1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by SIMES LLC (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to respect human and civil rights and freedoms when processing his personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://seames.ru/.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer facilities.
2.2. Blocking of personal data - temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://seames.ru/.
2.4. Personal data information system - a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine the belonging of personal data to a specific User or other personal data subject without the use of additional information.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed using or without using automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a public authority, municipal authority, legal entity or individual, independently or jointly with other persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://seames.ru/.
2.9. Personal data permitted by the personal data subject for dissemination - personal data to which access by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User - any visitor to the website https://seames.ru/.
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 at familiarizing an unlimited number of persons with personal data, including publicizing personal data in the media, posting in information and telecommunication 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 government body of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data are irrevocably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material media of personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right:
- to receive reliable information and/or documents containing personal data from the personal data subject;
- in case of withdrawal of consent to the processing of personal data by the personal data subject, as well as sending a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations 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 the personal data subject, upon his request, with information regarding the processing of his personal data;
- to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- to respond to the inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- to inform the authorized body for the protection of the rights of personal data subjects upon the request of this body with the necessary information within 10 days from the date of receipt of such request;
- to publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
- to take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with personal data;
- to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- to fulfill other obligations stipulated 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 regarding the processing of his personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects, unless there are legal 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 the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated processing purpose, as well as to take measures provided by law to protect his rights;
- to set a condition of prior consent when processing personal data for the purpose of marketing goods, works and services;
- to withdraw consent to the processing of personal data, as well as to send a request to stop processing personal data;
- to appeal unlawful actions or inaction of the Operator in the processing of his personal data to the authorized body for the protection of personal data subjects or to the court;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
- to provide the Operator with reliable data about themselves;
- to inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption for the deletion or clarification of incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows the identification of the personal data subject, no longer than required by the purposes of personal data processing, unless the personal data storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of processing purposes or in case of loss of necessity for achieving these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing




7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or a law, to implement the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a court order, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator 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.
7.6. Processing of personal data is carried out, access to which is granted by the personal data subject to an unlimited number of persons or at his request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address expert@seames.ru with the subject line "Personal Data Update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless otherwise provided by the contract or current legislation. The User may revoke his consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address expert@seames.ru with the subject line "Revocation of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, established by the personal data subject, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject, no longer than required by the purposes of personal data processing, unless the personal data storage period is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the personal data subject's consent, the withdrawal of consent by the personal data subject or a request to stop processing personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without it.
10. Cross-border Transfer of Personal Data
10.1. Before starting activities on cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of his intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom 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 personal data to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email at expert@seames.ru.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://seames.ru/privacy.