Privacy Policy
This Policy on the processing of personal data (hereinafter — the Policy) defines the policy regarding the processing of personal data and contains information about the implemented requirements for the protection of personal data on the Operator's Platform.
1. Terms and Definitions
1.1 User – the subject of personal data, a natural or legal person intending to use or using the Platform, including one who has concluded an agreement with the Operator.
1.2 Operator – Fortsys Group LLC, 191014, St. Petersburg, Ligovsky Prospect, 6, building/section 2, apartment/office 14n.
1.3 Platform – the software infrastructure that ensures interaction and transactions between a significant number of independent participants (for example, consumers and producers, sellers and buyers) in a unified information environment intended for display in a browser and accessed using the domain name fortsys.org.
1.4 Registration data – the list of information about the User determined by the Operator, specified on the Platform during registration and in the process of fulfilling the Agreement.
1.5 Personal data – any information relating to a directly or indirectly identified or identifiable natural person (the subject of personal data).
1.6 Anonymization of personal data – actions as a result of which it becomes impossible, without the use of additional information, to determine that personal data belong to a specific subject of personal data.
1.7 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), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
1.8 Automated processing of personal data – processing of personal data using computing equipment.
1.9 Personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
1.10 Blocking of personal data – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify the personal data).
2. General Provisions
This Policy has been drawn up in accordance with part 4 of article 22 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by the Operator.
2.1. This Policy is published on the Platform page at https://fortsys.org
2.2. This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may receive about visitors to the website https://www.fortsys.org.
2.3. By accepting the terms of this Policy, the User expresses consent to the processing of data about the User for the purposes provided for in this Policy.
2.4. 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 right to privacy and personal and family secrets.
2.5. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.6. Distribution of personal data – any actions aimed at disclosing personal data to an undefined group of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
3. Categories of Personal Data Subjects
3.1. The Operator processes the personal data of the following categories of personal data subjects:
3.2. Employees of the Operator, dismissed employees, and candidates for vacant positions.
3.3. Users.
3.4. Natural persons acting on behalf of Customers.
3.5. Representatives of the Operator's Counterparties.
4. Purposes and Grounds for Processing Personal Data
4.1. Personal data of employees, dismissed employees, and candidates for vacant positions of the Operator are processed in accordance with subparagraph 2 of paragraph 1 of article 6 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", as well as the Labor Code of the Russian Federation, for the purpose of fulfilling the provisions of the employment contract, the Labor Code of the Russian Federation, and related regulatory legal acts.
4.2. Personal data of Users in terms of the use of the Platform are processed in accordance with subparagraphs 1 and 5 of paragraph 1 of article 6 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" for the purpose of familiarization with the Operator's services and the intention to conclude an agreement.
4.3. Personal data of Users in terms of informing about the activities of the Operator via email, official mail, or telephone are processed in accordance with subparagraph 1 of paragraph 1 of article 6 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" in connection with consent to the processing of personal data given in implicit or explicit form.
4.4. Personal data of Users who are representatives of the Customer are processed in accordance with subparagraph 5 of paragraph 1 of article 6 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" for the purpose of concluding and executing the agreement for the provision of services.
4.5. Personal data of employees (representatives) of the Operator's Counterparty are processed in accordance with subparagraph 5 of paragraph 1 of article 6 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" for the purpose of concluding and executing the agreement concluded between the Counterparty and the Operator.
4.6. Personal data may be used for other purposes if this is mandatory in accordance with the provisions of the legislation of the Russian Federation.
4.7. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection of personal data is not permitted.
5. Composition of Information about Users
5.1. The Operator processes the following personal data of the User: surname, first name, patronymic, email address, phone numbers, name of the Legal entity.
5.2. The Operator processes personal data whose transfer is provided for by the data exchange protocols of the payment systems used to pay for services under contractual obligations.
5.3. Other personal data necessary for the full and conscientious performance of contractual obligations by the Operator.
6. Types of Personal Data Processing
6.1. Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
6.2. Sending information letters to the email address.
7. User Rights
The User has the right to:
7.1. Search for information on the site.
7.2. Receive information on the site.
7.3. Create information for the site.
7.4. Copy information to other sites with the permission of the Platform Operator.
7.5. Require the Operator to hide any information transferred by the user to the Platform.
7.6. Receive from the Company any information concerning the processing of their personal data.
7.7. Use Platform information for personal non-commercial purposes.
8. Conditions for Processing Personal Data
8.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
8.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
8.3. 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.
8.4. The processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor.
8.5. 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 goals, provided that the rights and freedoms of the subject of personal data are not violated.
8.6. The processing of personal data is carried out by a circle of persons authorized by the Operator, or at the request of the subject of personal data (hereinafter — publicly available personal data).
8.7. The processing of personal data subject to publication or mandatory disclosure shall be carried out in accordance with federal law.
9. Information on the Implemented Requirements for the Protection of Personal Data
9.1. When processing personal data, the Operator takes the necessary legal, organizational, and technical measures and ensures their adoption to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, and from other unlawful actions in relation to personal data, which include in particular (but are not limited to):
9.1.1. Appointment of a person responsible for the processing of personal data.
9.1.2. Restriction of the composition of employees who have access to personal data.
9.1.3. Software identification of Users, including employees of the Company, and recording of their actions.
9.1.4. Implementation of antivirus control and other measures against malicious software and mathematical influence.
9.1.5. Application of means of backup and restoration of information.
9.1.6. Updating software when security patches are available from manufacturers.
9.1.7. Implementation of encryption using an SSL certificate when transferring personal data over the Internet.
10. Confidentiality
10.1. 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 subject of personal data, except in cases provided for by current legislation.
11. Destruction (Anonymization) of Personal Data
11.1. Destruction (anonymization) of personal data – any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed. It is carried out in the following cases:
11.1.1. upon achievement of the purposes of their processing or in the event of the loss of the need to achieve them within a period not exceeding thirty days from the moment of achieving the purpose of processing personal data, unless otherwise provided for by an agreement to which the subject of personal data is a party, or another agreement between the Operator and the subject of personal data (their representative, employer);
11.1.2. in the event that the Operator detects unlawful processing of the User's personal data within a period not exceeding ten working days from the moment of detection of such a case;
11.1.3. in the event of the expiration of the period of storage of personal data determined in accordance with the legislation of the Russian Federation and the organizational and administrative documents of the Operator;
11.1.4. in the event of an order from the authorized body for the protection of the rights of personal data subjects, the Prosecutor's Office of Russia, or a court decision.
16. Final Provisions
16.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@fortsys.org.
16.2. This Policy on the processing of personal data is subject to amendment and supplementation in the event of new legislative acts and special regulatory acts on the processing and protection of personal data, as well as by decision of the Operator.
16.3. The period of processing of personal data processed by the Operator is determined by the organizational and administrative documents of the Operator in accordance with the provisions of the Federal Law "On Personal Data".
16.3. Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for the organization of the processing of personal data.
16.4. Issues not regulated by this Policy are governed by the current legislation of the Russian Federation.
16.5. The Policy is valid indefinitely and is subject to amendment and supplementation in the event of new legislative acts and special regulatory acts on the processing and protection of personal data, as well as by decision of the Operator.
16.6. The current version of the Policy is publicly available and posted in open access on the Internet at https://fortsys.org/ru/privacy_policy