1. General provisions
This Personal Data Processing Policy has been developed in accordance with the Federal Law No. 152-FZ dated July 27, 2006, “on Personal Data” (hereinafter - the Law “on Personal Data”) and defines the principles of personal data processing, as well as the measures, implemented by LLC “Seamarko” (hereinafter - the Operator) in order to provide safety of personal data.

1.1. The Operator sees respect for human rights and fundamental freedoms as a priority and as a ground for all its activities.

1.2. This Personal Data Processing Policy (hereinafter - the Policy) is applied to all information that the Operator can obtain about the visitors of the website https://seamarko.ru

2. Basic terms used in the Policy

2.1. Automated personal data processing means the processing of personal data with the use of computers.
2.2. Blocking of personal data means a temporary interruption of personal data processing (except where processing is required for the clarification of personal data).
2.3. The website - a set of graphic and information materials, as well as software and databases that ensure their availability on the Internet at https://seamarko.ru.
2.4. Personal data information system means a set of personal data contained in personal data databases, as well as information technologies and tools used for their processing.
2.5. Personal data processing means any action (operation) or a series of actions (operations) with personal data performed with or without automation tools, including collecting, recording, systematization, accumulation, storage, clarification (updating, making changes), extraction, usage, transfer (spreading, providing, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator means a government authority, a municipal authority, a legal or private person, which severally or jointly arrange and/or perform the processing of personal data, as well as define the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8 Personal data means any information related to a directly or indirectly identified or identifiable user of the website https://seamarko.ru
2.9 Personal data, the spreading of which is permitted by the data subject means personal data that was made available to the general public by the data subject via giving consent to the processing of personal data, the spreading of which is permitted by the data subject in line with the procedure provided by the Law “on Personal Data”.
2.10 The User is any visitor and/or user of the website https://seamarko.ru
2.11 Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12 Spreading personal data means any actions, directed at disclosing personal data to any group of persons, including publication of personal data in mass media, posting personal data in information and telecommunication networks, or providing access to personal data in any other way.
2.13 Trans-border transfer of personal data means a transfer of personal data to a foreign country, specifically to a foreign government body or a foreign natural or legal person.
2.14 Destruction of personal data means actions making it impossible to restore the content of personal data in the personal data information system and/or resulting in the destruction of physical media on which personal data are stored.

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 subject of personal data
— in case the personal data subject withdraws consent to the processing of personal data, as well as sending a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law “on Personal Data”;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law “on Personal Data” and regulatory legal acts issued in accordance with it, unless otherwise provided by the Law “on Personal Data” or other federal laws.
3.2. The Operator is obliged to:
— to provide the subject of personal data, at his request, with information concerning the processing of his personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law “on Personal Data” ;
— to inform the competent authority for the protection of the rights of personal data subjects at the request of this body of the necessary information within 10 days from the date of receiving such a 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 to them, destruction, modification, blocking, copying, provision, spreading of personal data, as well as from other illegal actions with respect to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop 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. Basic rights and obligations of personal data subjects.

4.1 Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosure of 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 it if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
— revoke their consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. The subjects of personal data are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about the clarification (update, change) of their personal data.
4.3 Persons who have provided the Operator with false information about themselves or information about another personal data subject without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing
5.1 The processing of personal data is carried out on a legal and fair basis.
5.2 Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Personal data processing is not allowed if such processing is incompatible with the purposes of personal data collection.
5.3 Combining databases containing personal data which are processed for incompatible purposes is not allowed.
5.4 Personal data are not subject to processing unless they meet the purposes of their processing.
5.5 The scope and amount of personal data comply with the stated purposes of processing. Data redundancy in relation to the stated purposes is not allowed
5.6 Personal data undergoing processing must be accurate, sufficient and, if necessary, relevant to the purposes of personal data processing. The Operator takes the required measures or makes efforts to delete or clarify incomplete or inaccurate personal data.
5.7 The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Personal data undergoing processing are destroyed or depersonalized as soon as the purposes of processing are achieved or if the achievement thereof is no longer required, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing: conclusion, execution and termination of commercial contracts.
Personal data:
· surname, name, patronymic
· email address
· phone numbers
Legal grounds
· statutory (founding) documents of the Operator
· Сontracts entered by the Operator and the subject of personal data
Types of personal data processing
· Collecting, recording, systematization, accumulation, storage, deletion and depersonalization of personal data.
· Sending informational letters to an email address.

7. Conditions of personal data processing.
7.1 The processing of personal data is carried out with consent from the data subject to have his/her personal data processed.
7.2 The processing of personal data is necessary to achieve the goals stipulated by an international agreement of the Russian Federation or a law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court ruling, an act of another organization or official subject to execution in accordance with the legislation of the Russian Federation on court enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the personal data subject or an agreement, under which the personal data subject will be the beneficiary or guarantor.
7.5. The 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 the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed, access to which is granted to an unlimited number of persons by the subject of personal data or at his request (hereinafter - the publicly available personal data).
7.7. Processing personal data that is subject to publication or mandatory disclosure in accordance with federal law.

8. The procedure for collecting, storing, transferring and other types of personal data processing

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 exclude unauthorized access to the personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a commercial contract.
8.3. In case of incorrect personal data, the User can update them independently by sending a notification to the Operator's email address office@seamarko.ru with the subject of “Personal data update”
8.4. The period of personal data processing is determined by achieving the purposes for which personal data was collected, unless another period is provided for by the contract or current legislation.
The User can withdraw his/her consent to personal data processing at any time, by sending a notification to the Operator's e-mail address office@seamarko.ru with the subject of "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy, the subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. The prohibition on distributing personal data, established by the subject of personal data (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition to terminate personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the requirement to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of actions performed by the Operator with the received personal data.

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.


10. Cross-border transfer of personal data

10.1. Prior to the start of cross-border transfer of personal data, the Operator is obliged to notify the federal executive body in charge of protection of personal data subjects’ rights of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification concerning the intention to process personal data).
10.2. Before submitting the notification named above, the Operator is obliged to receive relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities for whom the cross-border personal data transfer is planned.

11. Personal data privacy

The operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final provisions

12.1. The User can receive any clarifications on issues of interest concerning the processing of his/her personal data by contacting the Operator via e-mail office@seamarko.ru
12.2. This document will reflect any changes to the Personal Data Processing Policy made by the Operator. The Policy remains in force indefinitely, until it is replaced by a new version.
12.3. The current version of the Policy is available for free at https://seamarko.ru/en/privacy