Privacy Policy for the Processing of Personal Data
1. General provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Karpov Daniel (hereinafter, the Operator).
1.1. The Operator’s primary goal and condition for carrying out its activities is to respect human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website https://btop.ltd.cy/en
2. Key terms used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary cessation of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, which ensure their availability on the Internet at the network address https://btop.ltd.cy/en
2.4. Personal data information system means a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belong to a specific User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator means a state body, municipal body, legal entity, or natural person, independently or together with other persons, that organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://btop.ltd.cy/en
2.9. Personal data permitted by the personal data subject for dissemination means personal data to which access by an unlimited number of persons is provided by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner provided for by the Personal Data Law (hereinafter, personal data permitted for dissemination).
2.10. User means any visitor to the website https://btop.ltd.cy/en
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including the publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a public authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical media containing personal data are destroyed.
3. Primary rights and obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, as well as sends a request demanding cessation of personal data processing, 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 Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator shall:
— provide, at the request of the personal data subject, information relating to the processing of his/her personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide to the authorized body for the protection of the rights of personal data subjects, upon request of that body, the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions with respect to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and in cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.
4. Primary rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
— receive information relating to 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 must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the operator clarify their personal data, or block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data, as well as send a demand to cease the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator in processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
— provide the Operator with accurate information about themselves;
— inform the Operator about the clarification (updating, modification) 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, bear liability in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data were collected is not allowed.
5.3. The merging of databases containing personal data whose processing is carried out for purposes that are mutually incompatible is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject no longer than is required by the purposes of personal data processing, unless the period for storing personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing - informing the User by sending emails
Personal data:
— last name, first name, patronymic
— email address
— phone numbers
Legal grounds:
— the Operator’s charter (founding) documents
— contracts concluded between the Operator and the personal data subject
Types of personal data processing:
— collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
— sending informational emails to the email address
7. Conditions for processing personal data
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and duties imposed on 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 judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or a beneficiary or a guarantor, and also for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or a guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. Personal data that have been made accessible to an unlimited number of persons by the personal data subject or at his/her request (hereinafter, publicly available personal data) are processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.
8. Procedure for collection, storage, transfer, and other types of processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully meet the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the preservation of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. 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-law contract.
8.3. If inaccuracies are found in personal data, the User may update them independently by sending the Operator a notice to the Operator’s email address b.top.proff@gmail.com with the subject line “Update of personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or by applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending the Operator a notice via email to the Operator’s email address b.top.proff@gmail.com with the subject line “Withdrawal of consent to the processing of personal data.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall familiarize him/herself with such documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on transfer (other than provision of access), as well as on processing or on conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than is required by the purposes of personal data processing, unless the period for storing personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, or a demand to cease processing of personal data, as well as detection 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, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such means.
10. Cross-border transfer of personal data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notice is submitted separately from the notice of intention to process personal data).
10.2. Prior to submitting the above notice, the Operator shall obtain from the public authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarifications on matters of interest relating to the processing of his/her personal data by contacting the Operator via email at b.top.proff@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid for an indefinite period until it is replaced with a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://btop.ltd.cy/policy_en
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Karpov Daniel (hereinafter, the Operator).
1.1. The Operator’s primary goal and condition for carrying out its activities is to respect human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website https://btop.ltd.cy/en
2. Key terms used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary cessation of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, which ensure their availability on the Internet at the network address https://btop.ltd.cy/en
2.4. Personal data information system means a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belong to a specific User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator means a state body, municipal body, legal entity, or natural person, independently or together with other persons, that organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://btop.ltd.cy/en
2.9. Personal data permitted by the personal data subject for dissemination means personal data to which access by an unlimited number of persons is provided by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner provided for by the Personal Data Law (hereinafter, personal data permitted for dissemination).
2.10. User means any visitor to the website https://btop.ltd.cy/en
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including the publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a public authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical media containing personal data are destroyed.
3. Primary rights and obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, as well as sends a request demanding cessation of personal data processing, 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 Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator shall:
— provide, at the request of the personal data subject, information relating to the processing of his/her personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide to the authorized body for the protection of the rights of personal data subjects, upon request of that body, the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions with respect to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and in cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.
4. Primary rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
— receive information relating to 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 must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the operator clarify their personal data, or block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data, as well as send a demand to cease the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator in processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
— provide the Operator with accurate information about themselves;
— inform the Operator about the clarification (updating, modification) 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, bear liability in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data were collected is not allowed.
5.3. The merging of databases containing personal data whose processing is carried out for purposes that are mutually incompatible is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject no longer than is required by the purposes of personal data processing, unless the period for storing personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing - informing the User by sending emails
Personal data:
— last name, first name, patronymic
— email address
— phone numbers
Legal grounds:
— the Operator’s charter (founding) documents
— contracts concluded between the Operator and the personal data subject
Types of personal data processing:
— collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
— sending informational emails to the email address
7. Conditions for processing personal data
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and duties imposed on 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 judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or a beneficiary or a guarantor, and also for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or a guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. Personal data that have been made accessible to an unlimited number of persons by the personal data subject or at his/her request (hereinafter, publicly available personal data) are processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.
8. Procedure for collection, storage, transfer, and other types of processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully meet the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the preservation of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. 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-law contract.
8.3. If inaccuracies are found in personal data, the User may update them independently by sending the Operator a notice to the Operator’s email address b.top.proff@gmail.com with the subject line “Update of personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or by applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending the Operator a notice via email to the Operator’s email address b.top.proff@gmail.com with the subject line “Withdrawal of consent to the processing of personal data.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall familiarize him/herself with such documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on transfer (other than provision of access), as well as on processing or on conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than is required by the purposes of personal data processing, unless the period for storing personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, or a demand to cease processing of personal data, as well as detection 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, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such means.
10. Cross-border transfer of personal data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notice is submitted separately from the notice of intention to process personal data).
10.2. Prior to submitting the above notice, the Operator shall obtain from the public authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarifications on matters of interest relating to the processing of his/her personal data by contacting the Operator via email at b.top.proff@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid for an indefinite period until it is replaced with a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://btop.ltd.cy/policy_en
