law exist;
— independently determine the composition and list of measures necessary and sufficient to fulfill the obligations under the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by that Law or other federal laws.
3.2. The Operator must:
— provide the data subject, upon request, with information concerning the processing of their personal data;
— organize personal data processing in accordance with current legislation of the Russian Federation;
— respond to inquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law;
— provide the authorized authority for the protection of data subjects' rights with the necessary information upon its request within 10 days of receiving that request;
— publish or otherwise provide unrestricted access to this personal data processing Policy;
— take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions;
— stop transferring (disseminating, providing or granting access to) personal data, cease processing and destroy personal data in the manner and circumstances provided by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. Principal rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided by federal laws. The Operator must supply this information in an accessible form, without personal data relating to other data subjects unless lawful grounds exist for disclosing it. The Personal Data Law defines the information to be supplied and the procedure for obtaining it;
— require the Operator to clarify, block or destroy personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose, and take measures provided by law to protect their rights;
— require prior consent for processing personal data to promote goods, works and services on the market;
— withdraw consent to personal data processing and request that processing cease;
— challenge the Operator's unlawful actions or inaction in processing their personal data before the authorized authority for protecting data subjects' rights or in court;
— exercise other rights provided by Russian Federation legislation.
4.2. Personal data subjects must:
— provide the Operator with accurate information about themselves;
— notify the Operator of clarifications (updates or changes) to their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another data subject without that person's consent are liable under Russian Federation legislation.
5. Principles of personal data processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Processing is limited to achieving specific, predetermined and lawful purposes. Processing incompatible with the purposes for which personal data was collected is prohibited.
5.3. Combining databases containing personal data processed for mutually incompatible purposes is prohibited.
5.4. Only personal data that meets the purposes of its processing may be processed.
5.5. The content and volume of personal data processed must correspond to the stated purposes. Processing personal data that is excessive in relation to those purposes is prohibited.
5.6. Processing must ensure the accuracy and sufficiency of personal data and, where necessary, its relevance to the processing purposes. The Operator takes, and/or ensures that others take, the necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that permits identification of the data subject for no longer than the processing purposes require, unless a storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized when the processing purposes are achieved or no longer need to be achieved, unless federal law provides otherwise.
6. Purposes of personal data processing
Purpose of processing | collecting analytics |
Personal data |
- visits, statistics
Legal grounds |
- Federal Law of July 27, 2006, No. 149-ФЗ ‘On Information, Information Technologies and Information Protection’
Types of personal data processing |
- Collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
7. Conditions for personal data processing
7.1. Personal data is processed with the data subject's consent to that processing.
7.2. Processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, or to perform functions, powers and duties imposed on the Operator by Russian Federation legislation.
7.3. Processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official that is enforceable under Russian Federation legislation on enforcement proceedings.
7.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, or to conclude a contract at the data subject's initiative or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant objectives, provided that the data subject's rights and freedoms are not violated.
7.6. Personal data to which an unlimited number of people have been granted access by the data subject or at their request is processed (publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure under federal law is processed.
8. Procedure for collecting, storing, transferring and otherwise processing personal data
The security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to comply fully with current legislation on personal data protection.
8.1. The Operator safeguards personal data and takes every possible measure to prevent unauthorized persons from accessing it.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except to comply with current legislation or where the data subject has consented to the Operator transferring the data to a third party to fulfill obligations under a civil-law contract.
8.3. If inaccuracies are found in personal data, the User may update it by sending a notice to the Operator's email address, servis.get.leads@gmail.com, with the subject ‘Personal data update’.
8.4. The processing period is determined by the achievement of the purposes for which personal data was collected, unless a different period is provided by contract or current legislation.
The User may withdraw consent to personal data processing at any time by emailing the Operator at servis.get.leads@gmail.com with the subject ‘Withdrawal of consent to personal data processing’.
8.5. All information collected by third-party services, including payment systems, communications providers and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with those documents. The Operator is not responsible for third parties' actions, including those of the service providers mentioned in this clause.
8.6. Prohibitions imposed by the data subject on transfer (other than granting access), processing, or processing conditions (other than obtaining access) for data authorized for dissemination do not apply where personal data is processed in state, social or 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 permitting identification of the data subject for no longer than the processing purposes require, unless a storage period is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor.
8.9. Grounds for ending processing may include achievement of the processing purposes, expiry of the data subject's consent, withdrawal of consent or a request to cease processing, as well as discovery of unlawful processing.
9. Actions performed by the Operator on personal data received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates or alters), retrieves, uses, transfers (disseminates, provides or grants access to), anonymizes, blocks, deletes and destroys personal data.
9.2. The Operator processes personal data automatically, with or without receiving and/or transferring the resulting information over information and telecommunications networks.
10. Cross-border transfer of personal data
10.1. Before starting cross-border transfers of personal data, the Operator must notify the authorized authority for the protection of data subjects' rights of its intention to make such transfers. This notice is submitted separately from the notice of intent to process personal data.
10.2. Before submitting that notice, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals and foreign legal entities to which cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons who gain access to personal data must not disclose it to third parties or disseminate it without the data subject's consent, unless federal law provides otherwise.
12. Final provisions
12.1. The User may obtain clarification on any matters concerning the processing of their personal data by contacting the Operator by email at servis.get.leads@gmail.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 replaced by a new version.
12.3. The current version of the Policy is freely available online at https://getleads.red/privacy.
