Personal Data Processing Policy
1. General ProvisionsThis Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by SailWiki (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1.The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy and personal and family secrets, to be its most important goal and condition for carrying out its activities.
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://promo.sailwiki.com.
2. Basic 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 suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3.Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://promo.sailwiki.com.
2.4.Personal data information system — a set of personal data contained in databases and the information technologies and technical means used for their processing.
2.5.Depersonalization of personal data — actions resulting in the impossibility of determining, without the use of additional information, whether personal data belongs to a specific User or other personal data subject.
2.6.Processing of personal data — any action (operation) or set of actions (operations) 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, and destruction of personal data.
2.7.Operator — a state authority, municipal authority, 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 personal data processing, the composition of personal data to be processed, and the actions performed with personal data.
2.8.Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://promo.sailwiki.com.
2.9.Personal data permitted for distribution by the personal data subject — personal data to which access is granted to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for distribution in accordance with the Personal Data Law.
2.10.User — any visitor to the website https://promo.sailwiki.com.
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 group of persons (transfer of personal data) or making personal data accessible to an unlimited number of persons, including publication in mass media, posting in information and telecommunication networks, or providing access 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 governmental authority, foreign individual, or foreign legal entity.
2.14.Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of restoring the content of personal data in a personal data information system and/or destruction of physical media containing personal data.
  • 3. Basic 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;
  • continue processing personal data without the consent of the personal data subject in cases предусмотренных by the Personal Data Law if the subject withdraws consent or requests termination of processing;
  • independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations established by the Personal Data Law and related regulations, unless otherwise provided by law.
  • 3.2. The Operator is obliged to:provide the personal data subject, upon request, with information regarding the processing of their personal data;
  • organize personal data processing in accordance with the current legislation of the Russian Federation;
  • respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • provide the authorized body for the protection of personal data subjects’ rights with necessary information within 10 days from the receipt of such request;
  • publish or otherwise ensure unrestricted access to this Policy;
  • take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
  • terminate transfer, processing, and destroy personal data in cases provided by the Personal Data Law;
  • fulfill other obligations stipulated by the Personal Data Law.
  • 4. Basic Rights and Obligations of Personal Data Subjects 4.1. Personal data subjects have the right to:receive information regarding the processing of their personal data, except in cases provided by federal laws;
  • require clarification, blocking, or destruction of their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing;
  • require prior consent for processing personal data for the promotion of goods, works, and services;
  • withdraw consent to the processing of personal data and request termination of processing;
  • appeal unlawful actions or omissions of the Operator to the authorized body or in court;
  • exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:provide the Operator with accurate information about themselves;
  • notify the Operator of any updates or changes to their personal data.
4.3.Persons who provide false information about themselves or another personal data subject without consent shall bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing 5.1.Personal data shall be processed lawfully and fairly.
5.2.Processing shall be limited to achieving specific, predetermined, and lawful purposes.
5.3.Combining databases containing personal data processed for incompatible purposes is prohibited.
5.4.Only personal data relevant to processing purposes shall be processed.
5.5.The content and scope of processed personal data must correspond to the declared processing purposes.
5.6.The Operator shall ensure the accuracy, sufficiency, and relevance of personal data and take measures to delete or clarify incomplete or inaccurate data.
5.7.Personal data shall be stored in a form allowing identification of the personal data subject no longer than required by processing purposes unless otherwise provided by federal law or contract.
6. Purposes of Personal Data Processing Purpose of processingProviding the User with access to services, information, and/or materials available on the website.
  • Personal data processedsurname, first name, patronymic;
  • email address;
  • phone numbers.
Legal basisContracts concluded between the Operator and the personal data subject.
  • Types of personal data processingcollection;
  • recording;
  • systematization;
  • accumulation;
  • storage;
  • destruction;
  • depersonalization of personal data;
  • sending informational emails to the email address.
7. Conditions for Personal Data Processing 7.1.Personal data processing is carried out with the consent of the personal data subject.
7.2.Processing is necessary for achieving purposes provided by international treaties or laws of the Russian Federation.
7.3.Processing is necessary for the administration of justice or execution of judicial acts.
7.4.Processing is necessary for the performance of a contract involving the personal data subject.
7.5.Processing is necessary for exercising the legitimate rights and interests of the Operator or third parties.
7.6.Processing of publicly available personal data is carried out.
7.7.Processing of personal data subject to publication or mandatory disclosure under federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary for full compliance with applicable legislation.
8.1.The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2.The User’s personal data will never be transferred to third parties except in cases required by law or with the consent of the personal data subject.
8.3.If inaccuracies in personal data are identified, the User may update them by sending a notification to info@sailwiki.com marked “Personal Data Update”.
8.4.The period of personal data processing is determined by the achievement of processing purposes unless otherwise provided by law or contract.
The User may withdraw consent at any time by sending a notification to info@sailwiki.com marked “Withdrawal of Consent to Personal Data Processing”.
8.5.All information collected by third-party services, including payment systems and communication providers, is stored and processed by those parties in accordance with their User Agreements and Privacy Policies.
8.6.Restrictions established by the personal data subject regarding transfer or processing of personal data permitted for distribution do not apply in cases involving public interests established by Russian law.
8.7.The Operator ensures confidentiality of personal data during processing.
8.8.Personal data is stored no longer than required for processing purposes unless otherwise established by federal law or contract.
8.9.Conditions for termination of personal data processing may include:
  • achievement of processing purposes;
  • expiration of consent validity;
  • withdrawal of consent by the subject;
  • request to terminate processing;
  • identification of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data 9.1.The Operator performs:
  • collection;
  • recording;
  • systematization;
  • accumulation;
  • storage;
  • clarification (updating, modification);
  • extraction;
  • use;
  • transfer;
  • depersonalization;
  • blocking;
  • deletion;
  • destruction of personal data.
9.2.The Operator performs automated processing of personal data with or without transfer via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data 10.1.Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights.
10.2.Before submitting such notification, the Operator must obtain relevant information from foreign authorities, foreign individuals, or foreign legal entities to whom the transfer is planned.
11. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions 12.1.The User may obtain any clarifications regarding the processing of personal data by contacting the Operator at info@sailwiki.com.
12.2.Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains effective indefinitely until replaced by a new version.
12.3.The current version of the Policy is freely available on the Internet at:
https://promo.sailwiki.com/policy
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