Policy on the Processing of Personal Data1. General ProvisionsThis personal data processing policy is prepared in accordance with Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the Personal Data Law). It defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Koval Real Estate (hereinafter referred to as the Operator).
1.1. The Operator's main objective and condition for its activities is to respect the rights and freedoms of individuals and citizens during the processing of their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Operator’s personal data processing policy (hereinafter referred to as the Policy) applies to all information the Operator can obtain about visitors of the website https://kovalrealestate.com/en
2. Key Terms Used in the Policy2.1. Automated Processing of Personal Data: Processing personal data using computing technology.
2.2. Blocking of Personal Data: Temporary cessation of personal data processing (except when processing is required to clarify personal data).
2.3. Website: A collection of graphic and informational materials as well as software and databases, ensuring availability on the Internet at the network address https://kovalrealestate.com/en
2.4. Personal Data Information System: A set of personal data contained in databases and the technologies and technical tools used for their processing.
2.5. Anonymization of Personal Data: Actions resulting in the impossibility of determining the ownership of personal data to a specific User or subject without additional information.
2.6. Personal Data Processing: Any operation or set of operations performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator: A state body, municipal body, legal entity, or individual organizing and/or performing personal data processing independently or jointly with others and determining the purposes, scope, and methods of processing personal data.
2.8. Personal Data: Any information directly or indirectly related to an identified or identifiable User of https://kovalrealestate.com/en
2.9. Publicly Available Personal Data: Personal data provided by the subject for dissemination in a manner prescribed by the Personal Data Law.
2.10. User: Any visitor to the website https://kovalrealestate.com/en
2.11. Disclosure of Personal Data: Actions aimed at sharing personal data with a specific person or circle of people.
2.12. Distribution of Personal Data: Actions directed at sharing personal data with an unlimited number of individuals, including through media, Internet, or other means.
2.13. Cross-border Transfer of Personal Data: The transfer of personal data to the territory of a foreign state, foreign public authority, or foreign person.
2.14. Destruction of Personal Data: Actions that irreversibly destroy personal data, making their recovery impossible, including destruction of the media containing such data.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to:- Receive reliable information and/or documents containing personal data from the subject of personal data.
- Continue processing personal data without the consent of the subject in cases stipulated by the Personal Data Law, including when the subject revokes their consent or requests the termination of processing.
- Independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations set forth in the Personal Data Law and other regulatory legal acts, unless otherwise stipulated by the law.
3.2. The Operator is obligated to:- Provide the subject of personal data, upon request, with information regarding the processing of their personal data.
- Organize the processing of personal data in accordance with the requirements of the current legislation of the Russian Federation.
- Respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law.
- Notify the authorized body for the protection of the rights of personal data subjects upon request within 10 days of receiving such a request.
- Publish and ensure unrestricted access to this Policy regarding personal data processing.
- Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, or dissemination, as well as other illegal actions regarding personal data.
- Stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law.
- Fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:- Obtain information regarding the processing of their personal data, except in cases provided for by federal laws. The information must be provided in an accessible form and must not include personal data related to other subjects, unless legally permitted. The list of information and the procedure for obtaining it are defined by the Personal Data Law.
- Request that the Operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, obtained unlawfully, or unnecessary for the stated purposes of processing.
- Condition the processing of personal data for marketing purposes on prior consent.
- Withdraw their consent to the processing of personal data and demand the termination of such processing.
- File complaints with the authorized body for the protection of the rights of personal data subjects or in court against the Operator's unlawful actions or inaction in processing personal data.
- Exercise other rights provided by Russian law.
4.2. Personal data subjects are obligated to:- Provide the Operator with accurate information about themselves.
- Inform the Operator about updates (corrections, changes) to their personal data.
**4.3. Persons who transfer inaccurate information about themselves or information about another subject without their consent are responsible in accordance with Russian law.
5. Principles of Personal Data Processing5.1. The processing of personal data is conducted on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and legitimate objectives.
5.3. Combining databases containing personal data processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meets the purposes of its processing shall be processed.
5.5. The scope and content of processed personal data must correspond to the stated purposes of its processing. Excessive personal data unrelated to the purposes of its processing is not allowed.
5.6. The accuracy, adequacy, and relevance of personal data must be ensured. Measures must be taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than the purposes of its processing require, unless a longer storage period is prescribed by federal law or a contract.
6. Objectives of Personal Data ProcessingThe purpose of personal data processing includes informing Users via email.
Personal Data:- Full name
- Email address
- Phone numbers
Legal Basis:- Operator's founding documents
Types of Processing:- Sending informational emails
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7. Conditions for Processing Personal Data7.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data.
7.2. The processing of personal data is necessary for achieving purposes established by an international treaty of the Russian Federation or by law, for performing functions, powers, and duties imposed on the Operator by legislation.
7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or an act of another authority or official to be executed in accordance with Russian Federation legislation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the subject or a contract under which the subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the Operator or third parties to exercise their rights or legitimate interests or to achieve socially significant objectives, provided this does not violate the rights and freedoms of the subject of personal data.
7.6. The processing of personal data that has been made publicly accessible by the subject of personal data or at their request is carried out in accordance with the Personal Data Law.
7.7. The processing of personal data subject to publication or mandatory disclosure as required by federal law is carried out accordingly.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary for full compliance with applicable legislation on personal data protection.
8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to exclude unauthorized access to it.
8.2. Personal data of the User will never be transferred to third parties under any circumstances, except in cases related to compliance with applicable legislation or if the User has given their consent to the Operator for the transfer of data to a third party for fulfilling contractual obligations.
8.3. If inaccuracies in personal data are detected, the User may update the data themselves by sending a notification to the Operator via email at
kovalproductionco@gmail.com with the subject line "Updating 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 duration is prescribed by contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at
kovalproductionco@gmail.com with the subject line "Withdrawal of Consent for Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreements and Privacy Policies. The subject of personal data must familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions imposed by the subject of personal data on the transfer (other than access provision) or conditions of processing of publicly available personal data do not apply in cases of processing for state, public, or other public interests as defined by Russian Federation legislation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. Personal data is stored in a form that allows identification of the subject for no longer than necessary for processing purposes unless a longer storage period is prescribed by federal law or contract.
8.9. Personal data processing may be terminated upon achieving the processing goals, the expiration of the subject's consent, or at the request of the subject, as well as if illegal processing of personal data is identified.
9. List of Actions Performed by the Operator with Received Personal Data9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated personal data processing with the receipt and/or transmission of received information via telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data10.1. Before starting cross-border transfers of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intention to transfer personal data across borders (this notification is sent separately from the general notification on processing personal data).
10.2. Before sending the above notification, the Operator must obtain the necessary information from the foreign authorities, individuals, or entities to whom the personal data will be transferred.
11. Confidentiality of Personal DataThe Operator and other parties who have gained access to personal data must not disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise required by federal law.
12. Final Provisions12.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at
kovalproductionco@gmail.com.
12.2. Any changes to this Policy will be reflected in this document. The Policy is effective indefinitely until replaced with a new version.
12.3. The current version of the Policy is freely available online at https://kovalrealestate.com/privacy2.