Terms of Service and Privacy Policy

Privacy Policy

The Personal Data Processing Policy (hereinafter referred to as the Policy) is developed in accordance with Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as Law No. 152).

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data at APEX Ltd (hereinafter referred to as the Operator) in order to protect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.

This Policy also applies to all information located on the domain name www.p-bpm.online (hereinafter referred to as the Site), which may be obtained about the User during the use of the site, programs, and products of the Operator.

The following key concepts are used in the Policy:

Personal data - any information relating directly or indirectly to a identified or identifiable individual (personal data subject);
Operator - a state body, municipal body, legal entity, or individual acting alone 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 subject to processing, actions (operations) performed with personal data;
Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
Automated processing of personal data - processing of personal data using computer technology;
Dissemination of personal data - actions aimed at disclosing personal data to an indefinite number of persons;
Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons;
Blocking of personal data - temporary cessation of processing of personal data (except cases when processing is necessary to clarify personal data);
Destruction of personal data - actions resulting in the impossibility of restoring the content of personal data in the personal data information system and (or) actions resulting in the destruction of material carriers of personal data;
Depersonalization of personal data - actions resulting in the impossibility, without the use of additional information, to determine the belonging of personal data to a specific subject of personal data;
Personal data information system - a set of personal data contained in databases and providing their processing with information technology and technical means;
Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual, or a foreign legal entity;
User - a person who has access to the Site through the Internet and uses the Site.
The company is obliged to publish or otherwise ensure unrestricted access to this Personal Data Processing Policy in accordance with part 2 of article 18.1 of Law No. 152.

Article 1. GENERAL PROVISIONS

The use of the Site by the User implies agreement with this Privacy Policy and the terms of processing personal data of the User.
In case of disagreement with the terms of the Privacy Policy, the User must stop using the Site.
This Privacy Policy applies only to the Site. The Operator does not control and is not responsible for third-party sites that the User may visit through links available on the Site.
Personal data allowed for processing under this Privacy Policy is provided by the User by filling out the registration form on the Site and includes the following information:
User's last name, first name, patronymic;
User's contact phone number;
User's email address (e-mail);
Article 2. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL INFORMATION OF USERS

The Site collects and stores only those personal data that are necessary for the provision and provision of services (performance of agreements and contracts with the user).
The Site may use personal user information for the following purposes:
2.1. Identification of the party within agreements and contracts with the Site;
2.2. Providing the user with personalized services;
2.3. Communication with the user, including sending notifications, requests, and information related to the use of the Services, provision of services, as well as processing requests and applications from the user;
2.4. Improving the quality and convenience of their use, developing services;
2.5. Targeting advertising materials;
2.6. Conducting statistical and other research based on anonymized data.

Article 3. PRINCIPLES OF PERSONAL DATA PROCESSING

Processing of personal data by the Operator is carried out based on the following principles:
Legality and fairness;
Limitation of the processing of personal data to achieve specific, predetermined, and lawful purposes;
Prevention of processing of personal data incompatible with the purposes of collecting personal data;
Prevention of merging databases containing personal data processed for purposes incompatible with each other;
Processing only those personal data that correspond to the purposes of their processing;
Compliance of the content and volume of processed personal data with the stated purposes of processing;
Prevention of processing of personal data that is excessive in relation to the stated purposes of 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 achieving the purposes of their processing or in case of loss of the need to achieve these purposes, in case of impossibility of eliminating violations of personal data by the Operator, unless otherwise provided by federal law.
Article 4. CONDITIONS FOR PROCESSING PERSONAL DATA

The Operator processes personal data if at least one of the following conditions is met:
1.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data;
1.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to exercise and fulfill the functions, powers, and duties imposed by legislation of the Russian Federation on the operator;
1.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
1.4. Processing of personal data is necessary for the performance of a contract, of which the personal data subject is a party, beneficiary, or guarantor, or for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
1.5. Processing of personal data is necessary to protect the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;
1.6. Processing of personal data is carried out, unlimited access to which is provided by the personal data subject or at his request (hereinafter referred to as publicly available personal data);
1.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

Article 5. METHODS AND TERMS OF PROCESSING OF PERSONAL INFORMATION

Processing and storage of User's personal data are carried out without time limitations, in any lawful manner, including in personal data information systems using automation tools or without using such tools.
Personal data of the User may be transferred to authorized state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.

Article 6. CONFIDENTIALITY OF PERSONAL DATA

The Operator and other persons who have access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
The Operator takes necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other unlawful actions of third parties.

Article 7. PUBLIC SOURCES OF PERSONAL DATA

For the purpose of information provision, the Operator may create public sources of personal data of subjects, including directories and address books. With the written consent of the personal data subject, public sources of personal data may include his/her surname, first name, patronymic, date and place of birth, position, contact phone numbers, email address, and other personal data provided by the personal data subject.
Information about the subject must be excluded from public sources of personal data at any time upon the request of the subject or by court decision or other authorized state authorities.

Article 8. SPECIAL CATEGORIES OF PERSONAL DATA

The Operator processes special categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, state of health, intimate life, only in cases where:
1.1. The personal data subject has given written consent to the processing of his/her personal data;
1.2. Personal data has been made publicly available by the personal data subject;
1.3. Processing of personal data is carried out in accordance with the legislation on social assistance, labor legislation, legislation of the Russian Federation on pensions under state pension provision, on labor pensions;
1.4. Processing of personal data is necessary to protect the life, health, or other vital interests of the personal data subject or the life, health, or other vital interests of other persons, and obtaining consent of the personal data subject is impossible;
1.5. Processing of personal data is carried out for medical and preventive purposes, for the purpose of establishing a medical diagnosis, providing medical and medical-social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities and obliged in accordance with the legislation of the Russian Federation to maintain medical confidentiality;
1.6. Processing of personal data is necessary to establish or exercise the rights of the personal data subject or third parties, as well as in connection with the administration of justice;
Processing of special categories of personal data must be immediately terminated if the reasons for their processing have been eliminated, unless otherwise provided by federal law.
Processing of personal data on criminal records may be carried out by the Operator only in cases and in the manner determined in accordance with federal laws.

Article 9. BIOMETRIC PERSONAL DATA

Information characterizing the physiological and biological characteristics of a person, on the basis of which his/her identity can be established - biometric personal data - may be processed by the Operator only with the written consent of the subject.

Article 10. TRANSFER OF PERSONAL INFORMATION TO THIRD PARTIES

The Site has the right to transfer the user's personal information to third parties in the following cases:
1.1. The user has expressed consent to such actions;
1.2. Transfer is necessary within the framework of the user's use of a specific Service or for the provision of a service to the user;
1.3. The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by legislation;
1.4. Such transfer occurs within the framework of the sale or other transfer of the business (in whole or in part), in which case all obligations to comply with the terms of this Policy with respect to the personal information received by it are transferred to the acquirer;
1.5. To protect the rights and legitimate interests of the Site or third parties in cases where the user violates the Terms of Use of the Site's services.
When processing personal data of users, the Site is guided by the Federal Law of the Russian Federation "On Personal Data".Статья

Article 11. CROSS-BORDER TRANSFER OF PERSONAL DATA

The operator must ensure that the foreign state to which the transfer of personal data is intended provides adequate protection of the rights of the subjects of personal data before commencing such transfer.

Cross-border transfer of personal data to the territory of foreign states that do not ensure adequate protection of the rights of the subjects of personal data may be carried out in the following cases:
2.1. upon the written consent of the subject of personal data to the cross-border transfer of their personal data;
2.2. in the performance of a contract where the subject of personal data is a party.

Article 12. CONSENT OF THE SUBJECT OF PERSONAL DATA TO THE PROCESSING OF THEIR PERSONAL DATA

The subject of personal data makes a decision to provide their personal data and gives consent to their processing freely, by their own will, and in their own interest. Consent to the processing of personal data may be given by the subject of personal data or their representative in any form that allows confirming the fact of its receipt, unless otherwise provided by federal law.
The obligation to provide evidence of obtaining the consent of the subject of personal data to the processing of their personal data or evidence of the grounds specified in Federal Law No. 152 is imposed on the Operator.

Article 13. RIGHTS OF THE SUBJECT OF PERSONAL DATA

The subject of personal data has the right to obtain from the Operator information concerning the processing of their personal data, unless such right is restricted in accordance with federal laws. The subject of personal data has the right to demand from the Operator the clarification of their personal data, their blocking, or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, by submitting a written request to the Operator, including through electronic means of communication at the addresses specified on the Operator's Website, and to take measures provided by law to protect their rights.
Processing of personal data for the purpose of promoting goods, works, services on the market by means of direct contacts with the potential consumer using means of communication, as well as for political campaigning, is allowed only with the prior consent of the subject of personal data. Such processing of personal data is considered to be carried out without the prior consent of the subject of personal data if the Company fails to prove that such consent was obtained.
The Operator is obliged to immediately stop, at the request of the subject of personal data, the processing of their personal data for the purposes mentioned above.
Making decisions based solely on automated processing of personal data that produce legal consequences for the subject of personal data or similarly affect their rights and legitimate interests is prohibited, except in cases provided for by federal laws or with the written consent of the subject of personal data.
If the subject of personal data believes that the Operator is processing their personal data in violation of the requirements of Federal Law No. 152 or in any other way violates their rights and freedoms, the subject of personal data has the right to appeal the actions or inaction of the Operator to the Authorized Body for the Protection of the Rights of Subjects of Personal Data or in court.

Article 14. OBLIGATIONS OF THE PARTIES

The User shall:
1.1. Provide information about personal data necessary for using the Website.
1.2. Update, supplement the provided information about personal data in case of changes to this information.

The Operator shall:
2.1. Use the received information exclusively for the purposes specified in this Privacy Policy.
2.2. Ensure the confidentiality of information, not to disclose it without the prior written permission of the User, as well as not to sell, exchange, publish, or otherwise disclose the transferred personal data of the User, except as specified in Article 10 of this Privacy Policy.
2.3. Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure commonly used to protect such information in existing business practices.
2.4. Block personal data related to the respective User from the moment of the User's request or inquiry, or the request of the User's legal representative or authorized body for the protection of the rights of personal data subjects, for the period of verification, in case of identification of inaccurate personal data or unlawful actions.

Article 15. LIABILITY OF THE PARTIES

In case of loss or disclosure of Confidential Information, the Operator shall not be liable if such confidential information:
1.1. Became public domain before its loss or disclosure.
1.2. Was received from a third party before being received by the Site Administration.
1.3. Was disclosed with the User's consent.

Article 16. DISPUTE RESOLUTION

Before filing a lawsuit with claims arising from the relationship between the Website User and the Operator, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute).
The recipient of the claim shall, within 30 calendar days from the date of receipt of the claim, notify the claimant in writing of the results of the claim consideration.
In case of failure to reach an agreement, the dispute shall be referred to a court in accordance with the current legislation of the Russian Federation.
This Privacy Policy and the relationship between the User and the Operator are governed by the current legislation of the Russian Federation.
Article 17. ADDITIONAL TERMS

The Operator has the right to make changes to this Privacy Policy without the User's consent.
The new Privacy Policy comes into force from the moment of its publication on the Website, unless otherwise provided by the new version of the Privacy Policy.
The current Privacy Policy is posted on the page at cp-bpm.online.
Operator's location: Moscow, Presnenskaya nab. 10.