Location of Couponsaler LLC: Brnnsk 1440/134, 664 51 lapanice, Czech Republic
1. Purpose and scope of the document
“The policy of Couponsaler LLC (hereinafter also referred to as the Company) in relation to the processing of personal data” (hereinafter referred to as the “Policy”) determines the position and intentions of the Company in the field of processing and protection of personal data in order to observe and protect the rights and freedoms of each person and, in particular, the right to privacy, personal and family secrets, protection of one's honor and good name. The policy is strictly executed by the managers and employees of all structural divisions and separate divisions of the Company. The Policy applies to all personal data of entities processed in the Company using automation tools and without using such tools. This Policy has access to any subject of personal data.
Personal data - any information relating directly or indirectly to a specific or determinable natural person (citizen). Those. Such information, in particular, may include: name, year, month, date and place of birth, address, information about family, social, property status, information about education, profession, income, and other information. Processing personal data - any action (operation) or a set of actions (operations) with personal data committed with or without automation. Such actions (operations) include: collection, receipt, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion,
3. Subjects of personal data
Couponsaler LLC processes the personal data of the following persons:
- Company employees;
- subjects with which civil law contracts are concluded;
- Company customers;
- candidates for filling the vacant positions of the Company;
- registered users of the website of the Company;
- representatives of legal entities;
- suppliers (individual entrepreneurs).
4. Principles and conditions for the processing of personal data
Couponsaler LLC understands the security of personal data as the protection of personal data from unlawful or accidental access to it, the destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data and takes the necessary legal, organizational and technical measures to protect personal data.
Processing and ensuring the security of personal data at Couponsaler LLC is carried out in accordance with the requirements of the Constitution of the Russian Federation, Federal Law No. 152-ФЗ “On Personal Data”, by-laws, and other cases and features of the processing of personal data of federal laws of the Russian Federation.
When processing personal data of the Company, it adheres to the following principles:
- legality and fair basis;
- restrictions on the processing of personal data by achieving specific, predetermined and legitimate goals;
- preventing personal data processing incompatible with the purposes of collecting personal data;
- preventing the unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
- processing personal data that meets the purposes of their processing;
- content matching.
The company processes personal data only if at least one of the following conditions exists:
- personal data processing is carried out with the consent of the personal data subject to the processing of his personal data;
- the processing of personal data is necessary to achieve the goals stipulated by law, to implement and fulfill the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation;
- the processing of personal data is necessary for the execution of a contract to which either the beneficiary or guarantor is a personal data subject, as well as for the conclusion of a contract on the initiative of the personal data subject or the contract under which the personal data subject will be the beneficiary or guarantor;
- the processing of personal data is necessary to exercise the rights and legitimate interests of the Company or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject;
- processing of personal data is carried out, access to an unlimited circle of persons to which is provided by the subject of personal data or at his request;
- processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
The Company has the right to entrust the processing of personal data of citizens to third parties, on the basis of an agreement concluded with these persons.
Persons who process personal data on behalf of the Company undertake to comply with the principles and rules for the processing and protection of personal data provided for by Federal Law No. 152-ФЗ “On Personal Data”. For each person, a list of actions (operations) with personal data is defined that will be performed by the legal entity that processes personal data, the purpose of processing, the obligation of such a person to maintain confidentiality and ensure the security of personal data during their processing, as well as the requirements for the protection of processed personal data data.
In cases established by the legislation of the Russian Federation, the Company is entitled to transfer personal data of citizens.
In order to provide information support, publicly available sources of personal data of employees may be created in the Company, including directories and address books. With the consent of the employee, publicly available sources of personal data may include his surname, name, patronymic, date and place of birth, position, contact phone numbers, email address. Information about the employee should be excluded from public sources of personal data at any time at the request of the employee or by decision of the court or other authorized state bodies.
The company destroys or depersonalizes personal data when the processing goals are achieved or if the need to achieve the processing goals is lost.
5. Rights of the subject of personal data
A citizen whose personal data is processed by Couponsaler LLC has the right to:
5.1. receive from the Company:
- confirmation of the fact of processing personal data of the Company;
- legal grounds and purposes of processing personal data;
- information on the methods of processing personal data used by the Company;
- name and location of Couponsaler LLC;
- information about persons 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;
- a list of processed personal data relating to the citizen from whom the request was received and the source of their receipt, unless otherwise provided for by federal law;
- information about the periods of processing personal data, including the periods of their storage;
- information on the procedure for the exercise by a citizen of the rights provided for by the Federal Law "On Personal Data" No. 152-FZ;
- information on the ongoing or alleged cross-border transfer of personal data;
- the name and address of the person processing the personal data on behalf of the Company;
- other information stipulated by the Federal Law on Personal Data No. 152-ФЗ or other federal laws.
5.2. demand clarification of their personal data, their blocking or destruction in case personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
5.3. withdraw your consent to the processing of personal data;
5.4. demand the elimination of illegal actions of the Company in relation to its personal data;
5.5. appeal the actions or omissions of the Company if a citizen considers that the Company is processing his personal data in violation of the requirements of Federal Law No. 152-FZ “On Personal Data” or otherwise violates his rights and freedoms;
5.6. to protect their rights and legitimate interests, including to recover damages and / or compensation for non-pecuniary damage in court.
In case of failure to comply with the provisions of this Policy, Couponsaler LLC is liable in accordance with the current legislation of the Russian Federation.
DRAW YOUR ATTENTION TO!
Get clarification on the issues of processing your personal data that are of interest to you by contacting Couponsaler LLC personally or by sending an official request by Russian Post to the address: St. Petersburg, Kolomyazhsky prospekt, building 33, building 2, letter A, room 75N B, 197341. in case of sending an official request to Couponsaler LLC, the request text must indicate:
- FULL NAME;
- the number of the main document proving the identity of the subject of personal data or his representative, information on the date of issue of the said document and the authority that issued it;
- information confirming your participation in relations with Couponsaler LLC or information that otherwise confirms the fact of processing personal data of Couponsaler LLC;
- Signature of citizen (or his legal representative). If the request is sent in electronic form, then it must be executed in the form of an electronic document and signed by electronic signature in accordance with the legislation of the Russian Federation.
The megakupon.ru website publishes an up-to-date version of the “Couponsaler LLC Policies Regarding the Processing of Personal Data”.
Information on current requirements for the protection of personal data
When processing personal data, Couponsaler LLC takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data. Such measures in accordance with Federal Law No. 152-FZ “On Personal Data” include:
- identification of threats to the security of personal data during their processing in personal data information systems;
- the application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems necessary to fulfill the requirements for the protection of personal data, the implementation of which ensures the levels of personal data security established by the Government of the Russian Federation;
- the use of information security tools;
- assessment of the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of the personal data information system;
- detection of unauthorized access to personal data and taking measures;
- restoration of personal data modified or destroyed due to unauthorized access to them;
- establishing rules for access to personal data processed in the personal data information system, as well as ensuring registration and recording of all actions performed with personal data in the personal data information system;
- control over measures taken to ensure the security of personal data and the level of security of personal data information systems;
- accounting of machine carriers of personal data;
- organization of access control to the territory of the Company;
- placement of technical means of processing personal data within the territory of the Company;
- maintenance of technical means of protection, signaling in constant readiness;
- monitoring user actions, conducting proceedings on violations of personal data security requirements.
In order to coordinate actions to ensure the security of personal data, Couponsaler LLC has appointed persons responsible for ensuring the security of personal data.