PERSONAL DATA PROCESSING POLICY
(Privacy Policy)
1. GENERAL PROVISIONS
1.1. This Policy sets out the procedure for the processing and protection by Individual Entrepreneur Anatoly Viktorovich Mosin (OGRN 304616717300026, INN 616709480872, registered address: 21 1-ya Mayskaya St., apt. 28, Rostov-on-Don, 344019) (hereinafter, the Operator) of the personal data of individuals (hereinafter, Personal Data Subjects) who send information to the Operator's email and visit the website abpro.pro (hereinafter, the Website).
1.2. The Policy has been developed in strict compliance with the Constitution of the Russian Federation, the Civil Code of the Russian Federation, the Labour Code of the Russian Federation and Federal Law No. 152-FZ "On Personal Data" of 27.07.2006 (hereinafter, Law No. 152-FZ).
1.3. The Operator processes personal data exclusively within the territory of the Russian Federation. The databases used to collect, record, systematise, accumulate and store personal data of citizens of the Russian Federation are physically located on the servers of: JSC Timeweb (Timeweb Cloud), 22 Zastavskaya St., bldg. 2, lit. A, Saint Petersburg, 196006.
1.4. This Policy is publicly available and must be posted in the footer of every page of the Website.
2. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
The legal grounds for the processing of personal data by the Operator are:
- the Civil Code of the Russian Federation (Part Two) No. 14-FZ of 26.01.1996;
- the Labour Code of the Russian Federation No. 197-FZ of 30.12.2001 (Articles 65, 86–90);
- the consent of Personal Data Subjects to the processing of their personal data;
- the constituent and registration documents of Individual Entrepreneur A. V. Mosin.
3. PURPOSES, SCOPE, TERMS AND PROCEDURE OF PERSONAL DATA PROCESSING
The Operator processes personal data on a strictly differentiated basis, separating it by mutually incompatible purposes (in accordance with Part 2 of Article 5 of Law No. 152-FZ):
3.1. PURPOSE 1: Handling incoming enquiries, consulting, estimating the cost of architectural design and interior design services, preparing commercial proposals and draft contracts.
- Category of subjects: Prospective clients who have sent an unsolicited email to the Operator's email address (including info@abpro.ru).
- Personal data processed: Surname, first name and patronymic; contact telephone number; email address; other information and files (design briefs, floor plans, references) voluntarily provided and attached by the Subject to the email.
- Processing period: Until a design contract is concluded or a refusal to conclude a contract is received, but no longer than 1 (one) year from the date the email was received.
- Method of destruction: Permanent deletion of the email and its attachments from the Operator's mail server, including emptying the deleted items folder.
3.2. PURPOSE 2: Considering candidates for vacant positions at the Operator's studio, conducting online/offline interviews and assessing professional skills.
- Category of subjects: Job applicants who have sent an application (resume, CV) to the Operator's email address (including hr@abpro.ru).
- Personal data processed: Surname, first name and patronymic; contact telephone number; email; information on citizenship, city of residence, education, qualifications, work experience and length of service; portfolio (sample drawings, visualisations); photograph (sent as part of the resume solely for identification purposes, without biometric examination); other information contained in the resume and cover letter.
- Processing period: Until a decision is made to hire or to refuse employment, but no longer than 30 (thirty) days from the date the application was received.
- Method of destruction: Permanent deletion of resume and portfolio files from the HR specialists' work computers and from the Operator's mail database.
3.3. PURPOSE 3: Ensuring the correct functioning of the Website, improving its performance and analysing the user experience.
- Category of subjects: Website visitors.
- Personal data processed: Cookie data; IP address; information on the browser type and operating system; geolocation (determined by IP address); session parameters; information on actions performed on the Website.
- Processing period: Within the periods set by the technical settings of the web analytics systems, but no longer than the duration of the session or until the user deletes cookies.
- Method of processing: Automated processing using the following online services: YANDEX LLC (Yandex Metrica web analytics service).
4. PROCEDURE FOR COLLECTING AND TRANSFERRING PERSONAL DATA
4.1. The Operator does not use interactive data collection forms on the Website. All information is received exclusively by email.
4.2. Personal data processing includes: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, depersonalisation and destruction.
4.3. Personal data is not transferred to third parties without the additional consent of the Subject, except in cases expressly provided for by the legislation of the Russian Federation. No cross-border transfer of data is carried out.
5. RIGHTS OF PERSONAL DATA SUBJECTS AND THEIR EXERCISE
5.1. The Subject has the right to receive information concerning the processing of their personal data, the right to withdraw consent, and the right to demand that their data be blocked or destroyed if the data is incomplete, outdated or unlawfully obtained.
5.2. Requests or withdrawals of consent shall be sent by the Subject in writing to the Operator's postal address: 20 Zakrutkina St., Rostov-on-Don, 344019, or by email to info@abpro.ru marked "Withdrawal of consent to the processing of personal data".
5.3. The Operator shall cease processing and permanently destroy the personal data within a period not exceeding 3 (three) working days from the date of receipt of the withdrawal of consent (in accordance with Part 5 of Article 21 of Law No. 152-FZ).