Policy Regarding Personal Data Processing

1. General Provisions

• The Operator’s most important goal and condition of its activity is to observe the rights and freedoms of an individual and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

2. Basic Concepts Used in the Policy

• Automated processing of personal data means processing of personal data by computer technology.
• Blocking of personal data means temporary suspension of personal data processing, except in cases where processing is necessary for the clarification of personal data.
• Website means a collection of graphic and informational materials, as well as computer programs and databases that make them available on the Internet at the network address /.
• Personal data information system means a system of personal data contained in databases and information technologies and technical means that ensure their processing.
• Anonymization of personal data means actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another personal data subject.
• Processing of personal data means any action (operation) or a set of actions (operations) performed with personal data, with or without the use of automation, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
• Operator means a state body, municipal body, legal or natural person that independently or jointly with other persons organizes and (or) carries out processing of personal data, as well as determines the purposes of processing of personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
• Personal data means any information relating directly or indirectly to a specific or identifiable User of the website /.
• Personal data authorized by the subject for distribution means personal data to which the subject of personal data provides access to an unlimited number of persons by giving consent to the processing of personal data allowed by the subject for distribution.
• User means any visitor to the website /.
• Provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
• Dissemination of personal data means any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or at getting acquainted with personal data of an unlimited circle of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
• 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 natural person or a foreign legal entity.
• Destruction of personal data means any actions which result in irreversible destruction of personal data with impossibility of further restoration of the content of personal data in the personal data information system and (or) which result in destruction of material carriers of personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator is entitled to:

• receive from the subject of personal data reliable information and (or) documents containing personal data;
• continue to process personal data in case the subject of personal data withdraws his consent to personal data processing 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 obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance therewith, unless otherwise provided for by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the subject of personal data, upon request, with information concerning the processing of his personal data;
• organize the processing of personal data in accordance with the legislation of the Russian Federation;
• respond to requests of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
• report to the authorized body for the protection of the rights of subjects of personal data, at their request, the necessary information within 10 days from the date of such request;
• publish or otherwise provide unrestricted access to this Policy regarding personal data processing;
• take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as other unlawful actions;
• stop transferring (distribution, provision, access) of personal data, stop processing and destroy personal data in cases and under the conditions provided for by the Personal Data Law;
• fulfill other duties provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Rights of personal data subjects

• to receive information relating to the processing of his personal data, except in cases provided for by federal laws. The information shall be provided by the Operator in an accessible form and it shall not contain personal data relating to other subjects of personal data, except where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
• to demand from the Operator clarification of his personal data, their blocking or destruction in case personal data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the declared purpose of processing, as well as to take measures provided by law to protect his rights;
• to set the condition of prior consent when processing personal data for the purposes of promotion of goods, works and services on the market;
• to withdraw his consent to personal data processing;
• to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or omissions of the Operator during the processing of his personal data;
• to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Obligations of personal data subjects:

• to provide the Operator with reliable data about himself;
• to inform the Operator about the clarification (updating, change) of his personal data.

Persons who have transferred false data about themselves or data about another personal data subject to the Operator without the latter’s consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

• Processing of personal data is carried out on a lawful and fair basis.
• Processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
• It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
• Only personal data that meet the purposes of its processing are subject to processing.
• The content and volume of processed personal data corresponds to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not allowed.
• Accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing shall be ensured during personal data processing. The Operator takes the necessary measures or ensures that they are taken to delete or clarify incomplete or inaccurate data.
• Storage of personal data shall be carried out in a form allowing to identify the subject of personal data, no longer than required by the purposes of personal data processing, if the period of storage of personal data is not established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.

Upon achieving the purposes of personal data processing, or in case of loss of necessity in achieving these purposes, personal data shall be destroyed or depersonalized unless otherwise provided by federal law.

6. Purposes of personal data processing

The purpose of processing is to provide the User with access to services, information and (or) materials contained on the website.

Personal data processed by the Operator:

• surname, name and patronymic
• e-mail address
• telephone numbers
• date and place of birth
• photos

Legal grounds for personal data processing:

• statutory (constituent) documents of the Operator
• contracts concluded between the Operator and the subject of personal data

Types of personal data processing performed by the Operator:

• collection, recording, systematization, accumulation, storage, deletion and depersonalization of personal data
• sending information to e-mail addresses

7. Terms of personal data processing

• personal data processing is carried out with the consent of the subject of personal data to the processing of his personal data;
• personal data processing is necessary for the achievement of the goals provided for by an international treaty of the Russian Federation or by the law, for the performance of functions, powers and duties imposed by the legislation of the Russian Federation on the operator;
• personal data processing is necessary for the administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings;
• personal data processing is necessary for the performance of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data;
• personal data processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant purposes provided that the rights and freedoms of the subject of personal data are not violated;
• processing of personal data to which the subject of personal data has provided access to an unlimited number of persons or at his request is carried out (hereinafter, publicly available personal data);
• processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedures for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to comply in full 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 by unauthorized persons.
• The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of current legislation or in the event that the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
• In the event of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the e-mail address sales@magnumestate.pro with the note “Personal data update”.
• The period of processing of personal data is determined by the achievement of the goals for which personal data was collected, unless a different period is provided for by the contract or current legislation. The User may withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the address sales@magnumestate.pro marked “Withdrawal of consent to the processing of personal data”.
• Information collected by third-party services, including payment systems and communication services, is stored and processed by these persons (operators) in accordance with their User Agreement and Privacy Policy. The subject of Personal Data and/or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
• Prohibitions established by the subject of personal data on the transfer (except for providing 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 of processing of personal data in state, public and other public interests determined by the legislation of the Russian Federation.
• The Operator ensures the confidentiality of personal data during processing.
• The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law or an agreement to which the subject of personal data is a party, beneficiary or guarantor.
• The termination of personal data processing may occur upon achievement of the objectives of personal data processing, upon expiration of the consent of the subject of personal data, upon withdrawal of consent by the subject of personal data, upon request to stop personal data processing, as well as upon detection of unlawful processing of personal data.

9. List of actions by the Operator with 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 received information via information and telecommunication networks or without it.

10. Cross-border transfer of personal data

• Before starting the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to carry out personal data processing).
• Before submitting the above notification, the Operator is obliged to receive from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.

11. Confidentiality of personal data

The operator and other persons who have received access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final provisions

• The User can receive any explanations on issues of interest concerning the processing of his personal data by contacting the Operator via e-mail at sales@magnumestate.pro.
• This document will reflect any changes to the personal data processing policy of the Operator. The Policy is valid indefinitely until replaced by a new version.
• The current version of the Policy is freely available on the Internet at /.