This Privacy Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by “Second Navigation” LLC (hereinafter — the Operator).
1.1. The Operator’s primary goal and condition for carrying out its activities is to ensure the protection of the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://srcenter.ru/, including data automatically collected during visits (cookies, IP addresses, etc.).
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 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 ensuring their availability on the internet at the network address https://srcenter.ru/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine the ownership of personal data to a specific User or other subject of personal data without additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual, independently or jointly with others organizing and/or carrying out the processing of personal data, as well as 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://srcenter.ru/.
2.9. Personal data permitted for distribution by the subject of personal data — personal data to which an unlimited circle of persons has been granted access by the subject of personal data by giving consent to the processing of personal data permitted for distribution in accordance with the Law on Personal Data (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://srcenter.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. Distribution of personal data — any 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 the 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 — transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions that result in personal data being irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data being destroyed.
2.15. Cookies — small text files placed on the User’s device by the website to collect technical and statistical information, as well as to ensure the correct functioning of the site.
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the subject of personal data;
— in the event the subject of personal data withdraws consent to the processing of personal data or submits a request to cease processing, the Operator has the right to continue processing personal data without consent only in cases expressly provided for in paragraphs 2-11 of Part 1 of Article 6, Part 2 of Article 10 and Part 2 of Article 11 of the Federal Law “On Personal Data”, provided that the relevant basis for processing existed and had not ceased at the time of withdrawal of consent;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
— notify the authorized body for the protection of the rights of subjects of personal data, at the request of this body, of the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted 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, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions with respect to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
— perform other duties provided for by the Law on Personal Data.
4.1. Subjects of personal data have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
— require the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— impose a condition of prior consent when processing personal data for the purpose of marketing goods, works and services;
— withdraw consent to the processing of personal data, as well as submit a request to cease processing of personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or in court against the unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of the clarification (updating, changing) of their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another subject of personal data without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of their processing may be processed.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored 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, unless the storage period for personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achievement of processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
When You fill out a form on the Website to schedule a consultation
| Purpose of processing | Implementation of information interaction and communications — responses to requests and other communications |
| Categories and list of personal data | • e-mail; • phone number; • name; • User identification and settings data obtained using cookies, including IP address, operating system type and version, browser type and version, location data (geolocation), as well as other technical data automatically transmitted by the User’s device when visiting the website; • Other information provided by the User for the purposes specified in this Policy |
| Categories of subjects of personal data | Users who provided data via the feedback form and/or gave consent by checking a box on the website |
| Legal basis for processing personal data | Consent of the subject to the processing of their personal data (clause 1, part 1, article 6 of Federal Law No. 152-FZ), constituent (founding) documents of the Operator |
| Methods of processing | Automated processing |
| Types of processing | Collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer (provision, access), anonymization, blocking, deletion and destruction |
| Processing and storage period, deletion procedure | Until the purpose of processing is achieved, but no more than 3 years or until consent is withdrawn. After achieving processing goals or at your request, we ensure the destruction of your personal data within 30 days (unless a shorter period is provided by law). If you wish to contact us regarding your personal data, please write to info@srcenter.ru |
7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers and duties assigned by the legislation of the Russian Federation to the operator.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, 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 a contract to which the subject of personal data is a party, beneficiary or guarantor, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. Processing of personal data to which an unlimited circle of persons has been granted access by the subject of personal data or at their request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
7.8. Processing period: This consent is valid from the moment it is provided and for 3 (three) years, unless another period is provided by the legislation of the Russian Federation. After this period expires or upon early withdrawal, data processing ceases and data is destroyed, unless there are other legal grounds for their storage.
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with 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 prevent access to personal data by unauthorized persons.
8.2. The User’s personal data is never transferred to third parties, except in cases expressly provided for by this Policy or with the separate consent of the User. The Operator has the right to entrust data processing to the following third parties to ensure the operation of the site and fulfill obligations to the User:
— Web analytics services: YANDEX LLC (OGRN: 1027700229193)
— Feedback module: JIVOSITE LLC (OGRN: 1127746026792).
Data collected by these services is anonymized and used for statistics.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address info@srcenter.ru marked “Updating personal data”.
8.4. Cookie Policy. When visiting the site, anonymized technical data is automatically collected using cookies. This data includes IP address, browser type, time of visit, page transitions. It is used to ensure the operation of the site and improve it, and is not used to identify a specific user without their consent. The User can disable cookies in their browser settings, which may affect the operation of the site.
8.5. Prohibitions on transfer (except for providing access), as well as on processing or conditions of processing (except for gaining access) of personal data permitted for distribution, established by the subject of personal data, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.6. The Operator ensures the confidentiality of personal data when processing personal data.
8.7. The Operator stores personal data 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, unless the storage period for personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.8. The condition for termination of processing of personal data may be the achievement of the purposes of processing personal data, expiration of the consent period of the subject of personal data, withdrawal of consent by the subject of personal data or a request to cease processing of personal data, as well as the detection of unlawful processing of personal data.
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the received information via information and telecommunications networks.
10.1. Before commencing cross-border transfer activities, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its 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 is obliged to obtain relevant information from foreign government authorities, foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is planned.
10.3. None of the processes described in this Policy involve the transfer of personal data to foreign states.
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12.1. The User may obtain any clarification regarding the processing of their personal data by contacting the Operator via email at info@srcenter.ru.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online.