Privacy policy

This personal data processing policy has been drawn up in accordance with the requirements of the Russia Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data.

1. General Provisions

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of a person and citizen when processing his 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—the Policy) applies to all information that the Operator may receive about visitors of the website smm-e.ru.

2. Key concepts used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address smm-e.ru.
2.4. Personal data information system — a collection of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. 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 by a specific User or another subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a government agency, municipal agency, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and also determines 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 — information related to a specific or determinable User of the website smm-e.ru.
2.9. Personal data permitted for distribution by the personal data subject — personal data, access to which by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter — Personal data permitted for distribution).
2.10. User — any visitor to the website smm-e.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 number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including disclosure of personal data in the media, posting 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 government body of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;

— if the personal data subject revokes consent to the processing of personal data, as well as sends an appeal with a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;

— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on personal data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on personal data or other federal laws.
3.2. The operator is obliged to:
— provide the personal data subject, at his request, with information concerning the processing of his personal data;

— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

— respond to appeals to requests of personal data subject to the requirements of the Law on Personal Data;

—to notify the authorized body for the protection of the rights of personal data subjects, at the request of this body, of the necessary information within 10 days from the date of receipt of such request;

— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on personal data;

— fulfill other obligations stipulated by the Law on personal data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, with the exception of cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, with the exception of cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;

— to demand from the operator clarification of his personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also to take measures provided by law to protect his rights;

— to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;

— to revoke consent to the processing of personal data, as well as to send a request to stop processing personal data;

— appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing his personal data;

— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable data about themselves;

— notify the Operator about clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the latter's consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data shall be processed only to achieve specific, predetermined and lawful purposes. Personal data shall not be processed in a manner that is incompatible with the purposes for which the personal data were collected.
5.3. Databases containing personal data processed for purposes that are incompatible with each other shall not be combined.
5.4. Only personal data that meet the purposes for which they are processed shall be processed.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessive amounts of processed personal data in relation to the stated purposes of their processing are not allowed.
5.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing the personal data are ensured. The operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the subject of personal data to be identified, for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in the event of loss of the need to achieve these purposes, 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 smm-e.ru
Personal data	last name, first name e-mail address phone numbers ID (user identifier) in instant messengers or social networks: VK, Telegram, Yandex, Instagram, Max, WhatsApp IP address

Purpose of processing	informing the User by sending emails
Personal data	last name, first name e-mail address

Purpose of processing	informing the User by sending SMS messages or calls
Personal data	last name, first name phone numbers

Purpose of processing	informing the User by sending messages or calls in messengers and social networks: VK, Telegram, Instagram, Max, WhatsApp
Personal data	last name, first name phone numbers ID (user identifier) username (short link, login, nickname)

7. Terms of personal data processing

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. Personal data shall be processed to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data shall be processed to administer justice, execute a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise 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 is carried out, access to which by an unlimited number of persons is granted by the personal data subject or at his/her request (hereinafter referred to as Publicly Available Personal Data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for collecting, storing, transferring and other types of processing 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 requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given the Operator's consent to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3. In the event that inaccuracies are detected in the personal data, the User can update them independently by sending the Operator a notification to the Operator's email address support@smm-e.ru marked "Updating personal data".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or applicable law. The User may at any time revoke their consent to the processing of personal data by sending the Operator a notification via e-mail to the Operator's e-mail address support@smm-e.ru with the subject line "Revocation of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the said persons (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 specified in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or the conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined 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 identifying the subject of personal data, for no longer than required for the purposes of processing the personal data, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or a requirement to terminate the processing of personal data, as well as the detection of illegal processing of personal data.

9. List of actions performed by the Operator with the received personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before commencing activities related to the cross-border transfer of personal data, the operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification shall be sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the operator shall receive the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Final Provisions

12.1. The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail support@smm-e.ru.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at smm-e.ru/en/privacy-policy.