Personal Data Processing Policy

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter, the Personal Data Law) and determines the procedure for processing personal data and the measures to ensure the security of personal data taken by Olga Pavlovna Korenkova (hereinafter, the Operator).

1.1. The Operator regards the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and to personal and family secrecy, as its most important goal and as a condition of its activities.

1.2. This Operator's policy on the processing of personal data (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website http://bankrufeast.ru.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data — processing of personal data by means of computer technology.

2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address http://bankrufeast.ru.

2.4. Personal data information system — the totality of personal data contained in databases and the information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belong to a 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, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data and determines the purposes of processing, the composition of the personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website http://bankrufeast.ru.

2.9. Personal data authorized by the personal data subject for distribution — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized for distribution in the manner prescribed by the Personal Data Law (hereinafter, personal data authorized for distribution).

2.10. User — any visitor to the website http://bankrufeast.ru.

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

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making an unlimited number of persons familiar with personal data, including publication in the mass 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 — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed, making it impossible to restore the content of personal data in the personal data information system, and/or as a result of which the physical media containing personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— if the personal data subject withdraws consent to the processing of personal data or sends a request to stop processing personal data, continue processing personal data without the consent of the personal data subject where grounds specified in the Personal Data Law exist;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for 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 is obliged to:
— provide the personal data subject, at their request, with information concerning the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, at its request, with the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy on 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 or distribution of personal data, as well as from other unlawful actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform other obligations provided for by the Personal Data Law.

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 in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and take the measures provided by law 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 send a request to stop processing personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their 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;
— inform the Operator of any clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without that person's consent, bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data shall be processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

5.3. Merging databases containing personal data that is processed for purposes incompatible with each other is not permitted.

5.4. Only personal data that meet the purposes of their processing shall be processed.

5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessiveness of the processed personal data in relation to the stated purposes of their processing is not permitted.

5.6. When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, their relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that makes it possible to identify the personal data subject, for no longer than the purposes of processing require, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or when there is no longer a need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of processing personal data


7. Conditions for processing personal data

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.

7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, the enforcement of a judicial act, or an act of another body 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 concluding a contract at the initiative of 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 exercising the rights and legitimate interests of the operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request is processed (hereinafter, publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for the collection, storage, transfer and other types of processing of personal data

The security of personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where 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 e-mail address OPKorenkova@sberbank.ru marked "Updating personal data".

8.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by e-mail to the Operator's e-mail address OPKorenkova@sberbank.ru marked "Withdrawal of consent to the processing of personal data".

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

8.6. The prohibitions established by the personal data subject on transfer (other than granting access), as well as on processing or conditions of processing (other than obtaining access) of personal data authorized for distribution, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject, for no longer than the purposes of processing require, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.

8.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing, expiry of the personal data subject's consent, withdrawal of consent by the personal data subject or a demand to stop processing personal data, as well as the identification of unlawful processing of personal data.

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

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained over information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before starting cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to obtain from the authorities of the foreign state, foreign individuals and foreign legal entities to which cross-border transfer of personal data is planned, the relevant information.

11. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or distribute it 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 questions regarding the processing of their personal data by contacting the Operator by e-mail OPKorenkova@sberbank.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 replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://bankrufeast.ru/soglasie-en.