1. General Provisions
The personal data processing policy (hereinafter referred to as the Policy) was developed in accordance with the Federal Law of July 27, 2006. № 152-ФЗ “On personal data” (hereinafter – ФЗ-152). This Policy defines the procedure for collecting, processing personal data and measures to ensure the security of personal data at Aral LLC (hereinafter referred to as the Club) in order to protect the rights and freedoms of a person and citizen when processing his personal data.
2. Composition of personal data
2.1. Personal data is any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).
2.2. Personal data are confidential and protected information in accordance with the law.
3. Principles and purposes of personal data processing
The processing of personal data in the Club is carried out on the basis of the following principles:
– legality and fair basis;
– preventing the processing of personal data incompatible with the purposes of collecting personal data;
– processing only those personal data that meet the purposes of their processing;
– compliance of the content and volume of processed personal data with the stated processing purposes;
– preventing the processing of personal data that is redundant in relation to the stated purposes of their processing;
– ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
– destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of need
in achieving these goals, if the Club cannot eliminate the violations of personal data, unless otherwise provided by federal law.
4. Purposes of processing personal data
4.1 Personal data is processed for the purpose of registration of labor and civil law relations, accounting, tax accounting in accordance with Federal Law of June 27, 2006 No. 152-FZ, as well as for the purpose of organizing and conducting marketing and / or advertising campaigns and other events; fulfillment of obligations under civil law contracts, incl. through third parties and through the Club website https://adaptationclub.ru (hereinafter referred to as the Site), providing other services to subjects of personal data; promoting the Club’s services on the market by making direct contacts with personal data subjects using various means of communication (by phone, e-mail, mailing lists, social networks on the Internet, etc.); for other purposes, if such actions of the Club do not contradict the current legislation.
4.2 In order to properly fulfill its obligations as a personal data operator, the Club processes the following personal data necessary for the proper fulfillment of contractual obligations:
– personal data of employees who are in labor relations with the Club;
– personal data of other individuals, including, but not limited to, those who are in contractual, student, civil relations with the Club, including, but not limited to, applicants, Guests, participants in the loyalty program and other promotions.
5. Conditions for processing personal data
The club processes personal data in the presence of at least one of the following conditions: – processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
– the processing of personal data is necessary to achieve the goals provided for by the law of the Russian Federation, for the implementation and fulfillment of the functions, powers and duties imposed by the legislation of the Russian Federation on the operator;
– the 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;
– the processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding an agreement initiated by the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor;
– 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;
– processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
6. Collection, processing and use of personal data
ARAL ”takes all necessary technical and organizational measures to protect personal data of subjects from loss, alteration, theft or unauthorized access by third parties.
11. Confidentiality of personal data
A responsible officer has been appointed to develop and implement specific measures to ensure the security of personal data during their processing in the information system of the Club. The club keeps a record of persons who have access to personal data processed in the information system, who need such access to perform their official (labor) duties. The club does not provide personal data to third parties without the consent of the subject of personal data, with the exception of cases provided for by the legislation of the Russian Federation. All persons who have gained access to personal data are obliged 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 federal law.
12. Updates and changes to the Policy and final provisions
The Club reserves the right to update this Policy if necessary without prior notice. Other rights and obligations of the Club as a personal data operator are determined by the legislation of the Russian Federation in the field of personal data. Officials of the Club, guilty of violating the rules governing the processing and protection of personal data, bear material, disciplinary, administrative, civil or criminal responsibility in the manner prescribed by federal laws.
LLC “Aral” INN 7701648628, OGRN 1067746369503
Address: 111024, Moscow, 2nd street Entuziastov, 5.