Personal data processing policy
1. General provisions
This personal data processing policy has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the Personal Data Law). It defines the procedures for processing personal data and the security measures taken by Konstantin Olegovich Sereda (the Operator).
1.1. Respect for human and civil rights and freedoms when processing personal data, including privacy and personal and family confidentiality, is a primary objective and prerequisite of the Operator’s activities.
1.2. This personal data processing policy (the Policy) applies to all information the Operator may obtain about visitors to https://www.simplify-bots.com.
2. Definitions used in this Policy
2.1. Automated personal data processing means processing personal data using computing equipment.
2.2. Blocking personal data means temporarily suspending its processing, except where processing is required to clarify the data.
2.3. Website means the collection of graphical and informational materials, software and databases made available online at https://www.simplify-bots.com.
2.4. A personal data information system comprises personal data held in databases and the information technologies and technical equipment used to process it.
2.5. Anonymisation means actions that make it impossible to attribute personal data to a particular User or other data subject without additional information.
2.6. Personal data processing means any operation or set of operations, automated or otherwise, including collection, recording, organisation, accumulation, storage, clarification (updating or amendment), retrieval, use, transfer (distribution, provision or access), anonymisation, blocking, deletion and destruction.
2.7. Operator means a public or municipal authority, legal entity or individual that, alone or jointly, organises and/or carries out personal data processing and determines its purposes, the data to be processed and the operations performed.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://www.simplify-bots.com.
2.9. Personal data authorised for distribution means data to which the data subject grants access to an unlimited number of persons by consenting to its processing for distribution under the Personal Data Law.
2.10. User means any visitor to https://www.simplify-bots.com.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Distribution means any action aimed at disclosing personal data to an unspecified group of persons or allowing an unlimited number of persons to access it, including publication in the media, on information and telecommunications networks, or access by any other means.
2.13. Cross-border transfer means the transfer of personal data to the territory of a foreign state, to a foreign public authority, individual or legal entity.
2.14. Destruction means actions that irreversibly destroy personal data so its content cannot be restored in the information system, and/or destroy the physical media containing it.
3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
– obtain accurate information and/or documents containing personal data from the data subject;
– continue processing personal data after consent has been withdrawn where grounds specified in the Personal Data Law apply;
– independently determine the necessary and sufficient measures to fulfil obligations under the Personal Data Law and related regulations, unless otherwise provided by that Law or other federal laws.
3.2. The Operator must:
– provide the data subject, upon request, with information about the processing of their personal data;
– organise processing in accordance with applicable Russian legislation;
– respond to enquiries and requests from data subjects and their legal representatives as required by the Personal Data Law;
– provide information requested by the competent authority for the protection of data subjects’ rights within 30 days of receiving the request;
– publish this Policy or otherwise make it freely accessible;
– take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions;
– stop transferring (distributing, providing or granting access to) and processing personal data, and destroy it, in the cases and manner prescribed by the Personal Data Law;
– fulfil other obligations under the Personal Data Law.
4. Main rights and obligations of data subjects
4.1. Data subjects have the right to:
– receive information about the processing of their personal data, except as provided by federal law. The Operator must provide it in an accessible form without disclosing other persons’ data, unless lawful grounds for disclosure exist. The Personal Data Law defines the information available and how to obtain it;
– require clarification, blocking or destruction of incomplete, outdated, inaccurate, unlawfully obtained or unnecessary data, and take legal measures to protect their rights;
– require prior consent for processing aimed at promoting goods, works or services;
– withdraw consent to personal data processing;
– challenge unlawful actions or omissions by the Operator before the competent data protection authority or a court;
– exercise other rights under Russian legislation.
4.2. Data subjects must:
– provide the Operator with accurate information about themselves;
– notify the Operator of updates or changes to their personal data.
4.3. Persons providing false information about themselves or another person’s data without that person’s consent are liable under Russian legislation.
5. Personal data the Operator may process
5.1. Surname, first name and patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. Telegram username.
5.5. The website also collects and processes anonymised visitor data, including cookies, using web analytics services such as Yandex Metrica and Google Analytics.
5.6. The data listed above is collectively referred to as Personal Data in this Policy.
5.7. The Operator does not process special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, or intimate life.
5.8. Processing special-category personal data authorised for distribution, as listed in Article 10(1) of the Personal Data Law, is permitted subject to the prohibitions and conditions in Article 10.1.
5.9. Consent to process data authorised for distribution is obtained separately from other processing consents, subject in particular to Article 10.1 of the Personal Data Law. The competent authority determines the required content of this consent.
5.9.1. The User gives the Operator this consent directly.
5.9.2. Within three working days of receiving consent, the Operator must publish the processing conditions, including any prohibitions or conditions on processing the data by an unlimited number of persons.
5.9.3. Transfer (distribution, provision or access) of data authorised for distribution must cease at any time at the data subject’s request. The request must include their surname, first name, patronymic if any, contact details (phone, email or postal address), and the data whose processing must stop. Data in the request may only be processed by the Operator to whom it is addressed.
5.9.4. Consent to process data authorised for distribution ceases when the Operator receives the request described in clause 5.9.3.
6. Principles of personal data processing
6.1. Personal data is processed lawfully and fairly.
6.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes of collection is prohibited.
6.3. Databases containing personal data processed for incompatible purposes must not be combined.
6.4. Only data relevant to the purposes of processing is processed.
6.5. The content and volume of data must match the stated purposes. Excessive data processing relative to those purposes is prohibited.
6.6. Data must be accurate, sufficient and, where necessary, up to date for the purposes of processing. The Operator takes or ensures the necessary measures to delete or correct incomplete or inaccurate data.
6.7. Identifiable data is kept no longer than necessary for its purposes unless federal law or a contract to which the data subject is a party, beneficiary or guarantor sets a retention period. Data is destroyed or anonymised when those purposes are achieved or no longer needed, unless federal law provides otherwise.
7. Purposes of personal data processing
7.1. The purpose of processing the User’s personal data is:
– entering into, performing and terminating civil-law contracts.
7.2. The Operator may also send notifications about new products and services, special offers and events. Users can opt out at any time by emailing simplify.bots@gmail.com with the subject “Opt out of new product, service and special offer notifications”.
7.3. Anonymised data collected through web analytics is used to understand how Users interact with the website and improve its quality and content.
8. Legal grounds for personal data processing
8.1. The Operator’s legal grounds for processing are:
– Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”;
– the Operator’s constitutional documents;
– contracts between the Operator and data subjects;
– federal laws and other regulations governing personal data protection;
– Users’ consent to personal data processing and to processing data authorised for distribution.
8.2. The Operator processes data only when Users enter and/or submit it themselves through forms at https://www.simplify-bots.com or by email. By completing these forms and/or sending personal data, the User agrees to this Policy.
8.3. The Operator processes anonymised User data where the User’s browser settings permit it (cookies and JavaScript enabled).
8.4. The data subject independently decides to provide personal data and gives consent freely, of their own will and in their own interest.
9. Conditions for personal data processing
9.1. Processing takes place with the data subject’s consent.
9.2. Processing is necessary to achieve objectives under an international treaty of the Russian Federation or legislation, and to perform functions, powers and duties imposed on the Operator by Russian law.
9.3. Processing is necessary for the administration of justice or the enforcement of judicial decisions or decisions of other authorities or officials under Russian enforcement legislation.
9.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, or to enter into a contract at their initiative or one under which they will be a beneficiary or guarantor.
9.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve objectives of public significance, provided the data subject’s rights and freedoms are not infringed.
9.6. Processing concerns data made accessible to an unlimited number of persons by the data subject or at their request (publicly available personal data).
9.7. Processing concerns data that must be published or disclosed under federal law.
10. Collection, storage, transfer and other processing procedures
The Operator secures personal data through the legal, organisational and technical measures necessary to comply fully with applicable personal data protection legislation.
10.1. The Operator safeguards personal data and takes all possible measures to prevent access by unauthorised persons.
10.2. Users’ personal data will never be transferred to third parties, except to comply with applicable law or where the data subject has consented to transfer to a third party for the performance of obligations under a civil-law contract.
10.3. Users may correct inaccurate data by emailing the Operator at simplify.bots@gmail.com with the subject “Personal data update”.
10.4. The processing period is determined by the achievement of the purposes for which the data was collected, unless a contract or applicable law specifies otherwise.
Users may withdraw consent at any time by emailing simplify.bots@gmail.com with the subject “Withdrawal of consent to personal data processing”.
10.5. Information collected by third-party services, including payment systems, communication services and other providers, is stored and processed by those parties under their own user agreements and privacy policies. Data subjects and/or Users must familiarise themselves with those documents in a timely manner. The Operator is not responsible for the actions of third parties, including the providers mentioned here.
10.6. Restrictions on transfer (other than granting access), or on processing or its conditions (other than obtaining access), set by the data subject for data authorised for distribution do not apply where processing serves state, social or other public interests defined by Russian law.
10.7. The Operator ensures confidentiality when processing personal data.
10.8. The Operator keeps identifiable data no longer than necessary for the purposes of processing, unless federal law or a contract to which the data subject is a party, beneficiary or guarantor sets a retention period.
10.9. Processing may end when its purposes are achieved, consent expires or is withdrawn, or unlawful processing is identified.
11. Operations performed on personal data
11.1. The Operator collects, records, organises, accumulates, stores, clarifies (updates or amends), retrieves, uses, transfers (distributes, provides or grants access to), anonymises, blocks, deletes and destroys personal data.
11.2. The Operator performs automated processing with or without receiving and/or transmitting information over information and telecommunications networks.
12. Cross-border transfer of personal data
12.1. Before any cross-border transfer, the Operator must ensure that the destination country provides reliable protection of data subjects’ rights.
12.2. Transfers to countries not meeting these requirements may take place only with the data subject’s written consent to the cross-border transfer and/or to perform a contract to which they are a party.
13. Confidentiality of personal data
The Operator and other persons with access to personal data must not disclose it to third parties or distribute it without the data subject’s consent, unless federal law provides otherwise.
14. Final provisions
14.1. Users may request clarification about personal data processing by emailing the Operator at simplify.bots@gmail.com.
14.2. Changes to the Operator’s processing policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
14.3. The current Policy is freely available at https://www.simplify-bots.com.