Personal Data Processing Policy

  1. General Provisions
    This personal data processing policy has been developed in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by MIRIADA Translation Agency (hereinafter referred to as the Operator).
    1. The Operator's main goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens in the processing of their personal data, including protecting the rights to privacy, personal and family secrets.
    2. This Operator's policy regarding personal data processing (hereinafter - the Policy) applies to all information that the Operator can obtain about the visitors of the website vtorion.pro.
  2. Basic Concepts Used in the Policy
    1. Automated processing of personal data - processing of personal data using computer technology.
    2. Blocking of personal data - temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
    3. Website - a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at a network address vtorion.pro.
    4. Personal data information system - a set of personal data contained in databases and the information technology and technical means ensuring their processing.
    5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without additional information, the affiliation of personal data to a specific User or another personal data subject.
    6. Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
    7. Operator - a government body, municipal body, legal or physical person, independently or together with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
    8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website vtorion.pro.
    9. Personal data permitted by the subject of personal data for distribution - personal data, access to which is provided to an unlimited circle of persons by the subject of personal data by giving consent to the processing of personal data permitted for distribution in accordance with the Personal Data Law (hereinafter - personal data permitted for distribution).
    10. User - any visitor to the website vtorion.pro.
    11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
    12. Distribution of personal data - any actions aimed at disclosing personal data to an unspecified circle of persons (transfer of personal data) or at acquaintance with personal data of an unlimited circle of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.
    13. Transborder transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign authority, a foreign physical or legal entity.
    14. Destruction of personal data - any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
  3. Main Rights and Responsibilities of the Operator
    1. The Operator has the right:
      • to receive from the subject of personal data reliable information and/or documents containing personal data;
      • in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as when an application is submitted with a request to stop processing personal data, the Operator may continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
      • to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
    2. The Operator is obliged:
      • to provide the subject of personal data, at his request, with information regarding the processing of his personal data;
      • to organize the processing of personal data in the manner prescribed by the legislation of the Russian Federation;
      • to respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
      • to report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 10 days from the date of receipt of such request;
      • to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
      • to take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in respect of personal data;
      • to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
      • to perform other duties provided by the Personal Data Law.
  4. Main Rights and Obligations of Personal Data Subjects
    1. Personal data subjects have the right:
      • to receive information regarding the processing of his personal data, except in cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
      • to require the Operator to clarify his personal data, their blocking or destruction 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 by law to protect his rights;
      • to make a condition of prior consent when processing personal data for the purposes of promoting goods, works, services on the market;
      • to withdraw consent to the processing of personal data, as well as to send a request for the cessation of processing of personal data;
      • to appeal against unlawful actions or inaction of the Operator in the processing of his personal data to the authorized body for the protection of the rights of personal data subjects or in court;
      • to exercise other rights provided by the legislation of the Russian Federation.
    2. Subjects of personal data are obliged:
      • to provide the Operator with reliable data about themselves;
      • to inform the Operator about the clarification (updating, change) of their personal data.
    3. Persons who have provided the Operator with unreliable information about themselves or information about another subject of personal data without his consent are liable in accordance with the legislation of the Russian Federation.
  5. Principles of Processing Personal Data
    1. Processing of personal data is carried out on a lawful and fair basis.
    2. Processing of personal data is limited to achieving specific, pre-determined and lawful purposes. Processing of personal data not compatible with the purposes of collecting personal data is not allowed.
    3. Combining databases containing personal data processed for purposes that are incompatible with each other is not allowed.
    4. Only personal data that meets the purposes of their processing is subject to processing.
    5. The content and volume of processed personal data correspond to the declared processing purposes. Processing of personal data that is excessive in relation to the declared purposes of their processing is not allowed.
    6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their implementation to remove or clarify incomplete or inaccurate data.
    7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, unless the period of storage of personal data is established by federal law, a contract, a party to which, beneficiary, or guarantor is the subject of personal data. The processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
  6. Purposes of Processing Personal Data
    Purpose of processing: receiving requests for calls, bookings, and applications from Users in order to contact them by sending emails, calls, SMS messages, or messages through messengers.
    Personal data: email address, phone numbers, name.
    Legal basis: Federal Law "On Information, Information Technologies and on the Protection of Information" of 27.07.2006 N 149-FZ.
    Types of personal data processing: sending informational letters to an email address, calls, SMS messages, or messages through messengers.
  7. Conditions for Processing Personal Data
    1. Processing of personal data is carried out with the consent of the subject of personal data for the processing of his personal data.
    2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
    3. 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.
    4. Processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party or a beneficiary or guarantor, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
    5. Processing of personal data is necessary for the realization of the rights and lawful interests of the operator or third parties or for achieving socially significant objectives, provided that this does not violate the rights and freedoms of the subject of personal data.
    6. Processing of personal data, access to which is provided to an unlimited circle of persons by the subject of personal data or at his request (hereinafter - publicly available personal data), is carried out.
    7. Processing of personal data that must be published or disclosed in accordance with federal law is carried out.
  8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data
    The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
    1. The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
    2. Personal data of the User will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
    3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address hola@vtorion.pro with the note "Updating personal data".
    4. The term for processing personal data is determined by achieving the goals for which the personal data were collected, unless a different term is provided by the contract or current legislation. The User may at any time revoke his consent to the processing of personal data by sending a notification to the Operator via email to the electronic address of the Operator hola@vtorion.pro with the note "Revocation of consent to the processing of personal data".
    5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with these documents. The Operator is not responsible for the actions of third parties, including those specified in this item as service providers.
    6. Prohibitions set by the subject of personal data on the transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
    7. The Operator, when processing personal data, ensures the confidentiality of personal data.
    8. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, a contract, a party to which, beneficiary, or guarantor is the subject of personal data.
    9. The condition for the termination of processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the revocation of consent by the subject of personal data or a requirement to stop processing personal data, as well as the detection of unlawful processing of personal data.
  9. List of Actions Performed by the Operator with the Obtained Personal Data
    1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
    2. The Operator carries out automated processing of personal data with obtaining and/or transmitting the obtained information via information and telecommunication networks or without such networks.
  10. Transborder Transfer of Personal Data
    1. Before starting activities related to the transborder transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out the transborder transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
    2. Before submitting the above notification, the Operator must obtain from the authorities of a foreign state, foreign individuals, foreign legal entities to which it is planned to transfer personal data, the corresponding information.
  11. Confidentiality of Personal Data
    The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
  12. Final Provisions
    1. The User can obtain any clarifications on issues concerning the processing of his personal data by contacting the Operator by email hola@vtorion.pro.
    2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
    3. The current version of the Policy is freely available on the Internet at the address vtorion.pro/privacy-policy.html.
Updated 28.01.2025