Last updated: January 15, 2024
1. General provisions and terms used in the Policy
1.1. This document defines the Policy of Attention Laboratory LLC (hereinafter referred to as the “Company”) regarding the processing of personal data and the implementation of personal data protection requirements (hereinafter referred to as the “Policy”) in accordance with the requirements of Art. 18.1. of Federal Law No. 152-FZ dated 07/27/2006 “On Personal Data”.
1.2. The following basic concepts are used in this Policy:
personal data: any information related directly or indirectly to a specific or identifiable individual (subject of personal data);
cookie: a small text file that is placed on a device (computer, mobile device) when visiting our sites. It helps information resources to recognize the device the next time they are visited for ease of use;
website: electronic platform that provides access to text, video, graphic and audio content posted on the Internet under a domain name ir-press.com or ir-press.ru;
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;
automated processing of personal data – processing of personal data using computer technology;
dissemination of personal data – actions aimed at disclosing personal data to an indefinite circle of persons;
provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons;
blocking of personal data – temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data);
destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed;
depersonalization of personal data – actions as a result of which it becomes impossible to determine the identity of personal data to a specific personal data subject without using additional information;
personal data information system – set of personal data contained in databases and information technologies and technical means that ensure their processing;
subject of personal data – an individual to whom personal data is directly or indirectly related.
2. Principles of personal data processing in the Company:
2.1. The processing of personal data is carried out on a lawful and fair basis;
2.2. The processing of personal data is limited to achieving specific, predetermined and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not allowed;
2.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
2.4. Only personal data that meet the purposes of their processing are subject to processing;
2.5. The content and volume of the processed personal data correspond to the stated purposes of processing and are not excessive in relation to the stated purposes of their processing;
2.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. Necessary measures are being taken to delete or clarify incomplete or inaccurate data;
2.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data, upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law, are subject to destruction or depersonalization.
2.8. When collecting personal data, including through the information and telecommunication network “Internet”, recording, systematization, accumulation, storage, clarification (updating, modification), and extraction of personal data of citizens of the Russian Federation are using databases located on the territory of the Russian Federation.
3. Legal grounds for processing personal data:
The processing of personal data in the Company is carried out in accordance with Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”, Article 53 of the Federal Law of the Russian Federation dated 07.07.2003 No. 126-FZ “On Communications”, the Labor Code of the Russian Federation, Decree of the Government of the Russian Federation dated 11/01/2012 No. 1119 “On Approval of Requirements to the protection of personal data during their processing in personal data information systems”, by Decree of the Government of the Russian Federation dated September 15, 2008. No. 687 “On approval of the Regulation on the specifics of personal data processing carried out without the use of automation tools” and other regulatory legal acts in the field of personal data protection.
4. Purposes of personal data processing:
4.1. The Company collects, stores and processes only those personal data that are necessary for the provision of services and for the performance of its activities, as well as to ensure the rights and legitimate interests of third parties, provided that the rights of the personal data subject are not violated.
4.2. The personal data of the personal data subject may be processed by the Company for the following purposes:
4.2.1. To identify the subject of personal data;
4.2.2. To communicate with the personal data subject, if necessary, including for sending notifications, requests and information related to the provision of services, as well as for processing requests and requests from personal data subjects;
4.2.3. For conducting statistical and other research based on depersonalized data.
4.3. The Company does not process special categories of personal data related to race, nationality, political views, religious beliefs, health status, as well as biometric personal data.
5. The composition of personal data:
5.1. Personal data of the subject of personal data – an employee of the Company – information required by the Company in connection with the registration, modification, termination of employment relations.
5.2. Personal data of a personal data subject – a counterparty under a civil law agreement – information required by the Company in connection with the registration, modification, termination of a civil law agreement with this personal data subject.
5.3. Personal data of the personal data subject – the Company’s client – information necessary for the Company to fulfill its obligations under contractual relations with the personal data subject (the Company’s client) and to comply with the requirements of the legislation of the Russian Federation in the field of personal data protection.
5.4 Personal data of a personal data subject – a consumer of the Company’s services – information necessary for the Company to fulfill its non-contractual obligations to personal data subjects who consume content created by the Company as a service provided by the Company according to the “as is” rule and to comply with the requirements of the legislation of the Russian Federation in the field of personal data protection.
6. Processing of personal data:
6.1. The processing of personal data of the Company’s personal data subjects is carried out in order to ensure compliance with laws and other regulatory legal acts of the Russian Federation, training of personal data subjects-employees of the Company, ensuring the personal safety of personal data subjects, monitoring the quantity and quality of work performed and ensuring the safety of the Company’s property.
6.2. The processing of personal data is carried out by the Company with the consent of the subjects of personal data, both with the use of automation tools and without the use of such tools.
6.3. The Company does not provide or disclose information containing personal data of personal data subjects to a third party without the written consent of the personal data subject, except in cases where this is necessary in order to prevent threats to life and health, as well as in cases established by the current legislation of the Russian Federation in the field of personal data protection.
6.4. At the reasoned request of the authorized body and solely within the framework of the implementation of the current legislation, the personal data of the subject may be transferred without his consent: – to judicial authorities in connection with the administration of justice;
– bodies of the Federal Security Service;
– to the Prosecutor’s office;
– to the police authorities;
– to other bodies and organizations in cases established by regulatory legal acts that are mandatory for execution.
6.5. In case of obtaining consent to the processing of personal data from a representative of the personal data subject, the powers of this representative to give consent on behalf of the personal data subject are checked by the Company.
6.6. If the personal data subject withdraws consent to the processing of personal data, the Company has the right to continue processing personal data without the consent of the subject if there are grounds specified in the current legislation.
6.7. Legal regulation of the procedure and terms of storage of documents containing personal data of personal data subjects is carried out on the basis of the “List of standard administrative archival documents formed in the course of the activities of state bodies, local governments and organizations, indicating the terms of storage”, approved by Order of the Ministry of Culture of the Russian Federation dated 08/25/2010 No. 558.
6.8. The destruction of documents containing personal data is carried out in any way that excludes the possibility for unauthorized persons to familiarize themselves with the destroyed materials and the possibility of restoring their text.
7. Confidentiality of personal data
7.1. Information related to personal data that has become known in connection with the implementation of labor relations, the fulfillment of the provisions of a civil contract to which the subject of personal data is a party, and in connection with the provision of services by the Company, is confidential information and is protected by the current legislation of the Russian Federation.
7.2. Persons who have received access to the processed personal data have signed an obligation not to disclose confidential information, and have also been warned about possible disciplinary, administrative, civil and criminal liability in case of violation of the norms and requirements of the current legislation of the Russian Federation in the field of personal data protection.
7.3. Persons who have received access to the processed personal data do not have the right to disclose the personal data of the personal data subject to a third party without the written consent of such a subject, except in cases where this is necessary in order to prevent threats to the life and health of the personal data subject, as well as in cases established by the legislation of the Russian Federation.
7.4. Persons who have received access to personal data undertake not to disclose personal data for commercial purposes without the written consent of the personal data subject. The processing of personal data of personal data subjects for the purpose of promoting goods, works, and services on the market by making direct contacts with a potential consumer using means of communication is allowed only with his prior consent.
8. Rights of personal data subjects
8.1. The subject of personal data has the right to receive information concerning the processing of his personal data, including information containing:
8.1.1. confirmation of the fact of personal data processing by the Company;
8.1.2. legal grounds and purposes of personal data processing;
8.1.3. purposes and methods of personal data processing used by the Company;
8.1.4. name and location of the Company, information about persons (except for employees of the Company) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Company or on the basis of federal law of the Russian Federation;
8.1.5. processed personal data related to the relevant personal data subject, the source of their receipt, unless another procedure for submitting such data is provided for by federal law of the Russian Federation; Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”;
8.1.6. terms of processing of personal data, including the terms of their storage;
8.1.7. the procedure for the exercise by the subject of personal data of the rights provided for
8.1.8. information on the transborder data transfer that has been carried out or is expected to be carried out;
8.1.9. the name or surname, first name, patronymic and address of the person processing personal data on behalf of the Company, if processing is entrusted or will be entrusted to such a person;
8.1.10. other information provided for by Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” or other federal laws of the Russian Federation.
8.2. The personal data subject has the right to require the Company to clarify his personal data, block or destroy them if the personal data is 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. The subject may exercise his right to demand that the Company clarify, block or destroy his personal data by sending an appropriate request through the contact form on the website.
8.3. If the personal data subject believes that the Company is processing his personal data in violation of the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” or otherwise violates his rights and freedoms, the personal data subject has the right to appeal the actions or inaction of the Company to the body for the protection of the rights of personal data subjects (Federal Service for Supervision of Communications, Information Technology and Mass Communications – Roskomnadzor) or in court.
8.4. The subject of personal data has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.
8.5. Other rights defined by Chapter 3 of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”.
9. Cookie Policy
9.1 Cookies store information about your Internet activity, namely:
· IP address;
· OS type and version;
· browser type and version;
· OS and browser language;
· device type and screen resolution;
· location information;
· the source from where the user came to the site;
· which site or advertisement did the user come from;
· which pages are opened and which buttons are clicked by the user.
Information resources collect and record data in cookies automatically.
Cookies are not used to identify an individual or create a user profile, and do not combine information with other data.
The purposes for collecting cookie data are specified in section 4.2.3.
The site uses cookie collection and analysis tools — these are internal and external recommendation and analytics systems, advertising pixels and trackers.
You can familiarize yourself with the description of the cookie types using the appropriate external free services, for example:
https://www.hotcleaner.com/cookie-editor/
https://sitechecker.pro/ru/cookie-checker/
Our site contains only those third-party services that process data using the necessary data security measures.
The collection of cookies by third-party services is carried out by us only with your consent.
Information about cookies and how to manage them is posted on a public resource https://www.allaboutcookies.org /.
9.2 Consent to the use of cookies
The first time you visit an information resource, we ask for your consent to the processing of cookies. A notification about the cookies we collect is displayed on the screen.
9.3 Refusal to process cookies
You have the right to refuse cookie processing by disabling or deleting cookies in your browser settings. These options are usually found in the browser menu: “Options”, “Tools”, “Settings” or “Preferences”, etc., which you use.
The settings for disabling cookie collection for some browsers are shown below:
· Firefox
· Internet Explorer
· Google Chrome
· Safari
After disabling or deleting cookies, a notification about cookie processing will be displayed on the screen every time you visit an information resource.
9.4 Storing cookies
Some cookies are deleted from your device automatically when you close your browser.
Some cookies are deleted after a certain period of time. This period may vary from the time spent on the site and up to 3 years.
If you disable or delete cookies through your browser settings, the files are deleted immediately after your actions.
The retention period depends on the type of cookie itself. You can familiarize yourself with the storage period by cookie type using the appropriate external free services, for example:
https://www.hotcleaner.com/cookie-editor/
https://sitechecker.pro/ru/cookie-checker/
9.5 Automatic logging
Our web servers and security systems temporarily store technical data.
The processing of technical data is designed to ensure the operation of information resources and their security.
The technical data contains:
· the IP address of your computer/device;
· the content you requested (the name and URL of the requested file on the site);
· date and time of the request;
· GMT time zone;
· connection status;
· the amount of data transmitted;
· device specifications, including the language, browser version, and operating system of your computer or device;
· the URL of the website, if the website was accessed by a link;
Technical data is not used to identify an individual or create a user profile, is not combined with other data and is not transmitted.
Technical data is stored for no more than 12 months from the date of their collection. The shelf life may be extended only upon the requirement of the legislation of the Russian Federation or IF.
The only way for you to refuse to transfer technical data to us is to stop using the information resource.
10. Measures aimed at ensuring that the Company fulfills the obligations provided for in Articles 18.1., 19 of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data”:
10.1. The legal, organizational and technical measures provided for by the relevant regulatory legal acts to ensure the security of personal data during their processing in the Company’s personal data information systems are applied.
10.2. When processing personal data carried out without the use of automation tools, the requirements established by Decree of the Government of the Russian Federation No. 687 dated September 15, 2008 “On Approval of the Regulation on the specifics of processing personal data carried out without the use of automation tools” are fulfilled.
10.3. The Company’s employees who directly process personal data are familiarized with the provisions of the legislation of the Russian Federation on personal data (including requirements for personal data protection), local acts on personal data processing.
10.4. The Company is responsible for violation of obligations to ensure the security and confidentiality of personal data during their processing in accordance with the legislation of the Russian Federation.
10.5. To ensure unrestricted access to the Company’s Policy on Personal Data Processing and information on implemented measures to protect personal data, the text of this Policy is published on the Company’s official website (https://www.ir-press.ru).
This text is the translation from Russian. In case of dispute, the Russian version shall prevail.