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Personal Data Processing Policy

1. General provisions

1.1. The Privacy Policy (hereinafter referred to as the Policy) at Qform intl LLC(hereinafter referred to as the Company) has been developed in accordance with the Convention on the Protection of Individuals with Regard to Automated Processing of Personal Data (ETS N 108, concluded in Strasbourg on 28.01.1981); Regulation No. 2016/679 of the European Parliament and of the Council of the European Union "On the Protection of Individuals in the Processing of Personal Data and on the Free circulation of such Data, as well as on the repeal of Directive 95/46/EC (General Regulation on the Protection of Personal Data)" (adopted in Brussels, 27.04.2016)., as well as in accordance with other federal laws defining the cases and features of personal data processing and ensuring the security and confidentiality of such information and applies to all information, including personal data in the understanding of applicable legislation.

1.2. The Policy has been developed in order to implement the requirements of legislation in the field of processing and ensuring the security of personal data and is aimed at ensuring the protection of human and civil rights and freedoms when processing his personal data by the company.

1.3. The Policy establishes:

  • purposes of personal data processing;
  • classification of personal data and personal data subjects;
  • general principles of personal data processing;
  • the main participants of the personal data processing management system;
  • the main approaches to the personal data processing management system.

List of terms and definitions.

  • Company (operator of personal data processing) – QForm company (Qform intl LLC 02882801), which processes personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions performed with personal data.
  • Personal data - any information relating directly or indirectly to a specific or identifiable individual (subject of personal data);
  • Processing of personal data –  any action (operation) of the Company or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access) to third parties, depersonalization, blocking, deletion and destruction of personal data;
  • Automated processing of personal data - processing of personal data by means of computer technology;
  • Dissemination of personal data – actions aimed at disclosing personal data to third parties with whom the operator has a contractual relationship;
  • The subject of personal data – an individual who is directly or indirectly identified using personal data.

 

2. Purposes of personal data processing

2.1. Компания осуществляет обработку персональных данных в целях:

  • conclusion of any contracts with the subject of personal data and fulfillment of contractual obligations for the purpose of carrying out permitted economic activities provided for in the registration documents;
  • providing the subject of personal data with information about products, services and events posted on the websites of third parties with whom the company has contractual relations;
  • the company's fulfillment of its obligations, within the framework of the services provided, on the basis of concluded contracts (fulfillment of contractual obligations);
  • technical administration of site pages;
  • customer base management;
  • conducting settlements with clients;
  • work with complaints, statements of citizens;
  • sending notifications, letters about promotions, services/works provided, etc.

 

3. Classification of personal data and Personal data subjects

3.1. Personal data includes any information related directly or indirectly to a specific or identifiable individual (Subject of personal data) processed by the company to achieve predetermined goals.

3.2. The Company does not process special categories of personal data concerning race and nationality, political views, religious and philosophical beliefs, intimate life, criminal record of individuals, unless otherwise established by the legislation.

3.3. The Company processes personal data of the following categories of Personal data Subjects:

individuals who have purchased or intend to purchase services on their own behalf or on behalf of legal entities provided by the Company, services of third parties with whom the Company has contractual relations;

other individuals who have expressed their consent to the processing of their personal data by the Company.

 

4. General principles of personal data processing

4.1. The Company processes personal data on the basis of general principles:

  • legality of pre-defined specific purposes and methods of personal data processing;
  • ensuring proper protection of personal data;
  • compliance of the purposes of personal data processing with the purposes previously defined and declared when collecting personal data;
  • compliance of the volume, nature and methods of personal data processing with the purposes of personal data processing;
  • the reliability of personal data, their sufficiency for the purposes of processing, the inadmissibility of processing personal data that are redundant in relation to the purposes stated when collecting personal data;
  • the inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
  • storage of personal data in a form that allows you to identify the Subject of personal data, no longer than the purposes of their processing require;
  • destruction or depersonalization of personal data upon achievement of the purposes of their processing, if the period of storage of personal data is not established by the legislation, the contract to which the Subject of personal data is a party;
  • ensuring the confidentiality and security of the processed personal data.

4.2. Within the framework of personal data processing:

4.2.1. The subject of personal data has the right to:

  • receive information concerning the processing of his personal data in the manner, form and time limits established by the Legislation on Personal Data;
  • to demand clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, unreliable, illegally obtained, are not necessary for the stated purpose of processing or are used for purposes not previously stated when the Subject of personal data provided consent to the processing of personal data;
  • take legal measures to protect their rights;
  • withdraw your consent to the processing of personal data. At the same time, the withdrawal of consent to the processing of personal data means the refusal to provide services by the Company. 

4.2.2. The Company has the right to:

  • process the personal data of the Personal Data Subject in accordance with the stated purpose;
  • require the Subject of personal data to provide reliable personal data necessary for the execution of contracts, the provision of services, the identification of the Subject of personal data, as well as in other cases provided for by the Legislation on personal data;
  • process publicly available personal data of individuals;
  • to entrust the processing of personal data to a third party with the consent of the Personal data Subject;
  • update or modify this agreement at any time. Continued use of the Company's services after making changes and publishing them on the Company's website means the consent of the personal data subject to the processing of his personal data on new terms.

 

5. Organization of the personal data processing management system.

5.1. Processing of personal data of the Subject of personal data is carried out with his consent to such processing, as well as without it in cases provided for by the Legislation on personal data. Consent is expressed through the form of the website (checkbox), by clicking it.

5.2. The Company has the right to entrust the processing of personal data to another person with the consent of the Personal data Subject, unless otherwise provided by federal law. Such processing of personal data is carried out only on the basis of an agreement concluded between the Company and a third party, which must define:

  • list of actions (operations) with personal data that will be performed by a third party processing personal data;
  • purposes of personal data processing;
  • obligations of a third party to respect the confidentiality of personal data and ensure their security during processing, as well as requirements for the protection of processed personal data.  

5.3. The Company transfers personal data to state bodies within their powers in accordance with the legislation.

5.4. The Company is liable to the Personal Data Subject for the actions of persons to whom the Company entrusts the processing of personal data of the Personal Data Subject, to the extent provided for by the contract between the Company and third parties.

5.5. Access to the processed personal data is provided only to those Employees of the Company who need it in connection with the performance of their official duties and in compliance with the principles of personal responsibility.

5.6. The processing of personal data is terminated upon achievement of the purposes of such processing, as well as upon expiration of the period provided for by law, contract, or consent of the Personal data Subject to the processing of his personal data.

5.7. The processing of personal data is carried out in compliance with confidentiality, which means the obligation not to disclose to third parties and not to distribute personal data without the consent of the Subject of personal data, unless otherwise provided by the legislation.

5.8. The security of the processed personal data is ensured by the Company within the framework of organizational, technical and legal measures for the protection of information constituting a trade secret, taking into account the requirements of the Legislation on personal data adopted in accordance with it regulatory legal acts.

5.9. The Company is not responsible for the use (both lawful and unlawful) by third parties of Information posted by the subject of personal data on the websites of third parties with whom the Operator has no contractual relationship, including its reproduction.

 

6. Final provisions

6.1. The Policy is publicly available and is subject to posting on the official website of the Company https://qform.io .