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Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data applied by Limited Liability Company “Ist Pey” (hereinafter referred to as the Operator).
1.1. The Operator considers observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy, to be its most important goal and condition for conducting its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://east-pay.pro.

1. Basic Terms Used in the Policy

2.1. Automated processing of personal data means processing of personal data by means of computer technology.
2.2. Blocking of personal data means temporary suspension of processing of personal data (except where processing is necessary for clarification of personal data).
2.3. Website means a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the internet at the network address https://east-pay.pro.
2.4. Personal data information system means a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data means actions as a result of which it becomes impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another subject of personal data.
2.6. Processing of personal data means any action (operation) or a set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator means a state body, municipal body, legal entity or individual which, independently or jointly with other persons, organizes and (or) carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://east-pay.pro.
2.9. Personal data made publicly available by the subject of personal data means personal data to which access is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data made publicly available by the subject of personal data in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data made publicly available).
2.10. User means any visitor of the website https://east-pay.pro.
2.11. Provision of personal data means actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data means 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.
2.14. Destruction of personal data means any actions as a result of which personal data is destroyed irretrievably with no possibility of further restoration of the content of personal data in the personal data information system and (or) physical media of personal data are destroyed.

1. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive from the subject of personal data reliable information and (or) documents containing personal data
• in case the subject of personal data withdraws consent to the processing of personal data and also sends a request demanding cessation of processing of personal data, continue processing of personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator must:

• provide the subject of personal data, upon his or her request, with information concerning the processing of his or her personal data
• organize the processing of personal data in accordance with the current legislation of the Russian Federation
• respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law
• notify the authorized body for the protection of the rights of subjects of personal data, upon request of this body, of the required information within 10 days from the date of receipt of such request
• publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data
• take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to personal data
• fulfill other obligations provided for by the Personal Data Law.

1. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except when there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law
• demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights
• set a condition of prior consent when processing personal data for the purposes of marketing goods, works and services
• withdraw consent to the processing of personal data, and also send a request to cease processing of personal data
• appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inactions of the Operator during the processing of their personal data
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects must:

• provide the Operator with reliable information about themselves
• notify the Operator of clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the consent of the latter are liable in accordance with the legislation of the Russian Federation.

1. Principles of Personal Data Processing

5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data whose processing is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, their relevance with respect to the purposes of processing personal data are ensured. The Operator takes the necessary measures and (or) ensures such measures are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored 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 for storing personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achievement of the purposes of processing or in case the necessity to achieve these purposes is lost, unless otherwise provided by federal law.

1. Purposes of Personal Data Processing

• Purpose of processing: Clarification of order details
• Personal data: Name, phone number, Telegram username
• Legal grounds: Constituent documents of the Operator
• Types of personal data processing: Transfer of personal data

1. Conditions for Personal Data Processing

7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his or her personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to exercise the powers and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act or an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. 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 objectives, provided that the rights and freedoms of the personal data subject are not infringed.
7.6. Processing of personal data is carried out where access of an unlimited number of persons to them is provided by the personal data subject or at his or her request (publicly available personal data).
7.7. Processing of personal data is carried out where such data is subject to publication or mandatory disclosure in accordance with federal law.

1. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of applicable legislation or where the personal data subject has given consent to the Operator to transfer the data to a third party for the purpose of fulfilling obligations under a civil law contract.
8.3. In case inaccuracies in personal data are detected, the User may update them independently by sending the Operator a notification to the Operator’s email address main@east-pay.pro with the subject line “Update of personal data”.
8.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by an agreement or applicable legislation.
The User may withdraw his or her consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator’s email address main@east-pay.pro with the subject line “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should independently familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on transfer (other than provision of access), and also on processing or conditions of processing (other than obtaining access) of personal data made publicly available do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures confidentiality of personal data.
8.8. 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, unless the period of storage of personal data is established by federal law or an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of processing personal data, expiration of the term of consent of the personal data subject, withdrawal of consent by the personal data subject or a request to cease processing of personal data, as well as identification of unlawful processing of personal data.

1. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and (or) transfer of received information via information and telecommunication networks or without such means.

1. Cross-Border Transfer of Personal Data

10.1. Before starting cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data. Such notification is sent separately from the notification of the intention to process personal data.
10.2. Prior to submitting the notification specified above, the Operator must obtain from the authorities of the foreign state, foreign individuals or foreign legal entities to whom cross-border transfer of personal data is planned, the relevant information.

1. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data must not disclose such data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

1. Final Provisions

12.1. The User may receive any clarifications on matters concerning the processing of his or her personal data by contacting the Operator via email at main@east-pay.pro.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://east-pay.pro/privacy/.