Policy on the processing of personal data of the Limited Liability Company "Modern Communications" on the website https://rulet.tv #

(Privacy Policy) #

1. General Provisions #

1.1. This Policy on the processing of personal data (hereinafter referred to as the Policy) has been developed in compliance with the requirements of paragraph 2 of part 1 of article 18.1 of the Federal Law of 27.07.2006 No. 152-FZ "On personal data" (hereinafter referred to as the Law on personal data) in order to ensure the protection of the rights and freedoms of an individual and citizen when processing his personal data.

1.2. The Policy of the Limited Liability Company "Modern Communications" (TIN 9713001074, OGRN 1237700486275) (hereinafter referred to as the Operator) applies to all personal data that the Operator receives through the Internet resource https://rulet.tv, including all levels of the specified domain that are functioning on the date of approval of the Policy, as well as those put into operation during its validity period.

1.3. The Policy applies to the personal data processing relationships that arose with the Operator both before and after the approval of this Policy.

1.4. In compliance with the requirements of Part 2 of Article 18.1 of the Law on Personal Data, this Policy is published in the public domain on the Internet information and telecommunications network at https://rulet.tv , (hereinafter referred to as the Site).

1.5. Key concepts used in the Policy:

• personal data - any information related to a directly or indirectly determined or determinable individual (subject of personal data);
• personal data processing - any action (operation) or set of actions (operations) with personal data performed using automation tools or without their use. Personal data processing includes, among other things: collection; recording; systematization; accumulation; storage; clarification (updating, modification); retrieval; use; transfer (provision, access, distribution); depersonalization; blocking; deletion; destruction of personal data.
• website – a set of computer programs and other information contained in an information system, access to which is provided via the Internet information and telecommunications network under the domain name https://rulet.tv and used by the Operator to inform users about its activities.
• website (service) user – an individual accessing the website (service) https://rulet.tv
  Other terms not disclosed in the Policy are used in the meaning defined in the legislation of the Russian Federation.

1.6. Basic rights and obligations of the Operator.
The Operator has the right to:

• 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;
• in the event of the personal data subject's withdrawal of consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data.
  The Operator is obliged to:
• organize the processing of personal data in accordance with the requirements of the Law on Personal Data;
• respond to requests and inquiries of 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 (the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)) upon request of this body of the necessary information within 10 days from the date of receipt of such request.

1.7. Basic rights of the personal data subject.
The personal data subject has the right to:

• receive information regarding the processing of his 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 it 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 is established by the Law on Personal Data;
• demand that the operator clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights;
• appeal to Roskomnadzor or in court against illegal actions or inaction of the Operator when processing his personal data.
  Other rights and obligations of the Operator and personal data subjects are determined by the legislation of the Russian Federation.

1.8. Control over compliance with the requirements of this Policy is carried out by an authorized person responsible for organizing the processing of personal data by the Operator.

2. Purposes of personal data processing #

2.1. The purposes of personal data processing are determined by the Operator's activities in providing services arising from the use of the Roulette TV service (rulet.tv) https://rulet.tv/, as well as the Operator's activities in the remote sale of goods through the Operator's website.

2.2. Personal data is processed for the purposes specified in Appendix No. 1 of this Policy.

3. Legal grounds for processing personal data #

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

• The Civil Code of the Russian Federation of November 30, 1994 No. 51-FZ;
• user agreement;
• other civil law contracts;
• consent to the processing of personal data.
• Law of the Russian Federation of 07.02.1992 N 2300-1 (as amended on 08.08.2024) “On the Protection of Consumer Rights”

4. Volume and categories of personal data processed, categories of personal data subjects #

4.1. The categories of personal data processed and the categories of personal data subjects are specified in Appendix No. 1 of this Policy.

4.2. The Operator does not process biometric personal data of the categories of subjects specified in Appendix No. 1 of this Policy.

4.3. The Operator does not process special categories of personal data of the categories of subjects specified in Appendix No. 1 of this Policy.

4.4. The Operator does not carry out cross-border transfer of personal data of the categories of subjects specified in Appendix No. 1 of this Policy.

5. Procedure and conditions for processing personal data #

5.1. The Operator processes personal data in accordance with the requirements of the Russian Federation legislation. The Operator ensures compliance with the personal data confidentiality requirements established by Article 7 of the Law on Personal Data. The Operator does not disclose to third parties or distribute personal data without the consent of the personal data subject.

5.2. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, distribution and other unauthorized actions.

Legal measures include:

• development of local regulations and other documents governing relations in the field of processing and protection of personal data;
• compliance with the principles of processing personal data and refusal from methods of processing personal data that do not correspond to the purposes of processing.

Organizational measures include:

• appointment of a person responsible for organizing the processing of personal data;
• regulation of personal data processing processes;
• creation of the necessary conditions for working with personal data;
• organization of accounting of documents containing personal data;
• organization of work with information systems in which personal data is processed;
• identification of threats to the security of personal data during their processing, formation of a threat model on this basis.

Technical measures include:

• ensuring the security of personal data in information systems;
• storing personal data on paper media under conditions that ensure their safety and exclude unauthorized access to them;
• storing personal data in information systems under conditions that ensure their safety and exclude unauthorized access to them (ensuring the security of premises where information systems with personal data are stored, ensuring the safety of media with personal data, protecting information using tools that have undergone a conformity assessment procedure).
• preventing leaks of personal data via technical communication channels and by other means;
• preventing unauthorized access to personal data, special impacts on such information (information media) for the purpose of obtaining, destroying, distorting and blocking access to it;
• protection against malware, detection of intrusions and computer attacks;
• application of measures to identify, investigate and eliminate the consequences of incidents related to the facts of unlawful or accidental transfer (provision, distribution, access) of personal data that resulted in the violation of the rights of personal data subjects, in the manner prescribed by Part 3.1 of Article 21 of the Law on Personal Data.

5.4. The Operator processes personal data using the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, distribution, access), blocking, deletion, destruction of personal data.
The Operator does not disclose personal (private) information about personal data subjects to third parties, except in cases prescribed by Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", or when the personal data subject voluntarily agrees to the transfer of information.

5.5. The Operator carries out both automated and non-automated processing of personal data, and also uses mixed forms of processing.

5.6. The Operator ceases to process personal data in the event of:
achievement of the goals of such processing;
revocation of consent to the processing of personal data;
detection of illegal processing of personal data.
Upon occurrence of the circumstances specified in this clause, personal data are subject to destruction, unless otherwise provided by federal law.

5.7. When collecting personal data, the Operator ensures the recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation. The Operator does not carry out cross-border transfer of personal data.

5.8. The transfer (provision, access) of personal data will be terminated at any time at 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. Sending a request by the personal data subject to the Operator to terminate the transfer of his personal data entails the termination of the processing by the Operator of the personal data in respect of which the subject makes a request to terminate the transfer.

6. Updating, correcting, deleting and destroying personal data, responding to requests from subjects for access to personal data #

6.1. In the event that the fact of inaccuracy of personal data is confirmed, the personal data are subject to clarification.

6.2. The Operator is obliged to inform the subject of personal data about the processing of such subject's personal data upon the latter's request. Confirmation of the fact of personal data processing by the Operator, the legal grounds and purposes of personal data processing, as well as other information specified in Part 7 of Article 14 of the Law on Personal Data, are provided by the Operator to the subject of personal data or his representative upon request or upon receipt of a request from the subject of personal data or his representative.
The information provided does not include personal data related to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data.
The request must contain:

• the number of the main document certifying the identity of the subject of personal data or his representative, information on the date of issue of the said document and the body that issued it;
• information confirming the participation of the personal data subject in relations with the Operator or information otherwise confirming the fact of personal data processing by the Operator;
• signature of the personal data subject or his/her representative.
  The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
  If the personal data subject's request (appeal) does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data or the subject does not have the right to access the requested information, then a reasoned refusal is sent to him/her.
  The right of the personal data subject to access his/her personal data may be limited in accordance with Part 8 of Article 14 of the Law on Personal Data, including if the personal data subject's access to his/her personal data violates the rights and legitimate interests of third parties.

6.3. In the event that inaccurate personal data is detected upon an application by a personal data subject or his/her representative or at their request or at the request of Roskomnadzor, the Operator blocks the personal data related to this personal data subject from the moment of such application or receipt of the said request for the verification period, unless blocking the personal data violates the rights and legitimate interests of the personal data subject or third parties.

In the event that the fact of inaccuracy of personal data is confirmed, the Operator, based on the information provided by the personal data subject or his/her representative or Roskomnadzor, or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes the blocking of the personal data.

6.4. In the event that unlawful processing of personal data is detected upon an application (request) by a personal data subject or his/her representative or Roskomnadzor, the Operator destroys the unlawfully processed personal data related to this personal data subject from the moment of such application or receipt of the request.

6.5. Upon achieving the goals of personal data processing, as well as in the event of the personal data subject's withdrawal of consent to their processing, the occurrence of other grounds provided for in paragraph 5.6 of this Policy, personal data are subject to destruction if:

• The Operator does not have the right to carry out processing without the consent of the personal data subject on the grounds provided for by the Law on Personal Data or other federal laws;
• otherwise not provided for by the agreement between the Operator and the personal data subject.

7. Final Provisions #

7.1. The personal data subject may receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail makamekam@gmail.com

7.2. The provisions of this Policy may be revised by the Operator as necessary. The new version of the Policy is posted on the website with the date of the last update of the Policy.

Appendix No. 1 to the Policy of Sovremennye Kommunikatsii LLC regarding the processing of personal data #

LIST of purposes, methods and terms of processing personal data of Sovremennye Kommunikatsii LLC #