PERSONAL DATA PROCESSING POLICY
1. General
This Personal Data Processing Policy is developed in accordance with the requirements of Federal Law of July 27, 2006. No. 152-FZ “On Personal Data”. It defines the procedure for personal data processing and measures to ensure personal data protection by VZRIYV GROUP LLC (hereinafter the Operator).

  1. The most significant goal and condition of Operator’s activities is to observe human and civil rights and freedoms when processing personal data, protection of rights to personal and family privacy included.
  2. This Operator’s Personal Data Processing Policy (hereinafter the Policy) applies to all information that the Operator may gather about the visitors of its website http://en.vgroup.one.

2. Basic concepts used in the Policy
  1. Automated personal data processing is processing of personal data by means of computer technology;
  2. Blocking of personal data is suspending of personal data processing (except when the processing is necessary to clarify personal data);
  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 http://en.vgroup.one;
  4. Personal data information system is a set of personal data stored in databases, as well as information technology and technical equipment performing its processing;
  5. Depersonalization of personal data means actions that make it impossible to determine, with no additional information, whether the personal data belongs to a particular user or another subject of personal data;
  6. Personal data processing is any action (operation) or a set of actions (operations) performed on personal data with or without use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, destruction of personal data;
  7. Operator is a governmental body, municipal body, legal entity or individual, independently or jointly with others organizing and (or) performing personal data processing, as well as defining the purposes of personal data processing, the composition of personal data to be processed, the actions (operations) performed with personal data;
  8. Personal data means any information related directly or indirectly to a specific or identifiable User of the http://en.vgroup.one;
  9. User is any visitor of the http://en.vgroup.one;
  10. Personal data sharing means actions aimed at disclosing personal data to a certain person or a limited circle of persons;
  11. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited number of persons with the personal data, including publication of personal data in the media, releasing it to information and telecommunication networks or granting access to personal data in any other way;
  12. Cross-border transfer of personal data is transfer of personal data to the territory of a foreign country to an authority of a foreign state, a foreign individual or a foreign legal entity;
  13. Destruction of personal data means any actions that result in personal data irretrievable destruction without the possibility to further restore the content of personal data in the personal data information system and (or) lead to personal data material media destruction.

3. The Operator can process the following personal data of the User
  1. Name, surname, patrimony (if applicable);
  2. Email address;
  3. Phone numbers;
  4. The site also collects and processes impersonal data of the visitors (including cookies) using Internet statistics services (Yandex Metrika, Google Analytics, etc.).
  5. The abovementioned data is incorporated in a general concept of Personal data further on in the text of the Policy.

4. Purposes of personal data processing
  1. The purpose of User’s personal data processing is to render information to the User through phone calls or emails.
  2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at office@vgroup.one
  3. Impersonal User data collected through Internet statistical services are used to collect information about Users’ actions on the site, to improve the quality of the site and its content.

5. Legal grounds for personal data processing
  1. The operator processes only the personal data that was filled in and/or sent by the User himself/herself through special forms located on the site http://en.vgroup.one. By filling in the relevant forms and/or sending their personal data to the Operator the User expresses his/her compliance with this Policy.
  2. The Operator processes anonymized User’s data if it is allowed in the User’s browser settings (saving cookies and using JavaScript technology are enabled).

6. Collection, storage, transferring and other types of personal data processing procedure
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully meet the requirements of applicable laws regarding personal data protection.
1. The Operator ensures the safekeeping of personal data and takes all measures possible to prevent access of unauthorized persons to personal data.
2. The User’s personal data will under no circumstances be disclosed to third parties, except for situations related to applicable law execution.
3. If the User detects any inaccuracies in personal data, he/she can update it independently by sending a notice to the Operator’s e-mail address office@vgroup.one marked “Updating of personal data”.
4. The term for personal data processing is unlimited. The User may withdraw his/her consent to the personal data processing at any moment by sending an e-mail to the Operator’s e-mail address office@vgroup.one marked “Withdrawal of consent to personal data processing”.

7. Cross-border transfer of personal data
  1. Before starting the cross-border personal data transfer the Operator must ensure that the foreign state to whose territory the transfer of personal data is to be performed provides reliable protection of the rights of personal data subjects.
  2. Cross-border transfer of personal data to foreign countries that do not meet the abovementioned requirements can be performed only with written consent of the personal data subject regarding the cross-border transfer of his/her personal data and/or execution of the contract to which the subject of personal data is a party.

8. Final provisions
  1. The User can receive any clarifications on points of interest regarding the processing of his/her personal data by contacting the Operator via e-mail office@vgroup.one.
  2. This document will reflect any changes to the Operator’s Personal Data Processing Policy. The Policy is valid indefinitely until replaced by a new revision.
  3. The current revision of the Policy is freely available on the Internet at http://en.vgroup.one/personal-data-processing-policy.