1. General Provisions

This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data implemented by GMP Solutions (hereinafter — the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets, to be one of its most important goals and conditions for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://gmp-support.ru/.

2. Basic Terms Used in the Policy2.1. Automated processing of personal data — processing of personal data by means of computer 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, ensuring their availability on the Internet at the web address https://gmp-support.ru/.
2.4. Information system of personal data — a set of personal data contained in databases, and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions resulting in the impossibility of determining, without the use of additional information, whether the personal data belongs to a specific User or another 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 with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or 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 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 that relates directly or indirectly to an identified or identifiable User of the website https://gmp-support.ru/.
2.9. Personal data permitted by the subject of personal data for dissemination — personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of such data for dissemination, in accordance with the procedure established by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://gmp-support.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at acquainting an indefinite number of persons with personal data, including publication of personal data in the media, placement 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 the territory of a foreign state, to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data within the personal data information system and/or the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator 3.1. The Operator has the right to:— receive from the personal data subject accurate information and/or documents containing personal data;
— in case the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing personal data without the consent of the subject if there are legal grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator shall:— provide the personal data subject, upon their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries 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, upon its request, the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— cease the transfer (dissemination, provision, access), 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 Subjects 4.1. Personal data subjects have the right to:— receive information concerning the processing of their personal data, except in cases provided for by federal law. Such information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other subjects, unless there are legal grounds for the disclosure of such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the Operator clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing, and take legal measures to protect their rights;
— set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate such processing;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects shall:— provide the Operator with accurate information about themselves;
— notify the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who have submitted inaccurate information about themselves to the Operator or information about another personal data subject without their consent shall be held liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting such data shall not be permitted.
5.3. It is prohibited to merge databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and scope of the personal data being processed shall correspond to the declared purposes of processing. The processing of personal data that is excessive in relation to the declared purposes of processing shall not be permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, the relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a longer storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or when there is no longer a need to achieve those purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

7. Conditions for the Processing of Personal Data

7.1. Processing of personal data shall be carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary for the achievement of the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of the Operator’s functions, powers, and duties imposed by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. 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 this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data is carried out when access to such data by an unlimited number of persons has been provided by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing of personal data is carried out when such data is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, 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 the current legislation on personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data by third parties.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or when the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address at info@gmp-support.ru with the subject line “Update of Personal Data.”
8.4. The period of processing personal data is determined by the achievement of the purposes for which personal data was collected unless another period is established by a contract or applicable legislation.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 info@gmp-support.ru with the subject line “Withdrawal of Consent to 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 such entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject 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 established by the personal data subject regarding the transfer (other than granting access), processing, or conditions of processing (other than obtaining access) of personal data permitted for dissemination shall not apply in cases where personal data is processed in the public, governmental, or other socially significant interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required for the purposes of processing, unless a longer retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data shall be terminated upon achievement of the purposes of processing, expiration of the consent period, withdrawal of consent by the personal data subject, submission of a request to terminate processing, or discovery of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. 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 processing of personal data, including obtaining and/or transferring the received information through information and telecommunication networks or without such networks.

10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification is submitted separately from the general notification of personal data processing).
10.2. Before submitting the above notification, the Operator must obtain the necessary 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 DataThe Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate 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 may obtain any clarification on matters concerning the processing of their personal data by contacting the Operator via email at info@gmp-support.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://gmp-support.ru/.