Main concepts 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 processing of personal data (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 provide their accessibility on the Internet at the network address https://p2p.exnode.ru.
2.4. Personal data information system - a set of personal data contained in databases and providing information technology and technical means for their processing.
2.5. Anonymization of personal data - actions resulting in the impossibility of determining the belonging of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Platform - a state or municipal authority, legal or natural person, acting independently or jointly with other persons, organizing and/or processing personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or determinable User of the website https://p2p.exnode.ru.
2.9. Personal data authorized by the subject of personal data for distribution - personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner provided by the Personal Data Law (hereinafter - personal data authorized for distribution).
2.10. User - any visitor to the website https://p2p.exnode.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or acquainting an unlimited circle of persons with personal data, including disclosure of personal data in the media, placement in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign government body, foreign individual or foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data are irretrievably destroyed, with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
Main rights and obligations of the Platform
3.1. The Platform has the right to:
obtain from the subject of personal data accurate information and/or documents containing personal data;
in case the subject of personal data revokes their consent to the processing of personal data, as well as sending a request to cease the processing of personal data, the Platform has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on personal data;
independently determine the composition and list of measures necessary and sufficient to ensure the performance of obligations provided for by the Law on personal data and adopted in accordance with its regulatory legal acts, unless otherwise provided by the Law on personal data or other federal laws.
3.2. The Platform is obliged to:
- provide the subject of personal data with information related to the processing of their personal data upon their request;
- organize the processing of personal data in accordance with the current legislation of the Russian Federation;
- respond to requests and inquiries from the subjects of personal data and their authorized
- representatives in accordance with the requirements of the Law on personal data;
- provide the necessary information to the authorized body for the protection of the rights of subjects of personal data upon the request of this body within 10 days of receiving such a request;
- publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with respect to personal data;
Main rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- receive information about the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject in an accessible form, and it should not contain personal data related to other personal data subjects, except when there are legitimate reasons for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- require the Platform to clarify their personal data, block or destroy them if personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take the measures provided by law to protect their rights;
- stipulate a prior consent condition for the processing of personal data for the purpose of promoting goods, works, and services on the market;
- withdraw their consent to the processing of personal data, as well as send a request to stop the processing of personal data;
- appeal to the authorized body for protecting the rights of personal data subjects or in court for the unlawful actions or inaction of the Platform in processing their personal data;
exercise other rights provided by Russian legislation.
Principles of personal data processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, pre-determined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The combination of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Processing of excessive personal data in relation to the stated purposes is not allowed.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing is ensured during personal data processing. The platform takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows the identification of the subject of personal data for no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract, the party to which, the beneficiary, or guarantor of which is the subject of personal data. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of no longer needing to achieve these purposes, unless otherwise provided by federal law.
7.Personal data processing terms
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of his/her personal data.
7.2. Personal data processing is necessary for achieving the purposes provided for by an international treaty of the Russian Federation or a law, for the implementation of the platform’s functions, powers, and responsibilities imposed by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a court decision, a decision of another authority or official, which must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract, where the personal data subject is a party thereto, a beneficiary, or a guarantor thereof, as well as for the conclusion of a contract at the request of the personal data subject or a contract, under which the personal data subject will act as a beneficiary or a guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the platform or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated thereby.
7.6. Processing of personal data is carried out for personal data, access to which is provided by the personal data subject to an unlimited circle of persons or at his/her request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out for personal data that must be published or disclosed in accordance with federal law.
8.Order of collection, storage, transfer, and other forms of processing of personal data
The security of personal data processed by the Platform is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.8.1. The Platform ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never be transferred to third parties under any circumstances, except for cases related to the execution of current legislation or if the subject of personal data has given consent to the Platform to transfer data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Platform at the email address supportp2p@exnode.ru with the subject line "Updating personal data."
8.4. The processing time of personal data is determined by achieving the goals for which personal data was collected, unless another period is provided for in the contract or in the current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Platform at the email address supportp2p@exnode.ru with the subject line "Revocation 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 these parties in accordance with their User Agreement and Privacy Policy. The Platform is not responsible for the actions of third parties, including service providers mentioned in this section.
8.6. Prohibitions on transfer (excluding access provision), processing or processing conditions (excluding access acquisition) of personal data allowed for distribution do not apply in cases of processing personal data in state, public and other public interests, as defined by Russian legislation.
8.7. The platform ensures the confidentiality of personal data when processing it.
8.8. The platform stores personal data in a format that allows identifying the subject of the personal data for no longer than is required for the purposes of processing the personal data, unless the storage period of personal data is determined by federal law, a contract, a party, a beneficiary or a guarantor of which is the subject of personal data.
8.9. The termination of personal data processing may result from achieving the purposes of personal data processing, expiration of the consent of the subject of personal data, revocation of the consent of the subject of personal data or a request to terminate the processing of personal data, as well as the identification of illegal processing of personal data.
List of actions taken by the platform for received personal data
9.1. The platform collects, records, systematizes, accumulates, stores, specifies (updates, changes), retrieves, utilizes, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The platform carries out automated processing of personal data with the receipt and/or transmission of received information over information telecommunication networks or without them.
