Personal Data Processing Policy
1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ dated 27 July 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and sets out the procedure for processing personal data and measures to ensure the security of personal data undertaken by Gyrolab LLC (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to observe the human and civil rights and freedoms when processing personal data, including the protection of the 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 obtain about visitors to the website
https://gyrolab.ru/
2. Basic terms used in the Policy
2.1.
Automated processing of personal data — processing of personal data by means of computer technology.
2.2.
Blocking of personal data — temporary cessation of processing of personal data (except where processing is necessary to rectify (update, modify) personal data).
2.3.
Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address
https://gyrolab.ru/
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.
Anonymization (depersonalization) of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other personal data subject.
2.6.
Processing of personal data — any action (operation) or set of actions (operations) performed using automation or without using such means with personal data, including collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization (depersonalization), blocking, deletion, destruction of personal data.
2.7.
Operator — a state body, municipal body, legal entity or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, 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://gyrolab.ru/
2.9.
Personal data permitted by the data subject for dissemination — personal data to which an unlimited number of persons have been granted access by the data subject by giving consent to the processing of personal data permitted by the data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10.
User — any visitor to the website
https://gyrolab.ru/
2.11.
Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12.
Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunications 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 state to a foreign state authority, foreign natural person, or foreign legal entity.
2.14.
Destruction of personal data — any actions as a result of which personal data are destroyed irreversibly with the impossibility of further restoration of the content of personal data in the personal data information system and/or physical 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 data subject accurate information and/or documents containing personal data;
— in the event of withdrawal by the data subject of consent to the processing of personal data, as well as submission of a request demanding termination of processing of personal data, the Operator has the right to continue processing personal data without the data subject's consent if there are grounds specified in the Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:— to provide the data subject, at their request, with information concerning the processing of their personal data;
— to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— to respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to provide the authorized body for the protection of the rights of personal data subjects, upon request of this body, with the necessary information within 10 days from the date of receipt of such a request;
— to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with respect to personal data;
— to cease transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to perform other obligations provided for by the Personal Data Law.
4. Basic rights and obligations of data subjects
4.1. Data subjects have the right:— to receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the data subject by the Operator in an accessible form, and it must not contain personal data relating to other data subjects, except in cases where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— to demand that the operator rectify, block, or destroy their personal data if the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
— to set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to submit a demand to cease processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged:— to provide the Operator with accurate information about themselves;
— to inform the Operator of rectification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another data subject without the latter's consent shall be held liable in accordance with the legislation of the Russian Federation.
5. Principles of processing of personal data
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance in relation to the purposes of processing personal data is ensured. The Operator takes necessary measures and/or ensures their adoption to delete or rectify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or anonymized upon achievement of the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided for by federal law.
6. Purposes of processing personal data
Purpose of processing: Informing the User by sending email messages.
Personal data:Email address
User's name and company
Legal grounds:Federal Law No. 149-FZ dated 27 July 2006 "On Information, Information Technologies and Information Protection".
Federal Law No. 152-FZ dated 27 July 2006 "On Personal Data".
Types of processing of personal data:Collection, recording, systematization, accumulation, storage, destruction, and anonymization (depersonalization) of personal data.
Sending informational emails to an email address.
7. Conditions of processing of personal data
7.1. Processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice and for the execution of a court decision, or an act of another authority or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the data subject's initiative, or a contract under which the data subject will be the beneficiary or guarantor.
7.5. Processing of personal data is necessary for exercising the rights and legitimate interests of the Operator or third parties, or for achieving socially significant objectives, provided that this does not violate the rights and freedoms of the data subject.
7.6. Processing is carried out in respect of personal data to which an unlimited number of persons have been granted access by the data subject or at the data subject's request (hereinafter referred to as "publicly available personal data").
7.7. Processing is carried out in respect of personal data that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for collection, storage, transfer, and other types of processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the applicable legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all reasonable measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never be transferred to third parties under any circumstances, except where such transfer is required by applicable law, or where the data subject has provided consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator's email address
sales@gyrolab.ru with the subject line "Personal Data Update".
8.4. The processing period for personal data is determined by achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via email to the Operator's email address
sales@gyrolab.ru with the subject line "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 such parties (operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or the User should review those documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions on transfer (other than granting access) and on processing, or conditions of processing (other than obtaining access), of personal data permitted for dissemination that are established by the data subject do not apply where personal data are processed in state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the data subject for no longer than required by the purposes of processing personal data, unless the retention period is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the consent, withdrawal of consent by the data subject, or a request to terminate processing, as well as upon discovery of unlawful processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization (depersonalization), blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the received information via information and telecommunications networks, or without using such networks.
10. Cross-border transfer of personal data
10.1. Prior to commencing activities related to cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notice is submitted separately from the notice of intention to process personal data).
10.2. Before submitting the above notice, the Operator must obtain from the competent authorities of the foreign state, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of personal data
The Operator and other persons who have access to personal data must not disclose personal data to third parties or disseminate personal data without the data subject's consent, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at
sales@gyrolab.ru.
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 publicly available on the Internet at:
https://gyrolab.ru/privacy/en