Personal Data Policy of PDT Clinic LLC

1. General Provisions

This personal data policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-ФЗ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by PDT Clinic LLC (hereinafter referred to as the Operator).

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

1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://laserterapy.ru/.

2. Basic concepts of the Policy

2.1. Automated processing of personal data is the processing of personal data using computer technology.

2.2. Blocking of personal data is the temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).

2.3. Website is a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://laserterapy.ru/.
2.4. Personal data information system is a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data is the set of actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data.

2.6. Personal data processing is any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.

2.7. Operator is a government agency, municipal agency, 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.

2.8. Personal data is any information directly or indirectly related to a specific or determinable User of the website https://laserterapy.ru/.

2.9. Personal data permitted for distribution by the subject of personal data is personal data, access to which by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).

2.10. User is any visitor to the website https://laserterapy.ru/.

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

2.12. Dissemination of personal data is any set of actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including disclosure of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data is a transfer of personal data to the territory of a foreign state to a government body of a foreign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data is any set of actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the destruction of tangible media of personal data.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:

– receive reliable information and/or documents containing personal data from the personal data subject;

– continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data in the event of the personal data subject's withdrawal of consent to the processing of personal data;

– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

– provide the personal data subject, at his/her request, with information concerning 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 inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

– notify the authorized body for the protection of the rights of personal data subjects, at the request of this body, of the necessary information within 30 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 to them, 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 processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;

– perform other duties stipulated by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

– receive information concerning the processing of their personal data, except for cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and must not contain personal data related to other personal data subjects, except for 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 Law on Personal Data;

– demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures stipulated 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;

– revoke consent to the processing of personal data;

– appeal to the authorized body for the protection of the rights of personal data subjects or in court against the 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;

– notify the Operator about clarification (update, change) of their personal data.

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

5. The Operator may process the following personal data of the User:

5.1. Last name, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. Year, month, date and place of birth.

5.5. Photographs.

5.6. The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica, Google Analytics and others).

5.7. The above data are hereinafter referred to as Personal Data.

5.8. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.9. The processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is permitted if the prohibitions and conditions stipulated by Article 10.1 of the Law on Personal Data are observed.

5.10. The User's consent to the processing of personal data permitted for distribution is drawn up separately from other consents to the processing of his/her personal data. In this case, the conditions stipulated by Article 10.1 of the Law on Personal Data are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.10.1 The User provides the Operator with consent to the processing of personal data permitted for distribution directly in writing.

5.10.2 The transfer (distribution, provision, access) of personal data permitted for distribution by the personal data subject must be terminated at any time upon the request of the personal data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is sent.

5.10.3 Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in Paragraph 5.10.2 of the Personal Data Policy.

6. Principles of personal data processing

6.1. Personal data is processed on a lawful and fair basis.

6.2. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

6.3. Combining databases containing personal data that are processed for purposes that are incompatible with each other is not allowed.

6.4. Only personal data that meet the purposes of their processing may be processed.

6.5. The content and volume of the processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, 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.

6.7. Personal data shall be stored in a form that allows the subject of personal data to be identified, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. Purpose of processing the User's personal data:

– informing the User by sending emails;

– concluding, executing and terminating civil contracts;

– providing the User with access to services, information and/or materials contained on the website https://laserterapy.ru/.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always opt out of receiving informational messages by sending the Operator an email to laserterapy@bk.ru with the subject line "Opt-out of notifications about new products and services and special offers".

7.3. Anonymized User data collected using Internet statistics services is used to collect information about the Users' actions on the website, improve the quality of the website and its content.

8. Legal grounds for personal data processing

8.1. The legal grounds for the personal data processing by the Operator are:

– the statutory (founding) documents of the Operator;

– federal laws, other regulatory legal acts in the field of personal data protection;

– the consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution;

– local documents of the Operator regarding its personal data policy.

8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://laserterapy.ru/ or sent to the Operator by e-mail. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to the Policy.

8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (the storage of cookies and the use of JavaScript technology are enabled).

8.4. The subject of personal data independently decides on the provision of his/her personal data and gives consent freely, of his/her own free will and in his/her own interests.

9. Terms of personal data processing

9.1. Personal data is processed with the consent of the subject of personal data to the processing of his/her personal data.

9.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

9.3. 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.

9.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary to exercise 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.

9.6. The processing of personal data is carried out, access to which by an unlimited number of persons is provided by the personal data subject or at his/her request (hereinafter referred to as publicly available personal data).

9.7. The processing of personal data is carried out that is subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for collecting, storing, transferring 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 comply with the requirements of current legislation in the field of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

10.2. 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 subject of personal data has given the Operator consent to the transfer of data to a third party for the fulfillment of obligations under a civil law contract.

10.3. In the event that inaccuracies are detected in personal data, the User can update them independently by sending the Operator a notification to the Operator's e-mail address laserterapy@bk.ru with the subject line “Updating personal data”.

10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation.

The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator's e-mail address laserterapy@bk.ru with the subject line “Revocation of consent to the personal data processing”.

10.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently and promptly familiarize themselves with the said documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.

10.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.

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

10.8. The operator shall store personal data in a form that allows the identification of the subject of personal data for no longer than required by the purposes of processing the personal data, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.

10.9. The condition for termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the detection of unlawful processing of personal data.

11. List of actions performed by the Operator with the received personal data:

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.

12. Cross-border transfer of personal data

12.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is supposed to be transferred ensures reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent from the personal data subject to the cross-border transfer of his/her personal data and/or execution of an agreement to which the personal data subject is a party.

13. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final provisions

14.1. The User can receive any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator by e-mail laserterapy@bk.ru.

14.2. This document will reflect any changes to the Operator's personal data policy. The Policy is valid indefinitely until it is replaced by a new version.

14.3. The current version of the Policy is available on the Internet at https://laserterapy.ru/en/privacy.