1. GENERAL PROVISIONS

The Personal Data Processing Policy (hereinafter referred to as the Policy) has been developed in accordance with the Federal Law of 27.07.2006. No152-FZ “On Personal Data” (hereinafter referred to as FZ-152).

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in the Association of Continuing Professional Education “Educational Center for High Medical Technologies” (hereinafter referred to as the Operator, the Association) in order to protect the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

The following basic concepts are used in the Policy:

• automated processing of personal data – processing of personal data using computer technology;
• blocking of personal data – temporary suspension of personal data processing (except for cases where processing is necessary to clarify personal data);
• personal data information system – a set of personal data contained in databases, and information technologies and technical means ensuring their processing;
• depersonalization of personal data – actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific subject of personal data;
• personal data processing – any action (operation) or a set of actions (operations) performed with or without the use of automation 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;
• Operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons, organizing and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
• personal data – any information relating to a directly or indirectly identified or identifiable individual (personal data subject);
• provision of personal data – actions aimed at disclosing personal data to a certain person or a certain group of persons;
• distribution of personal data – actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way;
• cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
• destruction of personal data – actions as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which tangible media of personal data are destroyed;
• Cookies – files created by software for viewing web pages on the User’s device (web client, web browser) when viewing any site in the telecommunications network Internet. When opening the web page of the Site, this file is sent to the web server of the Site to authenticate the user, download his personal preferences and settings, track the status of the user’s access session, and maintain statistics about users. Cookies include the following technical information:
  • information about the browser, date and time of access to the Site;
  • duration of stay on the Site;
  • technical characteristics of the device;
  • information about behavior and activity on the Website using automation tools, including the metric program Yandex.Metrica

The Association is obliged to publish or otherwise provide unrestricted access to this Personal Data Processing Policy in accordance with Part 2 of Art. 18.1. FZ-152.

2. PRINCIPLES AND CONDITIONS FOR PROCESSING PERSONAL DATA

2.1. Principles of personal data processing

The processing of personal data by the Operator is carried out on the basis of the following principles:

• legality and a fair basis;
• limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;
• preventing the processing of personal data that is incompatible with the purposes of collecting personal data;
• preventing the unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
• processing only those personal data that meet the purposes of their processing;
• compliance of the content and volume of the processed personal data with the stated purposes of processing;
• preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;
• ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
• destruction or depersonalization of personal data upon achievement of the purposes of their processing or in the event of the loss of the need to achieve these goals, if the Operator is unable to eliminate the violations of personal data, unless otherwise provided for by federal law.

2.2. Terms of personal data processing

The Operator processes personal data if at least one of the following conditions is met:

• the processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;
• the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation and performance of the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation;
• the processing of personal data is necessary for the administration of justice, the execution of 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;
• 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;
• 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;
• personal data is processed, access to which is provided to an unlimited number of persons by the personal data subject or at his request (hereinafter publicly available personal data);
• personal data subject to publication or mandatory disclosure in accordance with the federal law is processed.

The Operator processes personal data up to the moment (whichever occurs first):

• until the personal data subject withdraws consent to the processing of personal data or requests the destruction of personal data;
• until the expiration of the consent or the achievement of the personal data processing purposes agreed upon by the subject and the Operator (no later than 30 days from such date, unless another period is agreed upon by the subject and the Operator);
• termination of the Operator’s activities (liquidation of a legal entity).

2.3. Privacy of personal data

The operator and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.

2.4. Publicly available sources of personal data

For the purpose of information support, the Operator may create publicly available sources of personal data of subjects, including directories and address books, databases (for mass mailing of information about the activities of the Association and for other purposes). With the written consent of the subject, publicly available sources of personal data may include his/her last name, first name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data provided by the personal data subject.

Information about the subject must be excluded from publicly available sources of personal data at any time at the request of the subject or by decision of a court or other authorized state bodies.

2.5. Special categories of personal data

The processing by the Operator of special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life is allowed in cases where:

• the personal data subject has consented in writing to the processing of their personal data;
• personal data are made publicly available by the personal data subject;
• the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on state pension provision, on labor pensions;
• the processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject or the life, health or other vital interests of other persons and it is impossible to obtain the consent of the personal data subject;
• personal data processing is carried out for medical and preventive purposes, for the purpose of establishing a medical diagnosis, providing medical and medical and social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities and obliged in accordance with the legislation of the Russian Federation to maintain medical confidentiality;
• the processing of personal data is necessary to establish or exercise the rights of the personal data subject or third parties, as well as in connection with the administration of justice;
• The processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with insurance legislation.

The processing of special categories of personal data shall be immediately terminated if the reasons for their processing have been eliminated, unless otherwise provided for by federal law.

The Operator may process personal data on criminal records only in the cases and in the manner determined in accordance with federal laws.

2.6. Biometric personal data

Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity – biometric personal data – may be processed by the Operator only with the written consent of the subject.

2.7. Entrusting the processing of personal data to another person

The operator has the right to entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by FZ-152.

2.8. Cross-border transfer of personal data

The Operator does not carry out cross-border transfer of personal data.

3. RIGHTS OF THE PERSONAL DATA SUBJECT

3.1. Consent of the personal data subject to the processing of his personal data

The personal data subject decides to provide his personal data and agrees to their processing freely, of his own free will and in his own interest. Consent to the processing of personal data may be given by the personal data subject or his representative in any form that allows confirming the fact of its receipt, unless otherwise provided by federal law.

The obligation to provide proof of obtaining the consent of the personal data subject to the processing of his personal data or proof of the existence of the grounds specified in FZ-152 rests with the Operator.

3.2. Rights of the personal data subject

The personal data subject has the right to receive information from the Operator regarding the processing of his personal data, if such right is not limited in accordance with federal laws. The personal data subject has the right to demand from the Operator to clarify his personal data, block or destroy them 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 his rights.

Processing of personal data for the purpose of informing an unlimited number of persons about the statutory activities of the Association, as well as for promoting services in the market by making direct contacts with a potential consumer using means of communication is allowed without the prior consent of the personal data subject. Subsequent processing of personal data is carried out only with the prior consent of the personal data subject (the burden of proof that it has been received is borne by the Association).

The Operator is obliged to immediately stop processing his/her personal data for the above purposes at the request of the personal data subject.

It is prohibited to make decisions on the basis of exclusively automated processing of personal data that give rise to legal consequences in relation to the personal data subject or otherwise affect his rights and legitimate interests, except in cases provided for by federal laws, or with the written consent of the personal data subject.

If the personal data subject believes that the Operator processes his personal data in violation of the requirements of FZ-152 or otherwise violates his rights and freedoms, the personal data subject has the right to appeal against the actions or inaction of the Operator to the Authorized Body for the Protection of the Rights of Personal Data Subjects or in court.

The personal data subject has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court.

4. ENSURING THE SECURITY OF PERSONAL DATA

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

• appointment of officials responsible for organizing the processing and protection of personal data;
• limiting the number of persons who have access to personal data;
• familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator on the processing and protection of personal data;
• organization of accounting, storage and circulation of information carriers;
• identification of threats to the security of personal data during their processing, the formation of threat models based on them;
• verification of the readiness and effectiveness of the use of information security tools;
• differentiation of user access to information resources and software and hardware means of information processing;
• registration and recording of actions of users of personal data information systems;
• use of anti-virus and personal data protection recovery tools;
• use of firewall, intrusion detection, security analysis and cryptographic information protection tools, if necessary;
• organization of security of the premises occupied by the Operator with technical means of personal data processing.

5. COOKIE PRINCIPLES AND CONDITIONS

On the website of the Association https://amtec-kazan.com/ (hereinafter referred to as the Website) implemented a technology of user identification based on the use of cookies. The software of the site uses cookie technology in automatic mode in order to: autofill data; identification of the user, the device used by him, the operating system, the selected settings for viewing the site. The Site uses two types of cookies – “session cookies” and “persistent cookies”.

Session cookies are temporary files that remain on the user’s device until you stop using the site. Persistent cookies remain on the device for a long time, or until the user manually deletes them (the period depends on the settings of the web browser or web client).

The site does not store personal data in cookies. The Operator uses the received cookies in an impersonal form using automation tools in order to improve the user experience when using the Website and to collect statistical data.

The software of the Website uses cookie technology for statistical purposes using the services of Yandex LLC INN 7736207543 Yandex.Metrica, Yandex.Metrica for Applications (App Metrica) in accordance with the terms of use of these services posted on the telecommunications network Internet at: https://yandex.ru/legal/metrica_termsofuse/. The characteristics of the files used by the services are disclosed at the link: https://yandex.ru/support/metrica/ru/general/cookie-usage.

In case of refusal to process cookies, the Site will only use essential cookies.

6. FINAL PROVISIONS

Other rights and obligations of the Operator as a personal data operator are determined by the legislation of the Russian Federation in the field of personal data.

The Operator’s officials guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.

The policy of the Association of Additional Professional Education “OCVMT” regarding the processing of personal data applies to all information posted on the website at the address: https://amtec-kazan.com/ (hereinafter referred to as the Website), which employees of the OCVMT, persons involved under civil law contracts (for the provision of services, performance of work on the Website) can receive about the User during the use of the Website, its services, programs and products. The Website does not control and is not responsible for third-party websites to which the User can follow the links available on the Website. The Website collects and stores only the personal information that is necessary to provide services or fulfill agreements and contracts with the User, except for cases when the legislation provides for the mandatory storage of personal information for a period specified by law.

Use of the Website services means the User’s unconditional consent to this Policy and the terms of processing of his personal information specified in it; in case of disagreement with these conditions, the User must refrain from using the services.

If the subject of personal data has questions regarding the processing of personal data by the Association, he can contact the Operator with a request by using any https://amtec-kazan.com/ available on the website communication channel. In order to comply with the requests of personal data subjects, the Operator may require the identification of such personal data subject and request additional information confirming his/her participation in relations with the Operator, or information otherwise confirming the fact of personal data processing by the Operator.