Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been 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 determines the procedure for processing personal data and the measures to ensure the security of personal data taken by Fortsys Group (hereinafter — the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://www.fortsys.info.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://www.fortsys.info.

2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.

2.6. Processing of personal data — 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), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, 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 subject to processing, the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://www.fortsys.info.

2.9. Personal data permitted by the personal data subject for distribution — personal data, access to which by an unlimited number of persons is granted 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 Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor to the website https://www.fortsys.info.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with personal data by an unlimited circle of persons, including the publication of personal data in the media, placement in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign natural or foreign legal person.

2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

  • receive from the personal data subject reliable information and/or documents containing personal data;
  • if the personal data subject withdraws consent to the processing of personal data, as well as sends a request to stop processing 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 Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for 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, at his request, with information concerning the processing of his personal data;
  • organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 10 days from the date of receipt of such a request;
  • publish or otherwise ensure unlimited 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, provision, access) of personal data, stop the processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
  • fulfill other duties provided for by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

  • receive information concerning the processing of his personal data, except for cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • require the operator to clarify his personal data, block or destroy them in case 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;
  • put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
  • withdraw consent to the processing of personal data, as well as to send a request to stop processing personal data;
  • appeal to the authorized body for the protection of the rights of personal data subjects or to the court against illegal actions or inaction of the Operator when processing his 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 reliable data about themselves;
  • inform the Operator about the clarification (update, modification) of their personal data.

4.3. Persons who have transferred unreliable information about themselves to the Operator, or information about another personal data subject without the consent of the latter, are responsible in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a legal and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predefined and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed 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, in necessary cases, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows the identification of the personal data subject, no longer than required by the purposes of processing personal data, if the storage period for personal data is not established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Processing purpose
Informing the User by sending emails
Personal data
  • surname, first name, patronymic
  • email address
  • phone numbers
  • year, month, date and place of birth
  • name of the Legal Entity
Legal basis
Charter (founding) documents of the Operator
Types of personal data processing
  • Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
  • Sending informational emails to the email address

7. Conditions for Processing Personal Data

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his 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, to carry out functions, powers and duties assigned by the legislation of the Russian Federation to the operator.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, 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 beneficiary or guarantor, as well as 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 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 violated.

7.6. Personal data is processed, access to which by an unlimited number of persons is provided by the personal data subject or at his request (hereinafter — publicly available personal data).

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 Personal Data Processing

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.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil contract.

8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address info@fortsys.info marked "Personal Data Update".

8.4. The period of processing personal data is determined by the achievement of the purposes for which personal data were collected, unless another period is provided for by an agreement or current legislation. The User can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via email at the Operator's email address info@fortsys.info marked "Withdrawal of consent to the processing of personal data".

8.5. All information that is collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers indicated in this paragraph.

8.6. The prohibitions on transfer (except for granting 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, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows the identification of the personal data subject, no longer than required by the purposes of processing personal data, if the storage period for personal data is not established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.

8.9. The conditions for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or the requirement to stop the processing of personal data, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information over information and telecommunications networks or without it.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing the activity of cross-border transfer of personal data, the Operator is obliged to 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 notification is sent separately from the notification of the intention to carry out the processing of personal data).

10.2. Before submitting the above notification, the Operator is obliged to receive from the authorities of the foreign state, foreign individuals, 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 can receive any clarifications on questions of interest concerning the processing of his personal data by contacting the Operator via email info@fortsys.info.

12.2. This document will reflect any changes in the personal data processing policy by the Operator. The Policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is published on this page and is freely available.