PALMA
PRIVACY POLICY

Policy regarding the processing and protection of personal data.

  1. INTRODUCTION

  1. The most important condition for the implementation of the goals of the activities of "Palma Luxury Club" (JOINT STOCK COMPANY "ACADEMY OF NETWORK INFORMATION TRAINING", 129343, Moscow, Serebryakova proezd, building 2, building 1, room 13 room 5 floor 5), 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.
  2. Ensuring the security of personal data is one of the priority tasks of the Site.
  3. 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.
  4. Personal data is protected information and all the requirements established by the legislation of the Russian Federation and the internal documents of the Site apply to them.

2. CONCEPT AND COMPOSITION OF PERSONAL DATA

  1. 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
  2. Information constituting personal data in the Site is any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).
  3. 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.
4. The site also hereby notifies the User that it uses cookies to improve the quality of the services provided, including but not limited to: to save user settings, improve search results and select products and advertisements, track user-specific trends, such as features search. The Site also uses cookies in advertising services to help advertisers and publishers place advertisements and manage ads on sites across the Internet and on the Site's services. If the user does not agree with the use of cookies by the Site, then the User is obliged to stop using the site and leave it.

3. PURPOSES OF PERSONAL DATA PROCESSING

  1. 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 the legislation of the Russian Federation in accordance with the Civil Code of the Russian Federation, the Labor Code of the Russian Federation, the Tax Code of the Russian Federation, the 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.

  1. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

  1. 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.
2. The processing of personal data of the Site is carried out on the basis of the principles:

  • 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 Academy of Networked Information Training JSC 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

  1. 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 stipulated by the legislation of the Russian Federation;
  • process the personal data of the subject without his consent in the cases provided for by the legislation of the Russian Federation.

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

  1. 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.
2. When processing personal data using automation tools, the Company, in particular, applies the following measures:

  • a person responsible for organizing and ensuring the security of personal data processing is appointed;
  • internal control and (or) audit of the compliance of personal data processing with the legislation of the Russian Federation and internal documents of the Site is carried out;
  • an assessment of the harm that may be caused to the subjects of personal data in case of violation of the legislation of the Russian Federation on personal data is carried out, the ratio of this harm and the measures taken by the Company aimed at ensuring the fulfillment of obligations stipulated by the legislation of the Russian Federation is determined.

4. FINAL PROVISIONS

  1. 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 officials of the Site who have access to personal data for failure to comply with the requirements of the rules governing the processing and protection of personal data is determined in accordance with the legislation of the Russian Federation and the internal documents of the Site.