1. General Provisions

This personal data processing policy is compiled in accordance with requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as Personal Data Law) and defines a procedure for processing personal data and measures to ensure security of personal data taken by JSC "NIIMA "PROGRESS" (hereinafter referred to as Operator).

1.1. The Operator sets as its most important aim and condition for implementing its activities the observance of rights and freedoms of man and citizen when processing his personal data, including protection of rights to privacy, personal and family secrets.

1.2. This Operator policy regarding processing of personal data (hereinafter referred to as Policy) applies to all information that the Operator may receive about visitors to the https://progeo.expert website.

2. Key concepts used in the Policy

2.1. Automated processing of personal data is a processing of personal data using computer technology.

2.2. Blocking of personal data is a temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://progeo.expert.

2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data represents actions resulting in impossibility to determine an ownership of personal data by a specific User or other subject of personal data without using an additional information.

2.6. Processing of personal data is any action (operation) or set of actions (operations) performed with a use of automation tools or without them with personal data including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator is a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or carries out a processing of personal data, as well as determines purposes of processing personal data, a composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. Personal data is any information relating directly or indirectly to a specific or identifiable User of the https://progeo.expert website.

2.9. Personal data permitted for distribution by a subject of personal data are personal data with access by unlimited number of persons granted by the subject of personal data by giving consent to a processing of personal data permitted by a subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).

2.10. User is any visitor to the https://progeo.expert website.

2.11. Provision of personal data represents actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data represents any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including a disclosure of personal data in media, posting in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data is a transfer of personal data to a territory of a foreign state to a foreign government body, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data represents any actions resulting in personal data irrevocable destruction with impossibility of further restoration of personal data content in a personal data information system and/or a destruction of tangible media of personal data.

3. Basic rights and responsibilities of the Operator

3.1. The Operator has right to:

— receive from a subject of personal data reliable information and/or documents containing personal data;

— in the case of personal data subject's withdrawal of personal data processing consent, as well as submission of application with a request to stop processing personal data, the Operator has a right to continue processing personal data without a consent of personal data subject if there is legal basis specified in the Personal Data Law;

— independently determine composition and list of measures necessary and sufficient to ensure fulfillment of responsibilities stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide a subject of personal data, on request, with information concerning processing of his personal data;

— organize processing of personal data in accordance with procedure established by current legislation of Russian Federation;

— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with requirements of the Personal Data Law;

— notify authorized body for protection of personal data subject rights, at the request of this body, of necessary information within 10 days from a date of such request receipt;

— publish or otherwise provide unrestricted access to this Policy regarding processing of personal data;

— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

— stop transferring (distributing, providing, accessing) personal data, stop processing and destroy personal data in a manner and cases stipulated by the Personal Data Law;

— perform other responsibilities stipulated by the Personal Data Law.

4. Basic rights and responsibilities of personal data subjects

4.1. Subjects of personal data have right to:

— receive information regarding processing of their personal data, except for cases stipulated by federal laws. Information is provided to a subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except for cases where there is legal basis for disclosing such personal data. A list of information and a procedure for obtaining it is established by the Personal Data Law;

— demand that the Operator clarify their personal data, block it or destroy it if personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for a stated purpose of processing, and also take measures provided by law to protect their rights;

— put forward a condition of prior consent when processing personal data for purpose of promoting goods, works and services on a market;

— revoke consent to processing of personal data, as well as send a request to stop processing of personal data;

— appeal to an authorized body for protection of personal data subjects' rights or in court against illegal actions or inaction of the Operator when processing their personal data;

— to exercise other rights provided by legislation of Russian Federation.

4.2. Subjects of personal data are obliged to:

— provide the Operator with reliable information about themselves;

— inform the Operator about clarification (update, change) of their personal data.

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

5. Principles of personal data processing

5.1. Processing of personal data is performed on a lawful and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with purposes of collecting personal data is not permitted.

5.3. It is not permitted to combine databases containing personal data with processing performed for purposes that are incompatible with each other.

5.4. Only personal data that meet purposes of their processing are subject to processing.

5.5. Content and volume of personal data processed correspond to stated purposes of processing. Excessive amounts of personal data processed in relation to a stated purposes of their processing are not allowed.

5.6. When processing personal data, an accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to purposes of processing personal data are ensured. The operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows a subject of personal data to be identified, for no longer than is required by purposes of processing personal data, unless a storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of purposes of processing or in a case of loss of need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purposes of processing
· Providing a User with access to services, information and/or materials contained on the website
· Identification of a party within the framework of agreements and contracts with the site
· Communication with a User, including sending notifications, requests and information regarding use of the site, provision of services, as well as processing requests and applications from a User
· Improving quality of the site, its usability, developing new products and services
· Conducting statistical and other research based on provided data

Personal data
Full name
Email address
Phone numbers
Date and place of birth, gender
Photos
Residential address
Link to personal site/blog

Legal basis
Federal Law "On Information, Informational Technologies and Information Protection" dated 27.07.2006 No. 149-FZ

Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
Sending newsletters to an email address

7. Terms of personal data processing

7.1. Processing of personal data is carried out with a consent of a personal data subject to processing of his personal data.

7.2. Processing of personal data is necessary to achieve goals stipulated by an international treaty of Russian Federation or by law, to exercise functions, powers and obligations imposed on the Operator by legislation of Russian Federation.

7.3. Processing of personal data is necessary for administration of justice, execution of a judicial act, an act of another body or official subject to execution in accordance with legislation of Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for performing an agreement with a personal data subject being a party, beneficiary or guarantor, as well as for conclusion of an agreement at initiative of a personal data subject or an agreement under which a personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary to exercise rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that it does not violate rights and freedoms of personal data subject.

7.6. Processing of personal data is performed with access by an unlimited number of persons being provided by a subject of personal data or at his request (hereinafter referred to as publicly available personal data).

7.7. Processing of personal data being a subject to publication or mandatory disclosure in accordance with federal law is performed.

8. Procedure for collecting, storing, transferring and other types of processing personal data

Security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

8.2. Personal data of a User will never, under any circumstances, be transferred to third parties, except in cases related to implementation of current legislation or in case that a 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.

8.3. In the case that inaccuracies are detected in personal data, a User can update them independently by sending a notification to the Operator at the Operator's email address info@progeo.expert marked "Updating personal data".

8.4. A period for processing personal data is determined by achievement of purposes for which personal data were collected, unless another period is provided by an agreement or applicable law. User may at any time revoke his consent to processing of personal data by sending a notification to the Operator via e-mail to the Operator's e-mail address info@progeo.expert marked "Withdrawal of consent to personal data processing".

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for actions of third parties, including service providers specified in this clause.

8.6. Prohibitions established by a subject of personal data on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in state, public and other public interests determined by legislation of Russian Federation.

8.7. When processing personal data, the Operator ensures confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows a subject of personal data to be identified, no longer than required by purposes of processing personal data, unless a storage period for personal data is established by federal law, an agreement to which a subject of personal data is a party, beneficiary or guarantor.

8.9. A condition for termination of personal data processing may be an achievement of purposes of processing personal data, an expiration of a consent of a personal data subject, withdrawal of consent by a subject of personal data or a requirement to terminate processing of personal data, as well as detection of unlawful processing of personal data.

9. List of actions performed by the Operator with personal data received

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data with or without receipt and/or transmission of received information via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before commencing activities related to a cross-border transfer of personal data, the Operator is obliged to notify an authorized body for protection of rights of personal data subjects of its intention to carry out a cross-border transfer of personal data (such notification is sent separately from a notification of intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without a consent of a personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. User can receive any clarifications on questions of interest regarding processing of his personal data by contacting the Operator via e-mail info@progeo.expert.

12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

12.3. A current version of the Policy is freely available on the Internet at the address https://progeo.expert/en/privacy-policy-en.