Personal Data Processing Policy
By accepting the Policy of this website, you also give Consent to Personal Data Processing
*Additional information: Cookie Processing Rules
1. General provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the Law on Personal Data) and Recommendations of the Federal Service for Supervision of Communications, Information Technology and Mass Media (also known as Roskomnadzor) of 27 July 2017.
This Policy is intended to inform subjects of personal data about the procedure for processing personal data and measures to ensure personal data security by the website owner (hereinafter referred to as the Operator).
Contact details of the operator:
Address: 105318, city of Moscow, 31 Ibragimova Street, Floor 6, Office 817
Phone: +7 (499) 501-1546.
ITIN: 7718771595
TRRC: 771901001
BGRN: 1097746442441
Key terms used in the Policy:
1. Automated processing of personal data refers to actions performed on personal data using computer technology.
2. Blocking of personal data is a temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
3. Website is defined as a collection of graphic and informational materials, along with computer programs and databases, that ensures their availability on the Internet at a specific network address https://teletor.com/ (hereinafter referred to as the Site, Website). E-mail of the website (operator): info@teletor.ru
4. Personal Data Information System (PDIS) is a defined set of personal data in databases, along with the information technologies and technical means that ensure their automated or non-automated processing.
5. Anonymization is the process of irreversibly altering personal data so that, without additional, separately stored information, it is impossible to identify a specific User or other subject of personal data.
6. Personal data processing covers any automated or manual action (operation) or set of actions (operations) performed on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), de-personalization, blocking, deletion, distribution, destruction of personal data.
7. Personal Data Operator is a legal entity, individual, municipal or government body that independently or jointly organizes and (or) carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data. For the purposes of this Policy, the Operator is the owner of this website.
8. Personal data is any information relating to an identified or identifiable User (data subject) of the website, directly or indirectly.
9. Personal data permitted by the subject of personal data for distribution refers to personal data, access of an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter, the Personal Data permitted for distribution).
10. User – any visitor to the website
11. Provision of personal data involves targeted actions designed to disclose, transfer, or provide access to a subject’s personal information to a specific individual or a defined group of people.
12. Distribution of personal data involves any action intended to disclose or make personal data accessible to an indefinite number of people (transfer of Personal Data) or at acquaintance with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way.
13. Cross-border transfer of personal data is defined as the transmission of personal data from a home country to a foreign state—specifically to a foreign government authority, individual, or legal entity.
14. Destruction of Personal Data constitutes any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and (or) physical media (on which personal data are stored) are destroyed.
Basic rights and obligations of the Operator
The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen when processing their personal data, including the protection of rights to privacy, personal and family secrets.
This Policy of the Operator regarding Personal Data Processing (hereinafter the Policy) applies to all the information that the Operator may receive from visitors to the website
The Operator shall be entitled to:
● receive reliable information containing personal data from the subject of personal data;
● if the subject of personal data withdraws their consent to the processing of personal data, the Operator is entitled to continue processing personal data without the consent of the subject of personal data if there are legal grounds specified in the Law on Personal Data;
● independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws;
The Operator shall do as follows:
● provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
● organize the processing of personal data in the manner stipulated by the current legislation of the Russian Federation;
● respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
● inform the authorized body for the protection of the rights of subjects of personal data upon the request of this body, providing necessary information within 30 days from the date of receipt of such request;
● publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
● take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to Personal Data;
● cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and in cases provided for by the Law on Personal Data;
● fulfill other obligations provided for by the Law on Personal Data.
Fundamental rights and obligations of Subjects of Personal Data
Subjects of Personal Data are entitled to:
● access information regarding the processing of their personal data, with the exception of those cases envisioned under the federal laws. The information is provided to the subject of Personal Data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, unless there are legal grounds for the disclosure of such Personal Data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
● demand the Operator to rectify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
● put forward a condition of prior consent when processing Personal Data in order to promote goods, works and services in the market;
● withdraw consent for Personal Data processing;
● appeal to authorized body for the protection of rights of subjects of Personal Data or file a lawsuit against illegal actions or inaction of the Operator, when processing their Personal Data;
● exercise other rights stipulated by the legislation of the Russian Federation.
The Subject of Personal Data shall do as follows:
● provide the Operator with reliable data about themselves;
Persons who have transferred inaccurate information about themselves to the Operator, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
The Operator may process (if there is a respective form on the website) the following Personal Data of the User:
1. Full name
2. E-mail address
3. Phone numbers
4. Nickname (if any)
5. User’s avatar image
6. Address of the User
7. Information about the User (about me)
8. Questions from the User
9. Also, the site collects and processes anonymized visitor data (including cookies) using tools, Internet statistics services (Yandex Metrica and Google Analytics and others).
10. The above data hereinafter in the text of the Policy are united by the general concept of Personal Data.
11. The processing of special categories of Personal Data related to race, nationality, political views, religious or philosophical beliefs, and intimate life is not carried out by the Operator.
12. The processing of Personal Data permitted for distribution from among the special categories of Personal Data specified in Part 1 of Article 10 of the Law on Personal Data is allowed if specific, separate consent is obtained and all restrictions and conditions under Article 10.1 of the Federal Law on Personal Data are observed.
The User’s consent for processing Personal Data intended for public distribution shall be obtained separately from general consent for the processing of their Personal Data via an explicit checkbox when sending any form.
At the same time, the conditions stipulated by, in particular, Article 10.1 of the Law on Personal Data shall be observed. The requirements for the content of such consent are established by the authorized body for the protection of rights of subjects of Personal Data.
The User shall give consent to the processing of Personal Data permitted for distribution directly to the Operator.
The operator shall, no later than three working days from the date of receipt of the specified consent of the User, publish information on the processing conditions, on the presence of prohibitions and conditions for the processing of Personal Data by an unlimited number of persons permitted for distribution. The transfer (distribution, provision, access) of Personal Data permitted by the subject of Personal Data for distribution shall be stopped at any time upon the request of the subject of Personal Data.
This requirement shall include the last name, first name, patronymic name (if any), contact information (phone number, email address or postal address) of the subject of Personal Data, as well as the list of Personal Data, the processing of which shall be terminated. The Personal Data specified in this requirement can be processed only by the Operator to whom it is sent.
Consent to the processing of Personal Data permitted for distribution ceases to be effective from the date the Operator receives the request specified in this Policy in relation to the processing of Personal Data.
Principles of processing Personal Data
1. The processing of Personal Data shall be carried out on a legal and fair basis.
2. The processing of Personal Data is limited to the achievement of specific, predetermined and legitimate purposes. Processing Personal Data for the purposes that are incompatible with the original collection purpose is strictly prohibited.
3. Combining databases with personal data processed for incompatible purposes is strictly prohibited.
4. Only Personal Data that meet the purposes of their processing is subject to processing.
5. The content and volume of processed Personal Data shall strictly correspond to, and not exceed, the stated, specific, and legitimate purposes of processing. The redundancy of the processed Personal Data in relation to the stated purposes of their processing is not allowed.
6. When processing Personal Data, the accuracy, sufficiency, and, if necessary, relevance of Personal Data in relation to personal data processing purposes shall be ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate Personal Data.
7. The storage of Personal Data is carried out in a form that makes it possible to determine the subject of Personal Data, no longer than the purpose of processing Personal Data requires, if the storage period for Personal Data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed Personal Data is destroyed or anonymized (depersonalized) once processing goals are met or no longer necessary, unless federal law requires longer retention.
Purposes of processing Personal Data
1. The purpose of Personal Data processing of the User:
2. informing the User by sending e-mails;
3. conclusion, execution and termination of civil law contracts;
4. providing the User with access to services, information and / or materials contained on the website
5. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator marked “Refusal of notifications about new products and services and special offers”.
6. Anonymized User data, collected via internet statistics services is processed to analyze User behavior, improve site quality, and enhance content.
Legal basis for the processing of Personal Data
The legal grounds for processing Personal Data by an Operator are the following:
● list the legal acts governing the relations related to your activities, for example, if your activities are related to information technology, in particular with the creation of websites, then here you can indicate the Federal Law “On Information, Information Technology and Protection of Information” of 27 July 2006 N 149-FZ;
● Operator’s documents;
● agreements concluded between the Operator and the subject of Personal Data, if any;
● federal laws and other regulatory legal acts in the area of Personal Data protection; – consent of Users to the processing of their Personal Data, to the processing of Personal Data permitted for distribution.
The Operator processes the User’s Personal Data only if it is filled in and / or sent by the User independently through special forms located on the website or sent to the Operator via e-mail. The User signifies their agreement to this Policy by filling out the appropriate forms and / or sending their Personal Data to the Operator.
The Operator processes anonymized data about the User if it is allowed in the settings of the User’s browser (saving of cookies and use of JavaScript technology are enabled).
The subject of Personal Data independently decides on the provision of their Personal Data and gives consent freely, of their own free will and in their interest.
Conditions for processing Personal Data
1. The processing of Personal Data is carried out with the consent of the subject of Personal Data to the processing of their Personal Data.
2. The processing of Personal Data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers and duties imposed by the legislation of the Russian Federation on the Operator.
3. The processing of Personal Data is necessary for the administration of justice, execution of a court ruling, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
4. The processing of Personal Data is necessary for the execution of an agreement, to which the subject of Personal Data is either a party or a beneficiary or a guarantor, as well as for concluding an agreement on the initiative of the subject of Personal Data or an agreement under which the subject of Personal Data will be a beneficiary or guarantor.
5. The processing of Personal Data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that it does not violate the rights and freedoms of the subject of Personal Data.
6. The processing of Personal Data is carried out, access to an unlimited number of persons to which is provided by the subject of Personal Data or upon their request (hereinafter the Publicly Available Personal Data).
7. The processing of Personal Data is carried out, subject to publication or mandatory disclosure in accordance with the federal law.
Procedure for collecting, storing, transferring and other types of processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
The Operator ensures the safety of Personal Data and takes all possible measures to exclude access to Personal Data of unauthorized persons.
The User’s Personal Data shall never, under any circumstances, be transferred to third parties, except in 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 to fulfill obligations under a civil contract.
In case of revealing inaccuracies in Personal Data, the User can update them independently by sending a notification to the Operator to the Operator’s e-mail marked “Updating personal data”.
The period for processing Personal Data shall be determined by the achievement of the purposes for which the Personal Data were collected, unless another period is provided for by the contract or current legislation. The User can at any time withdraw their consent to the processing of Personal Data by sending a notification to the Operator via e-mail to the Operator’s email marked “Revocation of consent to the processing of Personal Data”.
All information that is collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of Personal Data and / or the User is obliged to independently proactively review these documents in a timely manner. The Operator shall not be responsible for the actions of third parties, including the service providers specified in this clause.
The restrictions or prohibitions imposed by the subject of Personal Data on the transfer (except for granting access), as well as on the processing or processing conditions (except for gaining access) of Personal Data permitted for distribution do not apply if the personal data processing serves state, public, or other public interests defined by the law of the Russian Federation.
When processing Personal Data, the Operator ensures the confidentiality of Personal Data.
The storage of Personal Data is carried out by the Operator in a form that makes it possible to determine the subject of Personal Data, no longer than the purpose of processing Personal Data requires, if the storage period for Personal Data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
The condition for terminating the 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 or withdrawal of consent by the subject of Personal Data, as well as the identification of illegal processing of Personal Data.
List of actions performed by the Operator with the received Personal Data
The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys Personal Data.
The Operator carries out automated processing of Personal Data with the receipt and / or transmission of the information received via information and telecommunication networks or without it.
No cross-border transfer of Personal Data is performed
Confidentiality of Personal Data
The Operator and other persons who have gained access to Personal Data shall not disclose to third parties and not distribute Personal Data without the consent of the subject of Personal Data, unless otherwise provided by the federal law.
Final provisions
The User can receive any clarifications on issues of interest regarding the processing of their Personal Data by contacting the Operator via an e-mail
This document will reflect any changes in the Personal Data Processing Policy by the Operator. The policy shall be valid indefinitely until it is replaced by a new version.
The current version of the Policy is publicly available on the Internet at the address specified in the URL of your browser.