Privacy policy
1. General Provisions
This Personal Data Processing Policy is drafted in accordance with the requirements of the Personal Data Law and defines the procedures for processing personal data and the measures taken by LLC “VINI” (hereinafter — the Operator) to ensure the security of personal data.
1.1. The Operator considers the primary goal and condition for its activities to be the respect for human and citizen rights and freedoms when processing their personal data, including the protection of privacy, personal, and family secrets.
1.2. This Policy of the Operator regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website http://noone.am.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary cessation 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, that provide access to them on the Internet at the network address http://noone.am.
2.4. Personal Data Information System — a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine, without additional information, the specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal Data — any information related directly or indirectly to a specific or identifiable User of the website http://noone.am.
2.9. Personal Data Authorized for Distribution — personal data to which an unlimited number of persons are granted access by the personal data subject through consent to the processing of personal data authorized for distribution by the personal data subject as per the Personal Data Law (hereinafter — personal data authorized for distribution).
2.10. User — any visitor to the website http://noone.am.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an undefined group of persons (transmission of personal data) or making personal data available to an unlimited number of persons, including publication in mass 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 — transfer of personal data to a foreign state’s territory to a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or destroying physical media of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Obtain accurate information and/or documents containing personal data from the personal data subject;
— In case of withdrawal of consent by the personal data subject for personal data processing, or a request to cease processing personal data, continue processing personal data without the subject’s consent if there are grounds specified in the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and related regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— Provide the personal data subject with information regarding the processing of their personal data upon request;
— Organize the processing of personal data in accordance with current Russian legislation;
— Respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Notify the authorized body for the protection of personal data subjects’ rights of any required information within 10 days from the date of such request;
— Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions regarding personal data;
— Cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— Fulfill other obligations as provided by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— Obtain information regarding the processing of their personal data, except in cases provided by federal laws. Information must be provided in an accessible form and should not contain personal data related to other personal data subjects, except where there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— Request the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purposes, as well as take legal measures to protect their rights;
— Require preliminary consent for processing personal data for marketing purposes;
— Withdraw consent to the processing of personal data and submit a request to cease processing personal data;
— Appeal to the authorized body for the protection of personal data subjects’ rights or take legal action against unlawful actions or inactions of the Operator regarding the processing of their personal data;
— Exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obligated to:
— Provide the Operator with accurate data about themselves;
— Notify the Operator of any updates (changes, modifications) to their personal data.
4.3. Individuals who provided inaccurate information about themselves or another personal data subject without consent bear responsibility in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out legally and fairly.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing that is incompatible with the purposes of personal data collection is not allowed.
5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of processing is processed.
5.5. The content and scope of processed personal data should correspond to the stated purposes of processing. Excessive processing of personal data relative to the stated purposes is not allowed.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data concerning the processing purposes are ensured. The Operator takes necessary measures to remove or correct incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the personal data subject only as long as required by the purposes of processing unless a different storage period is established by federal law, contract, or agreement involving the personal data subject. Processed personal data is either destroyed or anonymized upon achieving the processing purposes or when the need for processing ceases, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Informing Users through sending electronic emails
Last name, first name, patronymic, email address
Contracts between the Operator and the personal data subject
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
Sending informational emails to the email address
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes stipulated by international treaties of the Russian Federation or laws, to perform the functions, powers, and obligations imposed on the Operator by Russian legislation.
7.3. Personal data processing is necessary for the administration of justice, execution of a court order, or act of another authority or official that must be executed according to Russian law on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract, where the personal data subject is a party or a beneficiary or guarantor, and for the conclusion of a contract at the personal data subject’s initiative or where the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data that is made publicly available by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure according to federal law.
8. Procedure for Collecting, Storing, Transferring, 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 on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never be transferred to third parties under any circumstances, except in cases related to the enforcement of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for fulfilling obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update it independently by sending a notification to the Operator’s email address noone.armenia@mail.ru with the subject “Update of Personal Data.”
8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different term is established by contract or current legislation.
The User can withdraw their consent to process personal data at any time by sending a notification to the Operator via email at noone.armenia@mail.ru with the subject “Withdrawal of Consent to Process Personal Data.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by these parties (Operators) according to their User Agreement and Privacy Policy. The personal data subject and/or the mentioned documents. The Operator is not responsible for the actions of third parties, including those specified in this section.
8.6. Restrictions imposed by the personal data subject on the transfer (except for access provision), as well as processing or conditions of processing (except for access provision) of personal data authorized for distribution, do not apply in cases of processing personal data for state, public, or other public interests as determined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than required by the purposes of processing personal data, unless a different storage period is established by federal law, contract, or agreement involving the personal data subject.
8.9. The processing of personal data may be terminated upon achieving the processing purposes, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, or a request to cease processing personal data, as well as upon 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 collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transfer of the received information through information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before starting cross-border transfer activities, the Operator must notify the authorized body for the protection of personal data subjects’ rights of their intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, or 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 access to personal data must not 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
12.1. The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at info@noone.am
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://noone.am/privacy/.