Policy regarding the processing of personal data
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ "On Personal Data" and determines the procedure for processing personal data and measures to ensure the security of personal data "Palma Luxury Club" by Palma Corp.. (hereinafter referred to as the Operator).
The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the https://palmaluxury.club website.
2. Basic concepts used in the Policy
Automated processing of personal data - processing of personal data using computer technology;
Blocking of personal data - temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data);
Website - a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://palmaluxury.club;
Information system of personal data - a set of personal data contained in databases, and information technologies and technical means that ensure their processing;
Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data;
Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation 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;
Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons 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, the actions (operations) performed with personal data;
Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://palmaluxury.club;
User - any visitor to the website https://palmaluxury.club;
Providing personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;
Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way;
Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity;
Destruction of personal data - any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.
3. The Operator may process the following personal data of the User
Full Name;
Email address;
Phone numbers;
User ID on the Palma Luxury Club platform (if the User is a client of the platform);
The site also collects and processes anonymous data about visitors (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics and others).
The above data further in the text of the Policy are united by the general concept of Personal data.
4. Purposes of personal data processing
The purpose of processing the User's personal data is to inform the User by sending emails; providing the User with access to the services, information and / or materials contained on the website.
The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator at info@palmaluxury.club with the note "Refusal of notifications about new products and services and special offers".
Anonymized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.
5. Legal grounds for the processing of personal data
The Operator processes the User's personal data only if they are filled in and / or sent by the User independently through special forms located on the site https://palmaluxury.club. By filling out the relevant forms and / or sending their personal data to the Operator, the User expresses his consent to this Policy.
The Operator processes anonymized data about the User if it is allowed in the User's browser settings (saving cookies and using JavaScript technology is enabled).
6. The procedure for collecting, storing, transferring and other types of processing of personal data
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 the current legislation in the field of personal data protection.
The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law.
In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s e-mail address info@palmaluxury.club marked “Updating personal data”.
The term for processing personal data is unlimited. The User may at any time withdraw his consent to the processing of personal data by sending the Operator a notification by e-mail to the Operator's email address info@palmaluxury.club marked "Withdrawal of consent to the processing of personal data".
7. Cross-border transfer of personal data
Before the start of the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is supposed to be carried out provides reliable protection of the rights of subjects of personal data.
Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of his personal data and / or execution of an agreement to which the subject of personal data is a party.
8. Final provisions
The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail info@palmaluxury.club.
This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced by a new version.
The current version of the Policy is freely available on the Internet at http://palmaluxury.club/police.
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ "On Personal Data" and determines the procedure for processing personal data and measures to ensure the security of personal data "Palma Luxury Club" by Palma Corp.. (hereinafter referred to as the Operator).
The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the https://palmaluxury.club website.
2. Basic concepts used in the Policy
Automated processing of personal data - processing of personal data using computer technology;
Blocking of personal data - temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data);
Website - a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://palmaluxury.club;
Information system of personal data - a set of personal data contained in databases, and information technologies and technical means that ensure their processing;
Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data;
Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation 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;
Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons 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, the actions (operations) performed with personal data;
Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://palmaluxury.club;
User - any visitor to the website https://palmaluxury.club;
Providing personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;
Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way;
Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity;
Destruction of personal data - any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.
3. The Operator may process the following personal data of the User
Full Name;
Email address;
Phone numbers;
User ID on the Palma Luxury Club platform (if the User is a client of the platform);
The site also collects and processes anonymous data about visitors (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics and others).
The above data further in the text of the Policy are united by the general concept of Personal data.
4. Purposes of personal data processing
The purpose of processing the User's personal data is to inform the User by sending emails; providing the User with access to the services, information and / or materials contained on the website.
The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator at info@palmaluxury.club with the note "Refusal of notifications about new products and services and special offers".
Anonymized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.
5. Legal grounds for the processing of personal data
The Operator processes the User's personal data only if they are filled in and / or sent by the User independently through special forms located on the site https://palmaluxury.club. By filling out the relevant forms and / or sending their personal data to the Operator, the User expresses his consent to this Policy.
The Operator processes anonymized data about the User if it is allowed in the User's browser settings (saving cookies and using JavaScript technology is enabled).
6. The procedure for collecting, storing, transferring and other types of processing of personal data
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 the current legislation in the field of personal data protection.
The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law.
In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s e-mail address info@palmaluxury.club marked “Updating personal data”.
The term for processing personal data is unlimited. The User may at any time withdraw his consent to the processing of personal data by sending the Operator a notification by e-mail to the Operator's email address info@palmaluxury.club marked "Withdrawal of consent to the processing of personal data".
7. Cross-border transfer of personal data
Before the start of the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is supposed to be carried out provides reliable protection of the rights of subjects of personal data.
Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of his personal data and / or execution of an agreement to which the subject of personal data is a party.
8. Final provisions
The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail info@palmaluxury.club.
This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced by a new version.
The current version of the Policy is freely available on the Internet at http://palmaluxury.club/police.
PRIVACY POLICY
Policy regarding the processing and protection of personal data.
2. CONCEPT AND COMPOSITION OF PERSONAL DATA
3. PURPOSES OF PERSONAL DATA PROCESSING
3. The processing of personal data is carried out on the basis of the conditions determined by the legislation of the Russian Federation. The site processes personal data using automation tools, including using information technologies and technical means, including computer technology, information technology complexes and networks, means and systems for transmitting, receiving and processing personal data, software (operating systems, database management systems, etc.), information security tools used in information systems, as well as without the use of automation tools.
4 . When processing personal data, the Site will strive to ensure the accuracy of personal data, their sufficiency and, if necessary, relevance in relation to the purposes of processing personal data. The site seeks to ensure that the necessary measures are taken to remove or clarify incomplete or inaccurate personal data.
5. The site does not post the personal data of the personal data subject in publicly available sources without his prior consent.
6. By registering on the Site's Site or using the Site's site for personal or any other use, the User voluntarily and without any exceptions and restrictions, and also automatically agrees with this Policy and with each of its terms. In case of disagreement with the terms of the Policy, the User must refrain from using the Site.
7. By agreeing to the terms of the Policy, the User expresses his written consent to the processing of any personal data of the User by the Site and (or) service providers provided through the Site for an indefinite period, including the user agrees to the processing of any personal data in accordance with Article 10 and Article 12 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data".
8. The User's consent is terminated on the basis of a written application, which is signed by the User and sent by registered mail with a receipt notification to the "Palma Luxury Club" by Palma Corp. at its location. follow the links available on the Site Site. The site is not responsible if the User voluntarily disclosed his personal data to third parties.
2. RIGHTS AND OBLIGATIONS
2. Rights and obligations of the personal data subject
3. ENSURING THE SECURITY OF PERSONAL DATA
4. FINAL PROVISIONS
2. This Policy is subject to change, addition in case of amendments to the current legislative acts and the emergence of new legislative acts, and special regulatory documents on the processing and protection of personal data.
3. This Policy can be changed without prior notice or consent of the User. The new version of the Policy comes into force from the moment it is posted, unless otherwise provided by the new version of the Policy.
4. Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for ensuring the security of the personal data of the Site.
5. The responsibility of the Site officials who have gained access to personal data for non-compliance with the requirements of the rules for processing and protecting personal data is determined in accordance with the legislation and internal documents of the Site.
Policy regarding the processing and protection of personal data.
- INTRODUCTION
- The most important condition for the implementation of the goals of the activities of "Palma Luxury Club" by Palma Corp., hereinafter referred to as the Site, is to provide the necessary and a sufficient level of information security, including with respect to the processing of personal data.
- Ensuring the security of personal data is one of the priority tasks of the Site.
- This Policy (hereinafter also the Policy) has been developed in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" and defines the principles, procedure and conditions for the processing of personal data of various categories of subjects whose personal data is processed by the Site, with the purpose of ensuring the protection of human and civil rights and freedoms when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
- Personal data is protected information and all requirements established by law and internal documents of the Site apply to them.
2. CONCEPT AND COMPOSITION OF PERSONAL DATA
- The list of processed personal data subject to protection at the Site is formed in accordance with the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data", the Charter and internal regulations of the Site
- Information constituting personal data in the Site is any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).
- Depending on the subject of personal data, the Site processes personal data of the following categories of subjects of personal data:
- individuals who voluntarily provided their personal data in connection with the registration of the Questionnaire for registration on the Site's website https://palmaluxury.club., as well as individuals who have entered into any agreement with the Site;
- individuals who applied to the Site for employment purposes and provided their personal data, and Site employees;
- individuals who are affiliates of the Site or managers, participants (shareholders) or employees of a legal entity that is affiliated with the Site;
- individuals who have applied to the Sites with a request of any nature, and have provided their personal data in this regard.
3. PURPOSES OF PERSONAL DATA PROCESSING
- The site processes personal data for the following purposes:
- compliance with this Policy and the requirements of the legislation of the Russian Federation;
- communication with the User by sending notifications, requests and information regarding the use of the Site of the Site, the provision of services provided by the Site of the Site, as well as processing requests and applications from Users, sending messages by e-mail, as well as via SMS / MMS, via messengers (What's Up, Viber, Telegram, Skype, WeChat and so on), social networks about any events related to the provision of services as part of the use of the Site Site;
- improving the quality of the Site Site, its usability, development and testing of new services, conducting surveys related to the Site Site operation and user experience;
- promotion on the market, including by making direct contacts with Users using any means of communication, including electronic means of communication, mail, SMS messages, joint products and services of the Site and third parties in whose interests the Site operates, targeting advertising materials, conducting statistical and other studies based on anonymized data;
- assistance to the employees of the Site in employment, training and promotion, ensuring the personal safety of employees, monitoring the quantity and quality of work performed and ensuring the safety of the property of the employee and the Site as an employer;
- implementation of the functions assigned to the Site by law in accordance with the Civil Code, Labor Code, Tax Code, Federal Law "On Personal Data".
- customer identification;
- informing about advertising and (or) marketing campaigns, surveys, questionnaires, marketing research in relation to the services provided by the Site, conducted by the Company and (or) third parties in whose interests the Site operates.
- PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING
- The main task of ensuring the security of personal data during their processing at the Sites is to prevent unauthorized access to them by third parties, to prevent intentional software, hardware and other influences in order to steal personal data, destroy (destroy) or distort them during processing.
- the legality and fairness of the purposes and methods of processing personal data;
- compliance of the purposes of processing personal data with the goals predetermined and declared in the collection of personal data, as well as the powers of the Site;
- correspondence of the volume and nature of the processed personal data, methods of processing personal data to the purposes of processing personal data;
- the reliability of personal data, their sufficiency for the purposes of processing, the inadmissibility of processing personal data that are redundant in relation to the purposes stated when collecting personal data;
- storing personal data in a form that allows you to determine the subject of personal data for no longer than the purpose of processing personal data requires, if the storage period for personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor;
- destruction upon achievement of the goals of personal data processing or in case of loss of the need to achieve them, unless otherwise provided by federal law.
3. The processing of personal data is carried out on the basis of the conditions determined by the legislation of the Russian Federation. The site processes personal data using automation tools, including using information technologies and technical means, including computer technology, information technology complexes and networks, means and systems for transmitting, receiving and processing personal data, software (operating systems, database management systems, etc.), information security tools used in information systems, as well as without the use of automation tools.
4 . When processing personal data, the Site will strive to ensure the accuracy of personal data, their sufficiency and, if necessary, relevance in relation to the purposes of processing personal data. The site seeks to ensure that the necessary measures are taken to remove or clarify incomplete or inaccurate personal data.
5. The site does not post the personal data of the personal data subject in publicly available sources without his prior consent.
6. By registering on the Site's Site or using the Site's site for personal or any other use, the User voluntarily and without any exceptions and restrictions, and also automatically agrees with this Policy and with each of its terms. In case of disagreement with the terms of the Policy, the User must refrain from using the Site.
7. By agreeing to the terms of the Policy, the User expresses his written consent to the processing of any personal data of the User by the Site and (or) service providers provided through the Site for an indefinite period, including the user agrees to the processing of any personal data in accordance with Article 10 and Article 12 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data".
8. The User's consent is terminated on the basis of a written application, which is signed by the User and sent by registered mail with a receipt notification to the "Palma Luxury Club" by Palma Corp. at its location. follow the links available on the Site Site. The site is not responsible if the User voluntarily disclosed his personal data to third parties.
2. RIGHTS AND OBLIGATIONS
- Rights and obligations of the Site
- The site, as an operator of personal data, has the right to:
- defend their interests in court;
- provide personal data of subjects to state and other authorized bodies, if this is provided for by the current legislation of the Russian Federation (tax, law enforcement agencies, etc.);
- refuse to provide personal data in cases provided for by law.
- process personal data of the subject without his consent in cases provided for by law.
2. Rights and obligations of the personal data subject
- The personal data subject has the right:
- in writing to demand clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights. The corresponding notification about the clarification, blocking or destruction of their personal data is sent by the subject of personal data to the legal address of the Site by a valuable letter with a receipt confirmation;
- in writing, demand a list of your personal data processed by the Company and the source of their receipt by submitting a corresponding request to the legal address of the Site with a valuable letter with acknowledgment of receipt;
- to receive information in writing about the timing of the processing of their personal data, including the timing of their storage;
- to appeal in writing to the authorized body for the protection of the rights of subjects of personal data or in a judicial proceeding against unlawful actions or omissions in the processing of his personal data;
- to protect their rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.
3. ENSURING THE SECURITY OF PERSONAL DATA
- The site takes the necessary organizational and technical measures to ensure the security of personal data from accidental or unauthorized access, destruction, alteration, blocking of access and other unauthorized actions.
- a person responsible for organizing and ensuring the security of personal data processing is appointed;
- internal control and (or) audit of the compliance of the processing of personal data with the legislation and internal documents of the Site;
- an assessment is made of the harm that may be caused to the subjects of personal data in the event of a violation of the legislation on personal data, the ratio of this harm and the measures taken by the Company aimed at ensuring its obligations under the law.
4. FINAL PROVISIONS
- This Policy is publicly available and must be posted on the official website of the Platform on the Internet https://palmaluxury.club.
2. This Policy is subject to change, addition in case of amendments to the current legislative acts and the emergence of new legislative acts, and special regulatory documents on the processing and protection of personal data.
3. This Policy can be changed without prior notice or consent of the User. The new version of the Policy comes into force from the moment it is posted, unless otherwise provided by the new version of the Policy.
4. Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for ensuring the security of the personal data of the Site.
5. The responsibility of the Site officials who have gained access to personal data for non-compliance with the requirements of the rules for processing and protecting personal data is determined in accordance with the legislation and internal documents of the Site.
