PERSONAL DATA PROCESSING POLICY

General Provisions

This Personal Data Processing Policy (hereinafter – the Policy) of LLC "TK" with legal address: 625022, Tyumen Region, Tyumen, Shcherbakova St., 87 (hereinafter – the Operator) is an official document that defines the general principles, purposes, and procedure for processing personal data of users of the website (marcialmed.com) (hereinafter – the Website), as well as information about the implemented measures for the protection of personal data.

The Policy is developed in accordance with the legislation of the Russian Federation in the area of personal data.

This Policy applies exclusively to the Website. The Operator does not control and is not responsible for third-party websites that the User may access using links available on the Website.

The Operator's processing of personal data of other categories of personal data subjects is regulated by other local regulations of the Operator.

This Policy comes into force from the moment of its approval and is valid indefinitely until replaced by a new Policy.

The use of the Website means the User's unconditional consent to this Policy and the conditions for processing his/her personal information specified therein.

In case of disagreement with these conditions, the User must refrain from using the Website.

Key Terms and Definitions

The following terms are used in this Policy:

• Personal Data Information System – a set of personal data contained in databases and information technologies and technical means that support their processing.
• 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, modification), extraction, use, blocking, deletion, destruction of personal data.
• Operator of Personal Data (operator) – a public authority, municipal authority, 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, actions (operations) performed with personal data.
• Personal Data – any information relating to a directly or indirectly identified or identifiable individual (subject of personal data);
• Website User – any person visiting the Website and using the information, materials, and services of the Website.
• Website – a set of interconnected web pages located on the Internet at a unique address (URL), as well as its subdomains.
• Cookies – a small piece of data sent by a web server and stored on the User's computer, which the web client or web browser sends to the web server each time in an HTTP request when trying to open a page of the corresponding site.
• IP Address – a unique network address of a node in a computer network through which the User accesses the Website.

Procedure and Conditions for Personal Data Processing

The legal basis for the personal data processing of Website Users is consent to the processing of personal data.

Website Users give their consent to the processing of their personal data in the following cases:

• when logging in via social networks;
• when filling out a feedback form / submitting a request for a service / program / consultation;
• when subscribing to a mailing list;
• when submitting reviews;
• when submitting inquiries;

In case the User disagrees with the terms of this Policy, the use of the Website and/or any Services available when using the Website must be immediately terminated.

The personal data of Website Users are processed for the following purposes:

• promotion of goods, works, services;
• establishing feedback with the website user, including sending notifications, requests, and processing them;
• receiving and publishing reviews;
• maintaining statistics and analyzing the website's performance.

The list of personal data of users processed on the Website using automation tools:

• last name, first name, surname;
• date of birth;
• email address;
• phone number;
• other information that the user decides to provide.

For maintaining statistics and analyzing the Website's performance, the Operator processes, using the Yandex.Metrica service, data such as:

• IP address;
• browser information;
• data from cookies;
• access time;
• referrer (address of the previous page).

The Yandex.Metrica service, available at http://api.yandex.com/metrika, allows various User services and applications to interact with the Yandex.Metrica service of Yandex LLC, registered at 119021, Moscow, Lva Tolstogo St., 16 (hereinafter – Yandex).

Yandex.Metrica works with cookies and creates pseudonymous usage profiles that allow analyzing how Users use the Website.

Information stored in such cookies (for example, browser type/version, operating system used, referrer URL, hostname of the accessing computer, server request time) is usually transmitted and stored on a Yandex server.

The User can prevent the collection of data generated by the cookie and related to their use of the Website, as well as the processing of this data by Yandex, by downloading and installing the browser plugin available at the link: https://yandex.com/support/metrica/general/opt-out.html?lang=ru.

Additional information can be found in Yandex's privacy policy: https://yandex.ru/legal/confidential/?lang=ru.

If Yandex.Metrica is blocked, some functions of the Website may become unavailable.

The processing of biometric personal data and special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, health status, intimate life is not carried out on the Website.

The Operator does not verify the accuracy of the information provided by the User and assumes that the User provides reliable and sufficient information and maintains its relevance.

The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, blocking, deletion, destruction.

Storage of personal data is carried out in a form that allows identify the subject of personal data for no longer than required by the purposes of processing personal data.

The termination of personal data processing may occur upon achieving the purposes of processing personal data, expiration of the personal data processing period, withdrawal of the Website User's consent to the processing of his/her personal data, or identification of unlawful processing of personal data.

The storage period for personal data of Website Users is 1 year from the moment of the last data submission.

The confidentiality of the User's personal information is maintained, except in cases where the User voluntarily provides information about himself/herself for general access to an unlimited number of persons.

Measures to Ensure the Security of Personal Data

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational, technical, and program measures necessary and sufficient to meet the requirements of the legislation of the Russian Federation.

The Operator takes the following measures to ensure the security of personal data:

• appointment of responsible persons for organizing the processing and ensuring the protection of personal data;
• limiting the number of the operator's employees who have access to personal data;
• determining the level of protection of personal data when processed in personal data information systems;
• establishing rules for access control to personal data processed in personal data information systems and ensuring the registration and accounting of all actions performed with personal data;
• restricting access to premises where the main technical means and systems of personal data information systems are located and where non-automated processing of personal data is carried out;
• application of information security tools that have passed the conformity assessment procedure in accordance with the established procedure;
• assessment of the effectiveness of measures taken to ensure the security of personal data before commissioning the personal data information system;
• maintaining records of machine-readable media containing personal data;
• detection of facts of unauthorized access to personal data and taking measures to establish the causes and eliminate possible consequences;
• restoration of personal data modified or destroyed due to unauthorized access to them;
• establishing requirements for password complexity for access to personal data information systems;
• implementing antivirus control, preventing the introduction of malware (viruses) and software bookmarks into the corporate network;
• organizing timely updates of software used in personal data information systems and information protection tools;
• conducting regular assessments of the effectiveness of measures taken to ensure the security of personal data;
• monitoring the measures taken to ensure the security of personal data and the security levels of personal data information systems.

Rights of Website Users

The Website User has the right to receive information relating to the processing of his/her personal data, including the following:

• confirmation of the fact of personal data processing by the operator;
• legal grounds and purposes of personal data processing;
• the purposes and methods of processing personal data used by the operator;
• the name and location of the operator, information about persons (except for the operator's employees) who have access to personal data or to whom personal data may be disclosed under an agreement with the operator or based on federal law;
• the processed personal data relating to the respective subject of personal data, the source of their receipt, unless a different procedure for presenting such data is provided by federal law;
• the terms of processing personal data, including their storage periods;
• the procedure for the exercise by the subject of personal data of the rights provided for by the federal law "on personal data";
• the name or surname, first name, patronymic and address of the person processing personal data on behalf of the operator, if the processing is or will be entrusted to such a person;
• other information provided for by the federal law "on personal data" or other federal laws.

The Website User has the right to demand from the Operator the clarification of his/her personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights.

The Website User has the right to request, in a structured, commonly used, and machine-readable format, a list of his/her personal data provided to the Operator for processing, and to instruct the Operator to transfer his/her personal data to a third party, provided that the technical capability exists.

In this case, the Operator is not responsible for the subsequent actions of the third party with the personal data.

All questions regarding the processing of personal data should be sent to: info@marcial.ru.

Liability

The User is fully responsible for compliance with the requirements of the current legislation of the Russian Federation, including laws on advertising, on the protection of copyright and related rights, on the protection of trademarks and service marks, but not limited to the listed, including full responsibility for the content and form of materials, in case of quoting and other use of information obtained in connection with the use of the Website's services.

Final Provisions

The Operator has the right to make changes to this Policy unilaterally in case of changes in the regulatory legal acts of the Russian Federation, as well as at its own discretion.

Control over the implementation of the requirements of this Policy is carried out by the person responsible for organizing the processing of personal data.

Persons guilty of violating the norms governing the processing and protection of personal data bear material, disciplinary, administrative, civil, or criminal liability in the manner prescribed by the legislation of the Russian Federation.