Privacy policy

This Policy defines the personal data processing procedure and the measures taken by Barinoff Limited Liability Company (hereinafter referred to as the Operator) to protect it.

1. General Provisions

This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the personal data processing procedure and the measures taken by Barinoff Limited Liability Company (hereinafter referred to as the Operator) to ensure the security of personal data.

1. The Operator’s primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of privacy, personal and family confidentiality.
2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information the Operator may receive about visitors to the website https://barinof.ru.

2. Key Concepts Used in the Policy

1. Automated Processing of Personal Data — processing of personal data using computer technology.
2. Blocking of Personal Data — temporary suspension of processing of personal data (except in cases where processing is necessary to clarify personal data).
3. Website — a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://barinof.ru.
4. Personal Data Information System — a collection of personal data contained in databases and the information technologies and technical means that ensure their processing.
5. Anonymization of Personal Data — actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data data.
6. Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
7. Operator — a government agency, municipal body, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
8. Personal data — any information relating directly or indirectly to a specific or determinable User of the website https://barinof.ru.
9. Personal data permitted for distribution by the personal data subject — personal data, access to which is granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data, permitted by the personal data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data permitted for distribution).
10. User — any visitor to the website https://barinof.ru.
11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarization with personal data an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunications networks, or providing access to personal data in any other way.
13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign government agency, a foreign individual, or a foreign legal entity.
14. Destruction of personal data — any action resulting in the irreversible destruction of personal data, making it impossible to restore the contents of the personal data in the personal data information system, and/or the destruction of tangible media containing the personal data.

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 personal data subject;
• if the personal data subject revokes consent to the processing of personal data, or submits an application requesting termination of the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, provided there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject, upon request, with information regarding the processing of his or her personal data;
• organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
• notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 10 days from the date of receipt of such request;
• publish or otherwise ensure 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, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
• stop the transfer (distribution, (i) provision, access) of personal data, terminate processing, and destroy personal data in the manner and in the cases stipulated by the Law on Personal Data;
• fulfill other obligations stipulated 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 regarding the processing of their personal data, except in cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, unless there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
• require the operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
• condition prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
• revoke consent to the processing of personal data, as well as request the termination of the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing their personal data;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate information about themselves;
• notify the Operator of any clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject, without the latter’s consent, shall be liable in accordance with Russian legislation.

5. Principles of Personal Data Processing

1. Personal data shall be processed in a lawful and fair manner.
2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

Containing personal data that is processed for incompatible purposes.

3. Only personal data that is relevant to the purposes of processing will be processed.
4. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive amounts of processed personal data in relation to the stated purposes of processing are not permitted.
5. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing are ensured. The operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6. Personal data is stored in a form that allows for the identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized once the processing purposes have been achieved or if the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.

6. Purposes of personal data processing

7. Personal Data Processing Terms

1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
2. Personal data processing is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or the act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
5. Personal data processing is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject. Data.
6. Personal data processed is data that is made publicly available to an unlimited number of persons by the data subject or at their request (hereinafter referred to as publicly available personal data).
7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for collecting, storing, transferring, and otherwise processing 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 current legislation in the field of personal data protection.

1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given the Operator consent to transfer the data to a third party for the fulfillment of obligations under a civil contract.
3. If inaccuracies are discovered in personal data, the User can update it independently by sending a notification to the Operator’s email address info@barinof.ru with the subject “Updating personal data.”
4. The processing period for personal data is determined by the achievement of the objectives, for which the personal data was collected, unless another period is provided by the agreement or applicable law. The user may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to info@barinof.ru with the subject “Revocation of consent to the processing of personal data.”
5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or the specified documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this paragraph.
6. Prohibitions on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution established by the personal data subject, shall not apply in cases of personal data processing in state, public and other public interests defined by the legislation of the Russian Federation.
7. When processing personal data, the Operator ensures the confidentiality of personal data.
8. The Operator stores personal data in a form that allows for the identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
9. The condition for termination of personal data processing may be the achievement of the personal data processing purposes, the expiration of the consent of the personal data subject, the revocation of consent by the personal data subject or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data. Data.

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

1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

1. Prior to the commencement of cross-border transfers of personal data, the Operator is obligated to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
2. Prior to submitting the above notification, the Operator is obligated to obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

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

12. Final Provisions

1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator by email at info@barinof.ru.
2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
3. The current version of the Policy is publicly available online at https://barinof.ru/privacy-policy/.

This document has been prepared for posting on the Barinoff LLC website. For questions regarding the Policy: info@barinof.ru.