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Personal data processing policy
1. General terms
This Personal Data Processing Policy is prepared 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 the Law on Personal Data. No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and defines the procedure of personal data processing and measures taken by UPLAND STUDIO (hereinafter referred to as the Operator) to ensure personal data security.
1.1 The Operator sets as its most important goal and condition of its activity the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2 This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the upland.space/ website.
1.1 The Operator sets as its most important goal and condition of its activity the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2 This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the upland.space/ website.
2. Basic terms used
2. Basic concepts used in the Policy
2.1 Automated processing of personal data processing of personal data with the help of computer hardware.
2.2 Blocking of personal data - temporary cessation of personal data processing (with the exception of cases when processing is necessary to clarify personal data).
2.3 The website is a set of graphic and informational materials, as well as computer programs and databases that make them available on the Internet at the network address upland.space/.
2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Personal data depersonalization actions, as a result of which it is impossible to determine without the use of additional information whether personal data belong to a particular User or other subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8 Personal Data - any information relating directly or indirectly to a certain or definable User of the upland.space/ website.
2.9 Personal data authorized by the subject of personal data for dissemination, personal data to which an unlimited number of persons have access by the subject of personal data by giving their consent to processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data authorized for dissemination).
2.10. User - any visitor of the website upland.space/.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Trans-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign government body, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.
2.1 Automated processing of personal data processing of personal data with the help of computer hardware.
2.2 Blocking of personal data - temporary cessation of personal data processing (with the exception of cases when processing is necessary to clarify personal data).
2.3 The website is a set of graphic and informational materials, as well as computer programs and databases that make them available on the Internet at the network address upland.space/.
2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Personal data depersonalization actions, as a result of which it is impossible to determine without the use of additional information whether personal data belong to a particular User or other subject of personal data.
2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.
2.8 Personal Data - any information relating directly or indirectly to a certain or definable User of the upland.space/ website.
2.9 Personal data authorized by the subject of personal data for dissemination, personal data to which an unlimited number of persons have access by the subject of personal data by giving their consent to processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data authorized for dissemination).
2.10. User - any visitor of the website upland.space/.
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Trans-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign government body, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.
3.1 The Operator has the right to:
- Receive reliable information and/or documents containing personal data from the personal data subject;
- in the event that the personal data subject revokes his/her consent to the processing of personal data, the Operator shall have the right to continue processing personal data without the consent of the personal data subject on the grounds specified in the Law on Personal Data;
- determine independently the composition and the list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and normative legal acts adopted in accordance with the Law on Personal Data, unless otherwise stipulated by the Law on Personal Data or other federal laws.
3.2 The Operator shall:
- provide the subject of personal data, upon his request, with information concerning the processing of his/her personal data;
- organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
- respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- inform the authorized body for the protection of the rights of personal data subjects at the request of this body within 30 days from the date of receipt of such request;
- publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
- take legal, organizational and technical measures to protect personal data from unlawful or accidental access to personal data, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
- stop transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases stipulated by the Law on Personal Data;
- perform other duties stipulated by the Personal Data Law.
- Receive reliable information and/or documents containing personal data from the personal data subject;
- in the event that the personal data subject revokes his/her consent to the processing of personal data, the Operator shall have the right to continue processing personal data without the consent of the personal data subject on the grounds specified in the Law on Personal Data;
- determine independently the composition and the list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and normative legal acts adopted in accordance with the Law on Personal Data, unless otherwise stipulated by the Law on Personal Data or other federal laws.
3.2 The Operator shall:
- provide the subject of personal data, upon his request, with information concerning the processing of his/her personal data;
- organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
- respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- inform the authorized body for the protection of the rights of personal data subjects at the request of this body within 30 days from the date of receipt of such request;
- publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
- take legal, organizational and technical measures to protect personal data from unlawful or accidental access to personal data, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
- stop transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases stipulated by the Law on Personal Data;
- perform other duties stipulated by the Personal Data Law.
3. Basic rights and obligations of the Operator
4. Basic rights and obligations of personal data subjects
4.1 Personal data subjects have the right to:
- receive information regarding the processing of their personal data, with the exception of cases stipulated by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases when there are legal grounds for disclosure of such personal data. The list of information and the procedure for its receipt is established by the Law on personal data;
- require from the operator to clarify his personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his rights;
- to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or to the court against unlawful acts or omissions of the Operator in the processing of personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2 The subjects of personal data shall be obliged to:
- provide the Operator with reliable data about themselves;
- notify the Operator about clarification (update, change) of their personal data.
4.3 Persons who have provided the Operator with false information about themselves or about another subject of personal data without the latter's consent shall be held liable in accordance with the laws of the Russian Federation.
- receive information regarding the processing of their personal data, with the exception of cases stipulated by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases when there are legal grounds for disclosure of such personal data. The list of information and the procedure for its receipt is established by the Law on personal data;
- require from the operator to clarify his personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his rights;
- to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or to the court against unlawful acts or omissions of the Operator in the processing of personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2 The subjects of personal data shall be obliged to:
- provide the Operator with reliable data about themselves;
- notify the Operator about clarification (update, change) of their personal data.
4.3 Persons who have provided the Operator with false information about themselves or about another subject of personal data without the latter's consent shall be held liable in accordance with the laws of the Russian Federation.
5.1. Surname, first name, patronymic.
5.2. e-mail address.
5.3. Phone numbers.
5.4 The website also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics, etc.).
5.5 The aforementioned data are hereinafter referred to as Personal Data throughout the text of the Policy.
5.6 The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life.
5.7 The processing of personal data permitted for dissemination from the special categories of personal data specified in part 1 of Article 10 of the Law on Personal Data is allowed if the prohibitions and conditions stipulated in Article 10.1 of the Law on Personal Data are observed.
5.8 The User's consent to the processing of personal data authorized for distribution shall be executed separately from other consents to the processing of his/her personal data. In this case, the conditions stipulated in Article 10.1 of the Law on Personal Data shall be met. The requirements for the content of such consent shall be established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 The User shall provide the Operator with the consent to the processing of personal data authorized for distribution directly.
5.8.2 The Operator is obliged to publish information about the conditions of processing, prohibitions and conditions for processing of personal data allowed for dissemination by an unlimited number of persons within three working days from the moment of receipt of the User's consent.
5.8.3 The transfer (dissemination, provision, access) of personal data authorized by the subject of personal data for dissemination shall be stopped at any time at the request of the subject of personal data. This request shall include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data to be stopped. The personal data specified in this request may be processed only by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data authorized for distribution shall be terminated upon receipt by the Operator of the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
5.2. e-mail address.
5.3. Phone numbers.
5.4 The website also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics, etc.).
5.5 The aforementioned data are hereinafter referred to as Personal Data throughout the text of the Policy.
5.6 The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life.
5.7 The processing of personal data permitted for dissemination from the special categories of personal data specified in part 1 of Article 10 of the Law on Personal Data is allowed if the prohibitions and conditions stipulated in Article 10.1 of the Law on Personal Data are observed.
5.8 The User's consent to the processing of personal data authorized for distribution shall be executed separately from other consents to the processing of his/her personal data. In this case, the conditions stipulated in Article 10.1 of the Law on Personal Data shall be met. The requirements for the content of such consent shall be established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 The User shall provide the Operator with the consent to the processing of personal data authorized for distribution directly.
5.8.2 The Operator is obliged to publish information about the conditions of processing, prohibitions and conditions for processing of personal data allowed for dissemination by an unlimited number of persons within three working days from the moment of receipt of the User's consent.
5.8.3 The transfer (dissemination, provision, access) of personal data authorized by the subject of personal data for dissemination shall be stopped at any time at the request of the subject of personal data. This request shall include the surname, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data to be stopped. The personal data specified in this request may be processed only by the Operator to whom it is sent.
5.8.4 Consent to the processing of personal data authorized for distribution shall be terminated upon receipt by the Operator of the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
5. The Operator may process the following personal data of the User
6. Principles of personal data processing
6.1 The processing of personal data shall be carried out on a lawful and fair basis.
6.2 The processing of personal data shall be limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purpose of personal data collection is not allowed.
6.3 Databases containing personal data processed for incompatible purposes shall not be merged.
6.4 Only personal data that meet the purposes for which they are processed shall be processed.
6.5 The content and scope of personal data processed corresponds to the stated purposes of processing. The personal data processed shall not be redundant in relation to the stated purposes of their processing.
6.6 When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, their relevance to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
6.7 The personal data shall be stored in a form that allows to identify the subject of personal data for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon completion of the purposes of processing or in case of loss of necessity in achieving these purposes, unless otherwise provided for by federal law.
6.1 The processing of personal data shall be carried out on a lawful and fair basis.
6.2 The processing of personal data shall be limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purpose of personal data collection is not allowed.
6.3 Databases containing personal data processed for incompatible purposes shall not be merged.
6.4 Only personal data that meet the purposes for which they are processed shall be processed.
6.5 The content and scope of personal data processed corresponds to the stated purposes of processing. The personal data processed shall not be redundant in relation to the stated purposes of their processing.
6.6 When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, their relevance to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
6.7 The personal data shall be stored in a form that allows to identify the subject of personal data for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon completion of the purposes of processing or in case of loss of necessity in achieving these purposes, unless otherwise provided for by federal law.
6. Principles of personal data processing
7. Purposes of personal data processing
7.1 The purpose of processing the User's personal data:
- informing the User by sending e-mails;
- conclusion, execution and termination of civil law contracts;
- granting the User access to the services, information and/or materials contained on the upland.space/ website.
7.2 The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an e-mail to the Operator at hello@upland.space with the note "Refuse notifications about new products and services, special offers".
7.3 The anonymized data of Users collected through Internet statistics services are used to collect information about Users' actions on the website, to improve the quality of the website and its content.
7.1 The purpose of processing the User's personal data:
- informing the User by sending e-mails;
- conclusion, execution and termination of civil law contracts;
- granting the User access to the services, information and/or materials contained on the upland.space/ website.
7.2 The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an e-mail to the Operator at hello@upland.space with the note "Refuse notifications about new products and services, special offers".
7.3 The anonymized data of Users collected through Internet statistics services are used to collect information about Users' actions on the website, to improve the quality of the website and its content.
7. Purposes of personal data processing
8. Legal bases of personal data processing
8.1 The legal grounds for processing of personal data by the Operator are:
- the Operator's statutory (founding) documents;
- Federal laws, other regulatory legal acts in the sphere of personal data protection;
- Users' consent to the processing of their personal data, to the processing of personal data authorized for distribution.
8.2 The Operator shall process the User's personal data only in the case of their filling in and/or sending by the User through special forms located on the website upland.space/ or sent to the Operator by e-mail. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3 The Operator shall process anonymized data about the User if it is allowed in the User's browser settings (cookies and JavaScript technology enabled).
8.4 The subject of personal data independently decides whether to provide his/her personal data and gives his/her consent freely, of his/her own free will and in his/her own interest.
8.1 The legal grounds for processing of personal data by the Operator are:
- the Operator's statutory (founding) documents;
- Federal laws, other regulatory legal acts in the sphere of personal data protection;
- Users' consent to the processing of their personal data, to the processing of personal data authorized for distribution.
8.2 The Operator shall process the User's personal data only in the case of their filling in and/or sending by the User through special forms located on the website upland.space/ or sent to the Operator by e-mail. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3 The Operator shall process anonymized data about the User if it is allowed in the User's browser settings (cookies and JavaScript technology enabled).
8.4 The subject of personal data independently decides whether to provide his/her personal data and gives his/her consent freely, of his/her own free will and in his/her own interest.
8. Legal basis for personal data processing
9.1 Processing of personal data shall be carried out with the consent of the subject of personal data to the processing of his/her personal data.
9.2 The processing of personal data is necessary for the fulfillment of the purposes provided for by the international treaty of the Russian Federation or by law, for the fulfillment of the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
9.3 Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4 The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5 The processing of personal data is necessary for the exercise of the rights and legal interests of the operator or third parties or for the attainment of socially important goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6 Processing of personal data to which an unlimited number of persons have access by the subject of personal data or at his/her request (hereinafter referred to as publicly available personal data).
9.7 Personal data subject to publication or mandatory disclosure in accordance with the federal law shall be processed.
9.2 The processing of personal data is necessary for the fulfillment of the purposes provided for by the international treaty of the Russian Federation or by law, for the fulfillment of the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
9.3 Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4 The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5 The processing of personal data is necessary for the exercise of the rights and legal interests of the operator or third parties or for the attainment of socially important goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6 Processing of personal data to which an unlimited number of persons have access by the subject of personal data or at his/her request (hereinafter referred to as publicly available personal data).
9.7 Personal data subject to publication or mandatory disclosure in accordance with the federal law shall be processed.
9. Conditions of personal data processing
The security of personal data processed by the Operator shall be ensured by implementing legal, organizational and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.
10.1 The Operator shall ensure the safety of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.
10.2 The User's personal data will never, under no circumstances be transferred to third parties, except in cases related to the fulfillment of the applicable law or in the case when the subject of personal data has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
10.3 If any inaccuracies are found in the personal data, the User may update them independently by sending a notice to the Operator to the Operator's e-mail address hello@upland.space with the note "Personal Data Update".
10.4 The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another term is stipulated by the agreement or the applicable law.
The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address hello@upland.space with the note "Withdrawal of consent to the processing of personal data".
10.5 All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize himself/herself with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
10.6 The prohibitions established by the subject of personal data on the transfer (except for access), as well as on the processing or conditions of processing (except for access) of personal data allowed for dissemination shall not apply in the case of personal data processing in the state, public and other public interests defined by the legislation of the Russian Federation.
10.7 The Operator shall ensure confidentiality of personal data when processing personal data.
10.8 The Operator shall store personal data in a form that allows identification of the subject of personal data for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.
10.9 The condition for termination of 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 consent by the personal data subject, as well as detection of unlawful processing of personal data.
10.1 The Operator shall ensure the safety of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.
10.2 The User's personal data will never, under no circumstances be transferred to third parties, except in cases related to the fulfillment of the applicable law or in the case when the subject of personal data has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
10.3 If any inaccuracies are found in the personal data, the User may update them independently by sending a notice to the Operator to the Operator's e-mail address hello@upland.space with the note "Personal Data Update".
10.4 The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another term is stipulated by the agreement or the applicable law.
The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address hello@upland.space with the note "Withdrawal of consent to the processing of personal data".
10.5 All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize himself/herself with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
10.6 The prohibitions established by the subject of personal data on the transfer (except for access), as well as on the processing or conditions of processing (except for access) of personal data allowed for dissemination shall not apply in the case of personal data processing in the state, public and other public interests defined by the legislation of the Russian Federation.
10.7 The Operator shall ensure confidentiality of personal data when processing personal data.
10.8 The Operator shall store personal data in a form that allows identification of the subject of personal data for no longer than required for the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.
10.9 The condition for termination of 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 consent by the personal data subject, as well as detection of unlawful processing of personal data.
10. Procedure for collection, storage, transfer and other types of personal data processing
11. List of actions performed by the Operator with the personal data received
11. List of actions performed by the Operator with the personal data received
1.1 The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete and destroy personal data.
11.2 The Operator shall perform automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
1.1 The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete and destroy personal data.
11.2 The Operator shall perform automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
12.1 Before commencing transborder transfer of personal data, the Operator shall be obliged to ensure that the foreign state in whose territory the transfer of personal data is to take place ensures reliable protection of the rights of personal data subjects.
12.2 Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only in case of written consent of the personal data subject to the cross-border transfer of his/her personal data and/or fulfillment of an agreement to which the personal data subject is a party.
12.2 Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only in case of written consent of the personal data subject to the cross-border transfer of his/her personal data and/or fulfillment of an agreement to which the personal data subject is a party.
12. Cross-border transfer of personal data
13. Confidentiality of personal data
13.1 The Operator and other persons who have access to personal data shall not disclose to third parties and shall not disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final terms
14.1. The User may obtain any clarifications on any questions concerning the processing of his/her personal data by contacting the Operator via e-mail at hello@upland.space.
14.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at the address upland.space/en/policy.
14.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at the address upland.space/en/policy.