Policy regarding the processing of personal data

1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Dmitry Gubenko (hereinafter referred to as the Operator).
Вот перевод на английский язык:
1. General Provisions
1.1. The Operator’s primary objective and condition for carrying out its activities is to respect human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding personal data processing (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://vip-transfer-it.com/.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the internet at https://vip-transfer-it.com/.
2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means that enable their processing.
2.5. Depersonalization of personal data – actions that result in the inability to determine, without additional information, the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or 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), extraction, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information that directly or indirectly relates to a specific or identifiable User of the website https://vip-transfer-it.com/.
2.9. Personal data authorized by the data subject for dissemination – personal data that the data subject has provided access to an unlimited number of persons by giving consent to the processing of personal data authorized for dissemination under the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for dissemination”).
2.10. User – any visitor to the website https://vip-transfer-it.com/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or providing access to personal data to an unlimited number of persons, including publication in mass media, posting in information and telecommunications networks, or providing access in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to a foreign state, a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with no possibility of further restoration in the personal data information system and/or the destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Obtain accurate information and/or documents containing personal data from the data subject.
— Continue processing personal data without the data subject’s consent in cases provided by the Personal Data Law, even if the data subject withdraws their consent or submits a request to cease processing.
— Independently determine the composition and list of necessary and sufficient measures to ensure compliance with obligations under the Personal Data Law unless otherwise specified by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— Provide the data subject with information on the processing of their personal data upon request.
— Organize personal data processing in accordance with the legislation of Italy.
— Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.
— Notify the authorized personal data protection authority upon request within 10 days.
— Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing.
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, or other unlawful actions.
— Cease the transmission (distribution, provision, access) of personal data, stop processing, and destroy personal data in cases provided by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— Receive information on the processing of their personal data, except in cases stipulated by federal laws.
— Request the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing.
— Require prior consent for processing personal data for marketing purposes.
— Withdraw consent for personal data processing at any time.
— File complaints with the authorized personal data protection authority or in court regarding the Operator’s unlawful actions or inactions.
4.2. Personal data subjects are required to:
— Provide the Operator with accurate information about themselves.
— Inform the Operator about updates (changes) to their personal data.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and legitimate purposes.
5.3. The combination of databases containing personal data with incompatible processing purposes is not allowed.
5.4. Personal data must correspond to the purposes of their processing.
5.5. The volume and content of processed personal data must be appropriate and not excessive in relation to the stated processing purposes.
5.6. Personal data accuracy, sufficiency, and, if necessary, relevance must be ensured.
6. Purposes of Personal Data Processing
— Full name
— Email address
— Phone numbers
— Contracts concluded between the Operator and the personal data subject
— Sending informational emails to the email address
7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the data subject.
7.2. Processing is necessary to achieve objectives provided by an international agreement or law of Italy.
7.3. Processing is required for justice administration, court orders, or other legal obligations.
7.4. Processing is necessary for contract execution.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
8.1. The Operator ensures the security of personal data and takes all necessary measures to prevent unauthorized access.
8.2. Personal data will not be transferred to third parties except as required by law or with the data subject’s consent.
8.3. Users may update their personal data by sending an email to Viptransferit@gmail.com with the subject “Personal Data Update.”
8.4. Users may withdraw their consent at any time by sending an email to Viptransferit@gmail.com with the subject “Withdrawal of Consent for Personal Data Processing.”
Вот перевод на английский:
8. Withdrawal of Consent and Data Processing Conditions
8.1. The user may withdraw their consent for the processing of personal data at any time by sending a notification to the Operator via email at Viptransferit@gmail.com with the subject line "Withdrawal of Consent for Personal Data Processing."
8.2. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject must familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.3. Any restrictions imposed by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases where personal data is processed in state, public, or other public interests as defined by the legislation of Italy.
8.4. The Operator ensures the confidentiality of personal data during processing.
8.5. The Operator stores personal data in a format that allows identifying the personal data subject no longer than required for the purposes of data processing unless a different retention period is established by federal law, a contract in which the personal data subject is a party, beneficiary, or guarantor.
8.6. The processing of personal data may be terminated if the purposes of processing have been achieved, the consent of the personal data subject expires, the subject withdraws consent, a request for termination is made, or if unlawful processing is detected.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator performs the 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 carries out automated processing of personal data, including the receipt and/or transfer of the obtained information via information and telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before initiating cross-border transfers of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights about its intention to conduct such a transfer (this notification is sent separately from the notification about personal data processing).
10.2. Before submitting the above notification, the Operator must obtain the necessary information from foreign government authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
11.1. The Operator and other persons who have gained access to personal data must not disclose or distribute personal data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. The user may request any clarifications regarding the processing of their personal data by contacting the Operator via email at Viptransferit@gmail.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy remains 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://vip-transfer-it.com/privacy/ru.