1. General provisions
This Personal Data Processing Policy (the “Policy”) is prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and defines the procedure for processing personal data and the measures taken by Army Vacancy (the “Operator”) to ensure their security. Respect for human rights and freedoms when processing personal data, including the right to privacy and protection of family and private life, is one of the Operator’s key priorities. This Policy applies to all information about visitors of the website https://army-russian.com/privacy-policy that the Operator may obtain.
2. Key terms
For the purposes of this Policy, the following terms are used: automated processing of personal data — processing using computer technology; blocking of personal data — temporary suspension of processing (except where processing is required for data clarification); website — a set of software and materials available at https://army-russian.com/privacy-policy; personal data information system — a set of databases and technologies used to process personal data; depersonalisation of personal data — actions that prevent identifying a specific user without additional information; processing of personal data — any operation with personal data, including collection, recording, systematisation, storage, modification, use, transfer and destruction; operator — an entity that independently or jointly with others organises the processing of personal data and determines the purposes and scope of such processing; personal data — any information relating directly or indirectly to an identified or identifiable user of the website; personal data made publicly available by the data subject — data to which unrestricted access is provided by the subject by granting consent to dissemination; user — any visitor of the website; provision of personal data — actions aimed at disclosing data to a specific person or group of persons; dissemination of personal data — actions aimed at disclosing data to an unlimited number of persons; cross-border transfer of personal data — transfer of data to the territory of a foreign state; destruction of personal data — actions leading to irreversible destruction of data or their physical carriers.
3. Rights and obligations of the Operator
The Operator has the right to obtain accurate information and documents containing personal data from the data subject; continue processing personal data in cases where the data subject withdraws consent, provided there are grounds specified by law; and independently determine a set of measures sufficient to ensure compliance with the legislation on personal data, unless otherwise established by law. The Operator is obliged to provide the data subject, upon request, with information about the processing of his or her personal data; to organise processing in accordance with the laws of the Russian Federation; to respond to requests of data subjects and their representatives within the time limits set by law; to provide the authorised supervisory authority with requested information; to publish or otherwise ensure unrestricted access to this Policy; to take legal, organisational and technical measures to protect personal data from unlawful access and other illegal actions; to cease processing and destroy personal data in cases provided for by law; and to fulfil other obligations provided for by personal data legislation.
4. Rights and obligations of data subjects
The data subject has the right to obtain information regarding the processing of his or her personal data, except in cases provided for by federal laws; to demand that the Operator clarify, block or destroy personal data that are incomplete, outdated, inaccurate, unlawfully obtained or excessive for the stated purposes; to require prior consent for the processing of data for marketing purposes; to withdraw consent to personal data processing and to request termination of processing; to appeal actions or omissions of the Operator to the authorised supervisory authority or in court; and to exercise other rights provided by the laws of the Russian Federation. The data subject is obliged to provide the Operator with accurate information about himself or herself and to notify the Operator in a timely manner of any updates to personal data. Individuals who provide inaccurate information about themselves or about third parties without their consent are liable in accordance with Russian law.
5. Principles of personal data processing
Personal data are processed on a lawful and fair basis and only for specific, predetermined and legitimate purposes. Processing that is incompatible with the purposes for which the data were collected is not permitted, nor is the merging of databases whose processing serves incompatible purposes. Only personal data that are relevant to the declared purposes are processed, and their composition and volume are not excessive. The Operator ensures the accuracy, sufficiency and, where necessary, relevance of personal data in relation to the purposes of processing and takes measures to delete or clarify incomplete or inaccurate data. Personal data are stored in a form that allows identifying the data subject for no longer than required by the purposes of processing, unless a longer retention period is established by federal law or contract. Upon achieving the purposes of processing or when such purposes are no longer relevant, personal data are destroyed or anonymised, unless otherwise provided by law.
6. Purposes of personal data processing
Personal data are processed for the purposes of concluding, performing and terminating civil-law contracts. The data processed may include the data subject’s surname, first name, patronymic (where applicable), and telephone numbers. The legal basis for processing is the contracts concluded between the Operator and the data subject. Processing operations include collection, recording, systematisation, accumulation, storage, destruction and depersonalisation of personal data.
7. Conditions for personal data processing
Processing of personal data is carried out with the data subject’s consent, as well as in cases where processing is necessary to achieve objectives provided for by international treaties or laws of the Russian Federation, to perform functions assigned to the Operator, to administer justice and enforce court decisions, to perform a contract to which the data subject is a party or beneficiary, or to conclude a contract at the initiative of the data subject. Processing may also be carried out to achieve legitimate interests of the Operator or third parties, provided that the rights and freedoms of the data subject are not infringed. The Operator may process personal data made public by the data subject, as well as data subject to publication or mandatory disclosure under federal law.
8. Processing procedure and data protection measures
The security of personal data processed by the Operator is ensured through legal, organisational and technical measures aimed at full compliance with personal data protection requirements. The Operator takes all reasonable steps to prevent unauthorised access to personal data. Personal data are not transferred to third parties except in cases required by law or when the data subject has given consent for such transfer to perform a civil-law contract. If inaccuracies in personal data are identified, the user may update them by sending an email to recruit@army-russian.com with the subject “Personal data update”. The processing period is determined by the purposes for which the data were collected, unless another period is specified by contract or law. The user may withdraw consent to personal data processing at any time by sending an email to recruit@army-russian.com with the subject “Withdrawal of consent to personal data processing”. Certain information may be collected and processed by third-party services (such as payment systems and communication services) in accordance with their own user agreements and privacy policies; the Operator is not responsible for the actions of such third parties. Restrictions set by the data subject on the dissemination or processing of personal data made publicly available do not apply where data are processed in state, public or other public interests defined by Russian law. Personal data are stored in a form that allows identifying the data subject for no longer than required by the processing purposes, unless a different period is established by law. Processing is terminated upon achieving the purposes, expiry of consent, withdrawal of consent or detection of unlawful processing.
9. Actions performed by the Operator with personal data
The Operator carries out collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (including provision and access), depersonalisation, blocking, deletion and destruction of personal data. Processing may be performed both by automated means using information and telecommunication networks and without such means.
10. Cross-border transfer of personal data
Before commencing cross-border transfer of personal data, the Operator, where required, notifies the authorised supervisory authority of its intention to carry out such transfer, separately from the notification of the commencement of personal data processing. Prior to submitting the notification, the Operator obtains the necessary information from foreign authorities or persons to whom the personal data are to be transferred.
11. Confidentiality of personal data
The Operator and any persons who have gained access to personal data are obliged not to disclose or disseminate such data to third parties without the data subject’s consent, unless otherwise required by federal law.
12. Final provisions
The user may obtain explanations on any issues related to the processing of his or her personal data by contacting the Operator at recruit@army-russian.com. Any changes to this Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until a new version replaces it. The current version of the Policy is available at https://army-russian.com/privacy-policy.
