Terms and abbreviations

1.  Personal data (PD) – any information relating to an identified or identifiable individual (the subject of PD).
2.  The processing of personal data – any action (operation) or set of actions (operations) committed with use of means of automation or without use of such means with personal data including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, granting, access), depersonalization, blocking, deletion, deleting of personal data.
3.  Automated processing of personal data – the processing of personal data by means of computer technology.
4.  Information system of personal data (ISPD) – the set contained in the databases of personal data, that ensures their processing of information technologies and technical means.
5.  Personal data, which are publicly available subject of personal data, PD, unlimited access provided by the personal data subject or, by his request, – locking of personal data, temporary cessation of personal data processing (except if processing is needed for personal data specification).
6.  Deleting of personal data – temporary suspension of the processing of personal data (unless processing is necessary to clarify personal data).
7.  Deleting of personal data – actions, in which it becomes impossible to restore the contents of personal data in the information system of personal data and (or) in which material carriers of personal data are being deleted.
8.  Cookie – is a piece of data automatically based on your computer's hard drive whenever you visit the website. Thus, cookie – is a unique ID of the browser for web site. Cookies enable to store information on the server and make it easier to navigate in the web space, but also allows to analyse the site and evaluate the results. Most web browsers allow cookies, but you can change the settings for the refusal of cookies or tracking their way of distribution. However, some resources may not work properly if the cookies in the browser will be banned.
9.  Web-marks. On certain web pages or e-mails of PTF Areopag LLC there can be used a common Internet technology «web marks» (also known as «tags» or «accurate GIF technology»). Web tracking helps to analyze the effectiveness of websites, for example, by measuring the number of website visitors or number «clicks», made in key positions of site page.
10.  Operator – the organization, independently or together with other persons organizing and (or) carrying out processing of personal data, and also defining purposes of processing of personal data, the scope of personal data to be processed, actions (operations) committed with personal data.
11.  User – the user of the Internet.
12.  Website - website http://www.areopag-spb.ru owned by LLC «PTF «Areopag», and posted on it widget Callibri.ru developed by LLC “Callibri”.

 General provisions

1.  This Policy concerning the processing of personal data (hereinafter – Policy) is made in accordance with paragraph 2 of article 18.1 of the Federal law «On personal data » No. 152-FL of 27 July 2006, as well as other normative-legal acts of the Russian Federation in the field of protection and processing of personal data and applies to all personal data of LLC "PTF"Areopag" can obtain from the User during his usage of the Internet Site.
2.  The operator ensures the protection of processed personal data against unauthorized access and disclosure, misuse or loss in accordance with the requirements of the Federal law of 27 July 2006 №152-FL «On personal data».
3.  The operator reserves the right to make changes in this Policy. When there are changes in the header Policy, the date of the latest version indicates. The new edition of the Policy comes into force upon the time of its posting on the website, unless otherwise provided in the new version of the Policy.
4.  The operator is obliged to publish or otherwise provide unrestricted access to this Policy of personal data processing in accordance with part 2 of article 18.1. FL-152.

 The principles of personal data processing

1.  The processing of personal data of PTF"Areopag" LLC is based on the following principles:
2.  law and fair basis;
3.  restrictions on the processing of personal data for the achievement of specific, pre-defined and legitimate purposes;
4.  avoidance of personal data processing, that is incompatible with the objectives of collecting personal data;
5.  avoidance of the merging of databases containing personal data the processing of which is carried out for the purposes incompatible with each other;
6.  process only those personal data that meet the purposes of processing;
7.  matching the content and scope of processed personal data to the declared purpose of processing;
8.  avoidance of personal data processing, excessive in relation to the declared purposes of their processing;
9.  ensuring accuracy, adequacy and relevance of personal data in relation to the purpose of processing personal data;
10.  destruction or depersonalization of personal data when the purposes of processing achieved or in case of loss of necessity of achieving these goals, when PTF Areopag LLC cannot eliminate violations of personal data unless otherwise provided by Federal law.

 The processing of personal data

1.  Getting PD.
   1.  All PD should be obtained from the subject of PD. If the PD subject can be obtained only from a third part, the subject must be notified about it or there must be obtained the consent from him.
   2.  The operator must inform the PD subjects about the purposes, expected sources and ways of obtaining the PD, the nature of the receivable PD, the list of actions with the PD, the period during which the operating agreement is relevant and about order of his revocation and also the consequences of failure of the PD subject to give written consent to receive them.
   3.  Documents containing PD, are created by obtaining a PD over the Internet from a PD subject at the time of him using the Site.
2. PTF Areopag LLC produces the processing of PD in the presence of at least one of the following conditions:
   1.  The processing of personal data is carried out with the consent of personal data subject to the processing of personal data;
   2.  The processing of personal data is necessary to achieve the objectives stipulated by international treaty of the Russian Federation or by law, to implement and fulfill the legislation of the Russian Federation to the operator functions, powers and duties;
   3.  The processing of personal data is necessary for the implementation of justice, the execution of the judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;
   4.  The processing of personal data is necessary for execution of the contract to which either the beneficiary or the guarantor which is the subject of personal data, as well as for the contract at the initiative of the personal data subject or of the contract under which the data subject will be the beneficiary or guarantor;
   5.  The processing of personal data is necessary for the implementation of the rights and legitimate interests of the operator or third parties or to achieve important public purposes, provided that doing so does not violate the rights and freedoms of the data subject;
   6.  The processing of personal data, access of an unlimited circle of persons to which is provided by the personal data of subject or at the request of (hereinafter - public personal data);
   7.  The processing of personal data subject to publication or mandatory disclosure in accordance with Federal law.
3.  The operator can process the PD for the following purposes:
   1.  raising the awareness of the subject of PD on the products and services of PTF Areopag LLC;
   2.  conclusion with the subject of PD contracts and their execution;
   3.  informing the PD subjects on news and offers of PTF Areopag LLC;
   4.  identification of the subject of PD on the Website;
   5.  enforcement of laws and other normative legal acts in the field of personal data.
4.  Categories of personal data of subjects. PD processed for the following PD subjects:
   1.  An individuals that are in civil-legal relations with PTF Areopag LLC;
   2.  Individuals who are users of the Site;
5.  PD treated by PTF Areopag LLC - the data received from Users of the Site.
6.  The processing of personal data is carried out in case of:
   1.  – with the use of automation;
   2.  – without the use of automation.
7.  Storage of PD.
   1.  PD of subjects can be obtained, to be further processed and transmitted to storage on paper and electronically.
   2.  PD recorded on paper is stored in lockable cabinets or in lockable rooms with restricted access.
   3.  PD of subjects treated with the use of automation for different purposes, stored in different folders.
   4.  The storage and accommodation of documents containing PD, in the open electronic catalogs (file sharing) to ISPD is not allowed.
   5.  Storage of PD in the form, allowing to define the subject of the PD is no longer stored than required by the purpose of their processing, and they are liable to destruction after reaching the purposes of processing or in case of loss of necessity in them.
8.  The destruction of the PD.
   1.  Destruction of documents (media), containing PD, produced by burning, crushing (chopping), chemical decomposition, transformation into a shapeless mass or powder. For the destruction of paper documents the use of the shredder is allowed.
   2.  PD on electronic media are destroyed by erasing or formatting the media.
   3.  The fact of the destruction of PD is confirmed by the act of destruction the storages.
9.  Transmission of PD.
   1.  The operator transmits the PD to third parties in the following cases of when the subject have expressed their consent to such actions; the transfer is provided by Russian or other applicable legislation within the statutory procedures.
   2.  The list of persons to whom the PD can be transmitted.
   Third parties to whom the PD is transmitted:
   PTF Areopag LLC transmits the PD to Kolibri LLC (located at: c. Ekaterinburg, street of Chemists 3, office 207) and SP Shkirya Ivan Aleksandrovich (located at: c. Sredneural'sk, ul. Chkalova 20) for the purposes specified in paragraph 4.3 of this policy. PTF Areopag LLC instructs the processing of PD to the LLC Kolibri, and SP Shkirya Ivan Aleksandrovich , with the consent of the PD subject, unless otherwise provided by Federal law, on the basis of concluded with these persons of the agreement. LLC Kolibri and SP Shkirya Ivan Aleksandrovich are processing personal data on behalf of PTF Areopag LLC, they are obliged to respect the principles and rules of processing of personal data, stipulated by FL-152.

 Protection of personal data

1.  In accordance with the requirements of the regulations, the system of protection of personal data (SPPD) is created by the Operator, consisting of subsystems of legal, organizational and technical protection.
2.  Subsystem of legal protection is a complex of legal, organizational-administrative and regulatory documents providing the establishment, operation and improvement of SPPD.
3.  Subsystem of organizational security includes the organization management of structure of SPPD, licensing system, protection of information while working with employees, partners and third parties.
4.  The subsystem of technical protection involves complex technical, software, hardware and software ensuring the protection of PD.
5.  The main measures of PD protection used by PTF Areopag LLC are:
   1.  The appointment of the person responsible for the processing of PD, which performs the PD processing, training and briefing, internal control over compliance with the institution and its employees of requirements to protect PD.
   2.  Determination of relevant threats to the security of the PD processed in ISPD and development of measures and activities for protection of PD.
   3.  Policy development in relation to the processing of personal data.
   4.  Establishment of rules of access to PD, processed in ISPD, as well as ensuring registration and recording of all actions performed with PD in ISPD.
   5.  Establishing individual passwords that staff have access to the information system in accordance with their operational responsibilities.
   6.  The use of means of protection of information held in the prescribed manner the conformity assessment procedure.
   7.  Certified antivirus software with regularly updated databases.
   8.  The observance of the conditions providing safety of PD and to exclude unauthorized access to them.
   9.  Detection of unauthorized access to personal data and taking action.
   10.  Recovery of PD, modified or destructed due to unauthorized access.
   11.  Training of employees of PTF Areopag LLC directly involved in the processing of personal data, the provisions of the legislation of the Russian Federation on personal data, including requirements for the protection of personal data, documents, policy-makers PTF Areopag LLC in relation to the processing of personal data, local acts on processing of personal data.
   12.  Implementation of internal control and audit.

 The basic rights of PD subjects and responsibilities of PTF Areopag LLC

1.  The basic rights of PD subjects.
The subject has the right to access its personal data and the following information:
1.  confirmation of PD processing by the Operator;
2.  legal basis and purpose of PD processing;
3.  the goals and methods that the Operator uses during the PD processing;
4.  the name and location of the Operator, data on individuals (except employees of the Operator) who have access to PD or which may be disclosed to PD on the basis of the contract with the Operator or on the basis of the Federal law;
5.  the timing of the processing of personal data, including terms of their storage;
6.  the procedure of the subject of PD rights under current Federal law;
7.  name or surname, name, patronymic and address of the person carrying out the treatment of PD on behalf of the Operator, if the processing is assigned or will be assigned to such person;
8.  communication with an Operator and ability to send a requests to him;
9.  appealment against actions or inaction of the Operator.
1.  The Website user may at any time revoke his consent to the processing of PD, by sending an e-mail to the e-mail address: marketing@areopag-spb.ru or by sending a written notice to the following address: 197374, Saint-Petersburg, street Opticians, D. 4, korp. 3, building A (BC Lakhta-2;, 6-th floor). After receiving such a message of processing PD User will be terminated and his PD will be deleted, except for the cases when the processing may be continued in accordance with the law.
2.  Responsibilities of PTF Areopag LLC.
PTF Areopag LLC is obliged to:

1.  in the process of PD collection provide information about the processing of PD;
2.  in cases where the PD was received from non-PD subjects, to notify the subject;
3.  in case of refusal of the subject to provide PD, the consequences of such refusal must be explained to the subject;
4.  to publish or in other way provide unrestricted access to the document that defines its policy regarding the processing of PD, for information about ongoing requirements for protection of PD;
5.  to take the necessary legal, organizational and technical measures or ensure their adoption to protect the PD from unlawful or accidental access, destruction, alteration, blocking, copying, granting, distribution of PD, as well as other unlawful actions in relation to PD;
6.  to give answers to the queries and complaints of subjects of PD, their representatives and the authorized body for the protection of human subjects of PD.

 Features of the processing and protection of data collected using the Internet

1.  There are two main ways in which PTF Areopag LLC gets data using the Internet:
   1.  The provision of PD subjects of PD by filling in forms of Site;
   2.  Automatically collected information.
   PTF Areopag LLC can collect and process information that is not PD:
   1.  information about the interests of Users on the Site based on the search queries of users of the Website about ongoing and proposed sale of services, goods with the aim of providing relevant information to Users when using the Website, as well as consolidation and analysis of information about which sections of the Site, services, the goods are most in demand among Users of the Website;
   2.  processing and storage of search requests of Site Users in order to consolidate and generate statistics about the use of sections of the Site.
2.  The operator automatically receives certain types of information obtained in the process of User interaction with the Website, email communications, etc. we are Talking about the technologies and services such as cookies, Web marks, and applications and User tools.
3.  However, the Web mark, cookies and other monitoring technologies do not provide the ability to automatically collect PD. If the User of the Site in its sole discretion provides its PD, for example, when filling in the feedback form, only then starts the automatic process of gathering information for the convenience of the Website and/or to improve User experience.

 Final provisions

1.  This Policy is a local normative act of PTF Areopag LLC.
2.  This Policy is publicly available. Public availability of this Policy is provided by the publication on the Website of PTF Areopag LLC.
3.  This Policy may be revised in any of the following cases:
   1.  in case of changing the legislation of the Russian Federation in the field of processing and protection of personal data;
   2.  in cases of receiving the regulations from the competent state bodies on elimination of disparities affecting the scope of the Policy
   3.  according to the decision of PTF Areopag LLC;
   4.  in case of changing the purpose and duration of PD processing;
   5.  in case of changing organizational structure, information and/or telecommunications system (or introducing new);
   6.  in case of application of new technologies of processing and protection of PD (including the transfer, storage);
   7.  in case of necessity to change the process of treatment of PD related to the activity of PTF Areopag LLC.
4.  In case of default of the provisions of this Policy, the Company and its employees bear responsibility in accordance with the current legislation of the Russian Federation.
5.  Control of execution of requirements of the present Policy is made by the persons responsible for the organization of Data processing Company, and for the security of personal data.