Personal data processing policy of Media5 Interactive LLC
- Terms and Definitions
- Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
- Operator – Limited Liability Company "Media5 Interactive".
- Personal Data (PD) – any information relating directly or indirectly to an identified or identifiable natural person (personal data subject).
- Personal data subject – a natural person, the holder of personal data, whose personal data has been transferred to the Company for processing.
- Website – the Operator's website on the Internet, located at https://www.media5.com/
- General Provisions
- This Policy describes the principles and approaches of LLC "Media5 Interactive" regarding the processing and security of personal data, the obligations and responsibilities of LLC "Media5 Interactive" when carrying out such processing of PD of Website Visitors. This Policy does not apply to the processing of personal data of other subjects, as these relationships are governed by other internal regulatory documents of LLC "Media5 Interactive".
- LLC "Media5 Interactive" fully ensures the observance of the rights and freedoms of citizens during the processing of personal data, including ensuring the protection of the rights to privacy, personal and family secrets.
- This Policy has been developed in accordance with subpar. 2 p. 1 of Article 18.1 of the Federal Law of July 27, 2006 No. 152 "On Personal Data" and is intended for familiarization by an unlimited range of persons.
- Principles of Personal Data Processing
- When processing personal data at LLC "Media5 Interactive", the following principles are strictly observed:
- processing of personal data incompatible with the purposes of collecting personal data is not permitted;
- processing of personal data that does not meet the processing purposes is not permitted. The content and scope of personal data processed at LLC "Media5 Interactive" correspond to the stated processing purposes;
- when processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data are ensured;
- storage of personal data is carried out for no longer than required by the purposes of personal data processing, as well as federal laws of the Russian Federation and contracts to which the personal data subject is a party, beneficiary, or guarantor.
- Scope and Categories of Processed Personal Data, Categories of Personal Data Subjects. Purposes of Personal Data Processing
- The Operator processes PD in accordance with the requirements of the legislation of the Russian Federation in the field of PD. The Operator does not process PD concerning racial, national origin, political views, religious or philosophical beliefs, health status, intimate life.
- The Operator processes personal data of the following categories of subjects (natural persons): Website Visitors.
- The Operator may process the following personal data of Website Visitors:
- Composition of PD — Name, contact information (email address, phone number), name of the employer company
- Category of PD — Other
- Purpose of processing — Providing reference information about the activities of LLC "Media5 Interactive"
- Types of PD processing — Automated processing
- Methods of PD processing — Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, depersonalization, blocking, deletion, destruction
- Storage periods, conditions for termination of processing — From the date of signing the consent to the processing of PD until the moment the consent is withdrawn. Processing of personal data also ceases in cases of detection of unlawful processing of PD.
- Legal basis for PD processing — Consent to the processing of PD
- The subject clicking the "Submit" button when filling out the PD collection form is unequivocally regarded by the Operator as acceptance of the terms of this Policy and provision of consent to the processing of personal data.In the absence of the subject's consent to the processing of their personal data, such processing is not carried out.The condition for terminating the processing of personal data is the achievement of the processing goals, the expiration of the consent period or the withdrawal of the personal data subject's consent to the processing of their PD, as well as the detection of unlawful processing of personal data.
- The Operator has the right to use cookie technology. Cookies are used to provide or optimize the Website services, to communicate with Website Visitors, to develop content, or for research and analysis purposes.
- Confidentiality of Personal Data and Possibility of Transferring Personal Data to Third Parties
- Access to personal data is restricted in accordance with the federal laws of the Russian Federation and local legal acts of LLC "Media5 Interactive".
- LLC "Media5 Interactive" does not disclose personal data obtained as a result of its professional activities.
- Employees of LLC "Media5 Interactive" who have gained access to personal data undertake obligations to ensure the confidentiality of the processed personal data.
- Access to personal data processed at LLC "Media5 Interactive" is provided to state authorities upon their written request (demand), based on and in execution of normative legal acts.
- The Operator ensures the processing of PD using databases located on the territory of the Russian Federation. Cross-border transfer of PD is not carried out.
- The Operator does not disclose personal data to third parties and does not distribute personal data without the consent of the personal data subject, unless otherwise provided by law.
- The Operator may entrust the processing of PD to third parties with the consent of the personal data subject, provided that the person processing PD on behalf of the Operator complies with the principles and rules of processing, as well as ensuring the security of PD.
- Security of Personal Data
- LLC "Media5 Interactive" takes necessary technical and organizational information security measures to protect personal data from unauthorized access, alteration, disclosure, or destruction, through internal reviews of data collection, storage, and processing processes and security measures, as well as implementing measures to ensure the physical security of data to prevent unauthorized access to systems where LLC "Media5 Interactive" stores personal data.
- Rights and Obligations of Personal Data Subjects
- Rights of personal data subjects.
- The personal data subject has the right to receive information concerning the processing of their personal data, except in cases provided for by federal laws, by submitting a request to the Operator. Information is provided by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Federal Law of July 27, 2006 No. 152 "On Personal Data".
- The personal data subject has the right to supplement, correct, depersonalize, or delete any incomplete, inaccurate, or outdated personal data, or to withdraw consent to the processing of personal data by contacting the Operator via email.The request of the personal data subject must contain:
- the number of the main identity document of the personal data subject or their representative, information about the date of issue of the specified document and the issuing authority;
- information confirming the participation of the personal data subject in relations with the Operator (contract number, date of conclusion of the contract, conditional verbal designation and/or other information), or information otherwise confirming the fact of processing personal data by the Operator;
- the signature of the personal data subject or their representative.
The request can be sent to the Operator via email to info@media5.com. If the communication (request) of the personal data subject does not reflect all the necessary information in accordance with the requirements of the Federal Law of July 27, 2006 No. 152 "On Personal Data", or the subject does not have the right to access the requested information, a reasoned refusal will be sent to them.At the same time, in some cases (for example, if the personal data subject requests the deletion of personal data or the cessation of its processing), such a request may also mean that the Operator will no longer be able to provide services for which the receipt and processing of personal data by the Operator is a necessary and mandatory condition.
- Obligations of personal data subjects
- The personal data subject is obliged to provide the Operator with reliable data about themselves, to inform the Operator about the clarification (updating, modification) of their personal data.
- Users who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, bear responsibility in accordance with the legislation of the Russian Federation.
- Main Rights and Obligations of the Operator
- Rights of the Operator.
- The Operator takes reasonable measures to maintain the accuracy and relevance of available personal data, as well as to delete personal data if it is outdated, inaccurate, or excessive, or if the purposes of its processing have been achieved. The Operator has the right to receive reliable information and/or documents containing personal data from the personal data subject.
- If the personal data subject withdraws consent to 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 Federal Law of July 27, 2006 No. 152 "On Personal Data".
- The Operator has the right to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Federal Law of July 27, 2006 No. 152 "On Personal Data" and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Federal Law of July 27, 2006 No. 152 "On Personal Data" or other federal laws.
- Obligations of the Operator.
- The Operator is obliged to provide the personal data subject, upon their request, with information concerning the processing of their personal data.
- The Operator organizes the processing of personal data in the manner established by the current legislation of the Russian Federation; – respond to requests from personal data subjects and their legal representatives in accordance with the requirements of the Federal Law of July 27, 2006 No. 152 "On Personal Data";
- The Operator reports necessary information to the authorized body for the protection of the rights of personal data subjects upon request of this body within 30 days from the date of receipt of such a request;
- The Operator is obliged to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
- The Operator is obliged to take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data.
- The Operator is obliged to cease processing and destroy personal data in the manner and cases provided for by the Federal Law of July 27, 2006 No. 152 "On Personal Data".
- Final Provisions
- All issues related to the processing of personal data not regulated by this Policy are governed in accordance with the current legislation of the Russian Federation.
- The Policy is subject to updating in the following cases:
- upon changes in legislation in the field of processing and protection of personal data;
- upon order of competent state authorities;
- by decision of the Operator (including changes in collection and processing processes, changes in the purposes and terms of personal data processing, changes in organizational structure, information systems, technologies for collecting, processing, and protecting personal data).
- In case of amendments to the Policy, the changes are communicated to an unlimited range of persons by posting the Policy in the new version on the Website.
- Contacts
- Limited Liability Company "Media5 Interactive" (INN 7714878160, KPP 771401001, OGRN 1127746535564, Moscow, Leningradsky Prospekt, d. 39, str. 14, room VI, office 19v).