General Terms

Your privacy is important to us. Nixys’ policy of processing personal data (hereinafter – the Policy) involves respecting your confidentiality regarding any information we may collect from you on our website.

This policy outlines the order of processing of personal data and security measures of personal data of LLC Nixys (hereinafter – Operator) with the purpose of protecting the rights and freedoms of a person and citizen while processing his personal data.

The following basic terms are used in the Policy:

• Automated processing of personal data – processing of personal data by means of computer equipment;
• Blocking of personal data – temporary termination of personal data processing (except for cases when processing is necessary to clarify personal data);
• Information system of personal data – a set of personal data contained in databases of personal data and information technologies and technical means ensuring its processing;
• Depersonalization of personal data – actions, as a result of which it is impossible to determine without the use of additional information what personal data belongs to a particular personal data subject;
• Processing of personal data – any action (operation) or a set of actions (operations), performed with or without the use of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data
• Operator – a state body, municipal authority, legal entity or individual, independently or together with other persons, organizing and (or) carrying out the processing of personal data, as well as defining the purpose of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
• Personal data – any information related to directly or indirectly identified or defined by an individual (personal data subject);
• Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
• Distribution of personal data – actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or to familiarize an unlimited circle of persons with personal data, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way;
• Transboundary transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign authority, a foreign individual or a foreign legal entity;
• Destruction of personal data – actions, as a result of which it is impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

2. The methods and terms of personal information processing

2.1. The principles of personal data processing

Principles of processing personal data Processing of PDs by the Operator is carried out on the basis of the following principles:

• legality and fair basis; 

• restricting the processing of PDs by achieving specific, predefined and legitimate objectives; 

• processing only those PDs that meet the objectives of their processing; 

• avoiding pooling databases containing PD, processing of which is carried out for purposes incompatible with each other; 

• conformity of the content and volume of processed PD to the stated processing objectives; 

• ensuring the accuracy, adequacy and relevance of PD in relation to the objectives of processing PD; 

• destroying or depersonalizing PD upon reaching the objectives of their processing, or in case of a loss of the need to achieve these goals, if the Operator can not eliminate the violations of the PD

2.2. Conditions for processing personal data

The operator performs the processing of the PD if at least one of the following conditions exists:

• Processing of the PD is performed with the consent of PDS to process its PD; 

• Processing of PD is necessary to achieve the objectives by the Operator; 

• Processing of the PD is necessary to achieve the objectives stipulated by the laws of the Russian Federation for performance and completing the functions, duties and responsibilities entrusted to the Operator;

• Processing of the PD is necessary to implement a contract the party of which, beneficiary or guarantee of which is a PD subject and to make a contract on PD subject’s initiative, or a contract according to which the PD subject will be a beneficiary or guarantee;

• Processing of PD is necessary to implement 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 PDS are not thereby violated

• PD is processed with the access of an unlimited group of persons provided by the PD subject or on his/her request (hereinafter referred to as personal data made public by the personal data subject).

• The obligation to provide proof of the receipt of the consent of the PDS to the processing of his PD is vested in the Operator.

2.3. Confidentiality of personal data

The operator and other persons who have access to personal data must not disclose to third parties or disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.

2.4. Publicly available sources of personal data

In order to provide information, the Operator can create public sources of personal data of subjects, including directories and address books. In the public sources of personal data with the written consent of the subject may include his surname, name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data reported by the subject of personal data

Information about the subject must be deleted at any time from the publicly available sources of personal data at the request of the entity or by decision of the court or other authorized state bodies.

2.5. Special categories of personal data

The processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life is allowed in cases where:

• The subject of personal data has given his consent in writing to the processing of his personal data;
• Personal data is made publicly available by the subject of personal data;
• The processing of personal data is carried out in accordance with generally accepted legislative norms.
• The processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of others and obtaining the consent of the personal data subject is impossible;
• The processing of personal data carried out in medical and preventive purposes, to establish a medical diagnosis, the provision of medical and health-social services, provided that the processing of personal data carried out by a person professionally engaged in medical activities and must;
• The processing of personal data is necessary to establish or implement the rights of the subject of personal data or third parties, as well as in connection with the implementation of justice;
• Processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, with insurance legislation.
• Processing of special categories of personal data must be immediately terminated if the reasons for their processing are eliminated, unless otherwise provided by federal law.
• The processing of personal data on the criminal record can be carried out by the Operator only in cases and in the manner determined in accordance with federal laws.

2.6. Biometric personal data

Information that characterizes the physiological and biological characteristics of a person on the basis of which it is possible to establish his identity — biometric personal data — can be processed by the Operator only if there is consent in writing to the subject.

2.7. Ordering the processing of personal data to another person

The operator has the right to entrust the processing of personal data to another person with the consent of the personal data subject based on a contract concluded with that person. The entity processing personal data on behalf of the Operator is obligated to adhere to the principles and rules of personal data processing.

2.8. Cross-border transfer of personal data

The operator is obliged to make sure that the foreign state, into whose territory it is intended to transfer personal data, provides adequate protection of the rights of subjects of personal data, before the commencement of such transfer.

Transboundary transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data may be carried out in the following cases:

• the consent in writing of the subject of personal data to the cross-border transfer of his personal data;
• the performance of a contract to which the subject of personal data is a party.

3. Rights of the personal data subject

3.1. Consent of the subject of personal data to the processing of his personal data

The subject of personal data decides to provide his personal data and agrees to their processing freely, his will and in his interest. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form that allows to confirm the fact of its receipt, unless otherwise provided by federal law.

Obligation to provide evidence of the consent of the subject of personal data to the processing of his personal data is vested in the Operator.

3.2. Rights of the subject of personal data

The subject of personal data has the right to receive information from the Operator concerning the processing of his personal data, if such right is not restricted in accordance with federal laws. The data subject has the right to require the Operator to verify his personal data, blocking or destroying it in case personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights .

Processing of personal data in order to promote goods, works, services on the market by making direct contacts with potential consumers by means of communication, as well as for political agitation is allowed only with the prior consent of the subject of personal data. 

This processing of personal data is recognized to be carried out without the prior consent of the subject of personal data, unless the Operator proves that such consent has been received.

The operator must immediately stop, at the request of the personal data subject, the processing of his personal data for the above purposes.

It is prohibited to make decisions based solely on the automated processing of personal data that generate legal consequences with respect to the subject of personal data or otherwise affect his rights and legitimate interests, with the exception of cases provided for by federal laws or with the consent of the personal data subject in writing.

If the personal data subject considers that the Operator carries out the processing of his personal data violating his rights and freedoms, the subject of personal data has the right to appeal against the actions or omissions of the Operator to the Authorized body for the protection of the rights of subjects of personal data or in court .

The subject of personal data has the right to protect their rights and legitimate interests, including compensation for damages and (or) compensation for moral harm in the courts.

4. Safety of personal data

The safety of personal data processed by the Operator is provided by the implementation of legal, organizational and technical measures necessary to ensure the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

• appointment of officials responsible for organizing the processing and protection of personal data;
• restriction of the composition of persons having access to personal data;
• familiarization of subjects with the requirements of the federal legislation and regulatory documents of the Operator for the processing and protection of personal data;
• organization of accounting, storage and circulation of information carriers;
• the definition of threats to the security of personal data during processing, the formation of threat models on their basis;
• the development on the basis of the threat model of the personal data protection system;
• checking the readiness and effectiveness of using information protection tools;
• the delineation of users’ access to information resources and software and hardware processing facilities;
• registration and recording of actions of users of information systems of personal data;
• the use of antivirus and means of restoring the protection of personal data;
• application of firewall, intrusion detection, security analysis and cryptographic protection of information in necessary cases;
• the organization of an access regime to the territory of the Operator, the protection of premises with technical means for processing personal data.

5. Final provisions

Officials of the Operator who are guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.