Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 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 Yulia Alexandrovna Martynova (hereinafter referred to as the "Operator").
1.1. The Operator’s primary goal and condition for its operations is the observance of human and civil rights and freedoms when processing their 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 obtain about visitors to the website https://emco-realty.com.
2. Key Terms 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 personal data processing (except where processing is necessary to clarify personal data).
2.3. Website – a combination of graphical and informational materials, as well as computer programs and databases, making them available on the internet at the network address https://emco-realty.com.
2.4. Personal Data Information System – a set of personal data contained in databases and the information technologies and technical means enabling their processing.
2.5. Depersonalization of Personal Data – actions making it impossible to determine, without additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of Personal Data – any action (operation) or set of actions performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator – a state body, municipal authority, legal entity, or individual organizing and/or carrying out the processing of personal data independently or jointly with others, and determining the purposes of processing personal data, the composition of personal data to be processed, 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://emco-realty.com.
2.9. Personal Data Authorized by the Subject for Dissemination – personal data to which access by an unlimited number of persons has been granted by the subject of personal data by consenting to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as "Personal Data Authorized for Dissemination").
2.10. User – any visitor to the website https://emco-realty.com.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Dissemination of Personal Data – actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publishing personal data in mass 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 foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
– Receive accurate information and/or documents containing personal data from the subject of personal data;
– Continue processing personal data without the subject’s consent if grounds specified in the Personal Data Law exist, in case the subject withdraws consent or submits a request to cease processing;
– Independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
– Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
– Organize the processing of personal data in accordance with current Russian legislation;
– Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the Personal Data Law;
– Provide the authorized body for the protection of personal data subjects’ rights with necessary information within 10 days of receiving a request;
– Publish or otherwise ensure unrestricted access to this Policy on personal data processing;
– Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, or other unlawful actions;
– Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in cases and manner prescribed by the Personal Data Law;
– Fulfill other obligations stipulated by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
– Obtain information regarding the processing of their personal data, except in cases provided by federal laws. The Operator provides this information in an accessible form, excluding personal data of other subjects unless legally justified. The procedure for obtaining information is established by the Personal Data Law;
– Require the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated processing purpose, and take legal measures to protect their rights;
– Impose a condition of prior consent when personal data is processed for market promotion of goods, works, or services;
– Withdraw consent to the processing of personal data and submit a demand to cease processing;
– Appeal to the authorized body for the protection of personal data subjects’ rights or in court against unlawful actions or inaction of the Operator in processing their personal data;
– Exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
– Provide the Operator with accurate information about themselves;
– Notify the Operator of updates or changes to their personal data.
4.3. Persons who provide the Operator with false information about themselves or about another personal data subject without the latter’s consent bear responsibility under Russian law.
5. Principles of Personal Data Processing
5.1. Personal data processing is conducted on a lawful and fair basis.
5.2. Processing is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of data collection is prohibited.
5.3. Merging databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data relevant to the processing purposes may be processed.
5.5. The content and volume of processed personal data align with the stated processing purposes. Excessive data relative to the stated purposes is not permitted.
5.6. Processing ensures the accuracy, sufficiency, and, where necessary, relevance of personal data relative to the processing purposes. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form allowing identification of the data subject for no longer than required by the processing purposes, unless a storage period is set by federal law or an agreement. Processed data is destroyed or anonymized upon achieving the processing purposes or when no longer necessary, unless otherwise provided by law.
6. Purposes of personal data processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the objectives outlined in an international treaty of the Russian Federation or law, and to perform the functions, powers, and duties imposed on the Operator by Russian legislation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or an act of another authority or official subject to enforcement under Russian legislation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract where the personal data subject is a party, beneficiary, or guarantor, or for concluding a contract initiated by the personal data subject or under which the subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out on personal data made publicly available by the personal data subject or at their request (hereinafter referred to as "publicly available personal data").
7.7. Processing is carried out on personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with current legislation on personal data protection.
8.1. The Operator ensures the integrity of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases required by law or when the personal data subject has consented to the transfer to fulfill obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by notifying the Operator via email at Emco-real-estate@yandex.ru with the subject line "Personal Data Update."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the data was collected, unless otherwise specified by contract or law.
The User may withdraw consent to personal data processing at any time by notifying the Operator via email at Emco-real-estate@yandex.ru with the subject line "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 these parties (Operators) in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties, including the service providers mentioned herein.
8.6. Prohibitions established by the personal data subject on the transfer (except for providing access) or processing of personal data permitted for dissemination do not apply in cases of processing carried out in state, public, or other public interests as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the data subject for no longer than necessary to achieve the processing purposes, unless a storage period is set by federal law or contract.
8.9. Processing of personal data may be terminated upon achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the data subject, a request to cease processing, or if unlawful processing is identified.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator conducts automated processing of personal data with or without the transmission of received information via telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before engaging in cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intent to conduct such transfers (this notification is separate from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the personal data will be transferred.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarification on questions regarding the processing of their personal data by contacting the Operator via email at Emco-real-estate@yandex.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://emco-realty.com/polici.
This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 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 Yulia Alexandrovna Martynova (hereinafter referred to as the "Operator").
1.1. The Operator’s primary goal and condition for its operations is the observance of human and civil rights and freedoms when processing their 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 obtain about visitors to the website https://emco-realty.com.
2. Key Terms 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 personal data processing (except where processing is necessary to clarify personal data).
2.3. Website – a combination of graphical and informational materials, as well as computer programs and databases, making them available on the internet at the network address https://emco-realty.com.
2.4. Personal Data Information System – a set of personal data contained in databases and the information technologies and technical means enabling their processing.
2.5. Depersonalization of Personal Data – actions making it impossible to determine, without additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of Personal Data – any action (operation) or set of actions performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator – a state body, municipal authority, legal entity, or individual organizing and/or carrying out the processing of personal data independently or jointly with others, and determining the purposes of processing personal data, the composition of personal data to be processed, 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://emco-realty.com.
2.9. Personal Data Authorized by the Subject for Dissemination – personal data to which access by an unlimited number of persons has been granted by the subject of personal data by consenting to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as "Personal Data Authorized for Dissemination").
2.10. User – any visitor to the website https://emco-realty.com.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Dissemination of Personal Data – actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publishing personal data in mass 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 foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
– Receive accurate information and/or documents containing personal data from the subject of personal data;
– Continue processing personal data without the subject’s consent if grounds specified in the Personal Data Law exist, in case the subject withdraws consent or submits a request to cease processing;
– Independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
– Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
– Organize the processing of personal data in accordance with current Russian legislation;
– Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the Personal Data Law;
– Provide the authorized body for the protection of personal data subjects’ rights with necessary information within 10 days of receiving a request;
– Publish or otherwise ensure unrestricted access to this Policy on personal data processing;
– Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, or other unlawful actions;
– Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in cases and manner prescribed by the Personal Data Law;
– Fulfill other obligations stipulated by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
– Obtain information regarding the processing of their personal data, except in cases provided by federal laws. The Operator provides this information in an accessible form, excluding personal data of other subjects unless legally justified. The procedure for obtaining information is established by the Personal Data Law;
– Require the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated processing purpose, and take legal measures to protect their rights;
– Impose a condition of prior consent when personal data is processed for market promotion of goods, works, or services;
– Withdraw consent to the processing of personal data and submit a demand to cease processing;
– Appeal to the authorized body for the protection of personal data subjects’ rights or in court against unlawful actions or inaction of the Operator in processing their personal data;
– Exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
– Provide the Operator with accurate information about themselves;
– Notify the Operator of updates or changes to their personal data.
4.3. Persons who provide the Operator with false information about themselves or about another personal data subject without the latter’s consent bear responsibility under Russian law.
5. Principles of Personal Data Processing
5.1. Personal data processing is conducted on a lawful and fair basis.
5.2. Processing is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of data collection is prohibited.
5.3. Merging databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data relevant to the processing purposes may be processed.
5.5. The content and volume of processed personal data align with the stated processing purposes. Excessive data relative to the stated purposes is not permitted.
5.6. Processing ensures the accuracy, sufficiency, and, where necessary, relevance of personal data relative to the processing purposes. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form allowing identification of the data subject for no longer than required by the processing purposes, unless a storage period is set by federal law or an agreement. Processed data is destroyed or anonymized upon achieving the processing purposes or when no longer necessary, unless otherwise provided by law.
6. Purposes of personal data processing
Purpose of processing Clarifying order details |
Personal data |
- Last name, first name, patronymic
- Email address
- Phone numbers
Legal grounds |
- Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ of July 27, 2006
Types of personal data processing |
- Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the objectives outlined in an international treaty of the Russian Federation or law, and to perform the functions, powers, and duties imposed on the Operator by Russian legislation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or an act of another authority or official subject to enforcement under Russian legislation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract where the personal data subject is a party, beneficiary, or guarantor, or for concluding a contract initiated by the personal data subject or under which the subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out on personal data made publicly available by the personal data subject or at their request (hereinafter referred to as "publicly available personal data").
7.7. Processing is carried out on personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with current legislation on personal data protection.
8.1. The Operator ensures the integrity of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases required by law or when the personal data subject has consented to the transfer to fulfill obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by notifying the Operator via email at Emco-real-estate@yandex.ru with the subject line "Personal Data Update."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the data was collected, unless otherwise specified by contract or law.
The User may withdraw consent to personal data processing at any time by notifying the Operator via email at Emco-real-estate@yandex.ru with the subject line "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 these parties (Operators) in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties, including the service providers mentioned herein.
8.6. Prohibitions established by the personal data subject on the transfer (except for providing access) or processing of personal data permitted for dissemination do not apply in cases of processing carried out in state, public, or other public interests as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the data subject for no longer than necessary to achieve the processing purposes, unless a storage period is set by federal law or contract.
8.9. Processing of personal data may be terminated upon achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the data subject, a request to cease processing, or if unlawful processing is identified.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator conducts automated processing of personal data with or without the transmission of received information via telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before engaging in cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intent to conduct such transfers (this notification is separate from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the personal data will be transferred.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarification on questions regarding the processing of their personal data by contacting the Operator via email at Emco-real-estate@yandex.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://emco-realty.com/polici.