Personal data processing policy
1. General provisions
This personal data processing policy has been made in accordance with the requirements of the Federal Law dated July 27, 2006 No. 152-FZ ‘On Personal Data’ (hereinafter referred to as the Law on Personal Data) and sets the procedure for processing personal data and measures to ensure the security of personal data taken by De Novo Group LLC (hereinafter referred to as the Operator).
1.1. As its most important goal and condition for the implementation of its activities, the Operator sets the observance of the rights and freedoms of the person and the citizen when processing their personal data, including the protection of the rights to privacy of personal and family life.
1.2. This Operator’s policy for personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://bowlwow.com/
2. Basic definitions used in the Policy
2.1. Automated personal data processing is processing of personal data using computer technologies.
2.2. Blocking of personal data is a temporary suspension of the personal data processing (unless the processing is necessary to rectify personal data).
2.3. Website is a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the web address https://bowlwow.com/
2.4. Personal data information system is a set of personal data contained in databases, and information technologies & technical means that ensure their processing.
2.5. Depersonalization of personal data means actions leading to impossibility to determine the ownership of personal data by a specific User or other personal data subject without the use of additional information.
2.6. Personal data processing is any action (operation) or a set of actions (operations) done with or without the use of automation tools to personal data, including collection, recording, systematization, accumulation, storage, rectification (updating, changing), extraction, use, transfer (distribution, assignation, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator is a state body, municipal authority, legal entity or individual, independently or jointly with other parties organizing and (or) carrying out personal data processing, as well as determining the purposes of personal data processing, the composition of personal data to be processed, the actions (operations) done to personal data.
2.8. Personal data is any information relating directly or indirectly to a specific or identifiable User of the website https://bowlwow.com/
2.9. Personal data permitted by the personal data subject for dissemination means personal data, access to which for an unlimited number of persons is given by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as the personal data permitted for distribution).
2.10. User means any visitor to the website https://bowlwow.com/
2.11. Personal data provision means actions aimed at disclosing personal data to a certain person or a certain scope of persons.
2.12. Personal data distribution means any actions aimed at disclosing personal data to an indefinite scope of persons (transfer of personal data) or familiarizing with personal data of an unlimited scope of persons, including the disclosure 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 is the 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 means any actions leading to irretrievable elimination of personal data with no impossibility of further restoration of personal data content in the personal data information system, and (or) leading to physical carriers of personal data being destroyed.
3. Main rights and obligations of the Operator
3.1. The Operator is entitled to:
- receive reliable information and/or documents containing personal data from the personal data subject;
- in case the personal data subject withdraws consent to personal data processing, the Operator has the right to keep processing personal data without the consent of the personal data subject if there are legal grounds for that specified in the Law on Personal Data;
- independently determine the list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator shall:
- provide the personal data subject, at their request, with information regarding the processing of their personal data;
- arrange the personal data processing in the manner set by the current legislation of the Russian Federation;
- respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the terms of the Law on Personal Data;
- report to a body authorized for the protection of the personal data subjects’ rights, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;
- publish or otherwise provide unrestricted access to this personal data processing policy;
- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision or distribution, as well as from other illegal actions related to personal data;
- stop the transfer (distribution, provision, or access) of personal data, and stop processing and destroy personal data in the manner and in cases provided for by the Law on Personal Data;
- perform other duties set by the Law on Personal Data.
4. Main rights and obligations of the personal data subjects
4.1. Personal data subjects are entitled to:
- receive information regarding the processing of their personal data, except as otherwise provided by federal laws. The information is provided to the personal data subject by the Operator in an intelligible form, and it should not contain personal data related to other personal data subjects, unless there are legal grounds for disclosing such personal data. The necessary information and the procedure for obtaining it is set by the Law on Personal Data;
- demand that the operator rectify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or unnecessary for the stated purpose of processing, and take legal measures to protect their rights;
- stipulate that there must be a prior consent when processing personal data in order to promote goods, works and services on the market;
- withdraw consent to personal data processing;
- appeal to a body authorized for the protection of the personal data subjects’ rights or appeal through the courts against illegal actions or inaction of the Operator when processing their personal data;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
- provide the Operator with correct information about themselves;
- notify the Operator about rectifications (updates, changes) of their personal data.
4.3. Those who have provided the Operator with false information about themselves or provided information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.
5. The Operator is entitled to process the following personal data of the User
5.1. Full name.
5.2. E-mail address.
5.3. Phone numbers.
5.4. Year, month, date and place of birth.
5.5. The website also collects and processes anonymous data about its visitors (including ‘cookies’) using Internet statistics services (Yandex Metrika, Google Analytics and others).
5.6. The above data is hereinafter referred to as ‘Personal data’ in general.
5.7. The Operator shall not process any special types of personal data relating to race, nationality, political views, religious or philosophical beliefs, and intimate life.
5.8. Processing of personal data permitted for distribution and belonging to special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is allowed if the prohibitions and terms provided for in Art. 10.1 of the Personal Data Law are met.
5.9. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to personal data processing. At the same time, the conditions provided for, in particular, in Art. 10.1 of the Law on Personal Data, shall be complied with. Requirements for the details of such consent are set by a body authorized for the protection of the personal data subjects’ rights.
5.9.1 The User shall directly provide the Operator with the consent to the processing of personal data permitted for distribution.
5.9.2 The Operator shall, no later than three business days after the date of receipt of the specified consent of the User, publish information on the conditions of processing, on the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.
5.9.3 The transfer (distribution, provision, access) of personal data authorized by the personal data subject must be terminated at any time at the request of the latter. This request should include the full name, contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as the list of personal data, the processing of which is to be stopped. The personal data specified in this request may be processed only by the Operator the request has been sent to.
5.9.4 Consent to the processing of personal data permitted for distribution shall be deemed terminated at the moment the Operator receives the request specified in clause 5.9.3 of this Policy regarding personal data processing.
6. Principles of personal data processing
6.1. The processing of personal data is carried out fairly and lawfully.
6.2. Personal data processing is limited to the achievement of specific, predetermined and lawful purposes. It is prohibited to process personal data that is incompatible with the purposes of personal data collection.
6.3. It is prohibited to integrate databases that contain personal data processed for purposes that are incompatible with each other.
6.4. Only personal data that meet the relevant purposes of their processing may be processed.
6.5. The content and scope of the processed personal data correspond to the declared purposes of processing. No redundancy of the processed personal data in relation to the declared purposes of their processing is allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and (if necessary) relevance in relation to the purposes of personal data processing, are ensured. The Operator takes the required measures and/or ensures their taking in order to remove or rectify incomplete or inaccurate data.
6.7. Personal data are stored in a form that allows identifying the personal data subject, no longer than it is required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, or an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or in case of loss of the need to achieve such purposes, unless otherwise provided by federal law.
7. Purposes of personal data processing
7.1. The purpose of processing the User's personal data:
- informing the User by sending e-mails;
- providing the User with access to the services, information and/or materials contained on the website https://bowlwow.com/
7.2. The Operator is also entitled to send notifications to the User about new products and services, special offers and various events. The User can refuse to receive informational messages at any time by sending an email to the Operator at email@example.com marked with ‘Refuse to receive notifications about new products and services and special offers’.
7.3. Anonymized data of Users collected via Internet statistics services are used to gather information about the Users’ actions on the website, as well as improve the website quality and content.
8. Legal grounds for personal data processing
8.1. These are the legal grounds for the personal data to be processed by the Operator:
- Федеральный закон "Об информации, информационных технологиях и о защите информации" от 27.07.2006 N 149-ФЗ
- Operator’s constitutional documents;
- agreements concluded between the Operator and the personal data subject;
- federal laws and other regulations related to personal data protection;
- Users' consent to the processing of their personal data, and to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently via special forms on the website https://bowlwow.com/ or sent to the Operator by e-mail. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.4. The personal data subject independently decides on the provision of their personal data and gives consent freely, willingly and in their own interest.
9. Conditions for personal data processing
9.1. The personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is required to achieve the purposes provided for by an international treaty of the Russian Federation or the law, in order to carry out the Operator’s functions, powers and obligations set by the legislation of the Russian Federation.
9.3. The processing of personal data is required for the administration of justice, the execution of a court judgment, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation concerning enforcement proceedings.
9.4. The processing of personal data is required for the performance of an agreement to which the personal data subject is a party or beneficiary or guarantor, as well as to conclude an agreement at the instigation of the personal data subject or an agreement to which the personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is required to exercise the rights and to respect the legitimate interests of the Operator or third parties, or to achieve publicly significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6. The Operator shall process those personal data the access to which for an unlimited number of persons is provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. The Operator shall process those personal data that are subject to publication or mandatory disclosure in accordance with federal laws.
10. Collection, storage, transfer and other types of personal data processing
The security of personal data that are processed by the Operator is ensured through the implementation of legal, organizational and technical measures required to fully comply with the terms and provisions of the current legislation related to personal data protection.
10.1. The Operator ensures the safety of personal data and makes every effort to prevent unauthorized persons from accessing personal data.
10.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable legislation or if the personal data subject has given their consent to the Operator to transfer data to a third party in order to fulfill their obligations under a civil contract.
10.3. In case some inaccurate personal data have been detected, the User may rectify them independently by sending a notification to the Operator’s email address firstname.lastname@example.org marked with ‘Updating personal data’.
10.4. The term for the personal data processing is determined by the achievement of the purposes for which the personal data have been collected, unless a different term is provided by the contract or applicable law. The User may at any time withdraw their consent to the personal data processing by sending a notification to the Operator’s email address email@example.com marked ‘Withdrawal of consent to the personal data processing’.
10.6. The prohibitions set by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in any state or public interests determined by the legislation of the Russian Federation.
10.7. The Operator ensures the confidentiality of personal data when processing them.
10.8. The Operator shall store personal data in a form that allows identifying the personal data subject, no longer than it is required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, or an agreement to which the personal data subject is a party, beneficiary or guarantor.
10.9. The possible conditions for terminating the personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject’s consent or withdrawal of such consent by the personal data subject, as well as the detection of unlawful processing of personal data.
11. List of actions Operator performs to the obtained personal data
11.1. The Operator collects, records, systematizes, accumulates, stores, rectifies (updates or changes), extracts, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes and destroys personal data.
11.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information via data telecommunication networks or without it.
12. Cross-border transfer of personal data
12.1. Before starting a cross-border transfer of personal data, the Operator shall make sure that the foreign state to whose territory the personal data are going to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the abovementioned requirements can be carried out only if there is a written consent of the personal data subject to the cross-border transfer of their personal data and/or in case of execution of an agreement to which the personal data subject is a party.
13. Privacy of personal data
The Operator and other parties who have gained access to personal data must not disclose nor distribute such personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
14.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via e-mail firstname.lastname@example.org
14.2. This document will reflect any changes in the Operator’s personal data processing policy. The Policy remains in force indefinitely until it is replaced by a new version.
14.3. The most up-to-date version of the Policy is freely available on the website https://bowlwow.com/en/policy/