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” and establishes the procedure for processing personal data and the measures taken by GIAS LLC (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers respect for human and civil rights and freedoms when processing personal data, including the rights to privacy and to personal and family confidentiality, to be its primary objective and an essential condition for carrying out its activities.
1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://gias-consulting.com.
Key Terms Used in the Policy
2.1. Automated Processing of Personal Data — the processing of personal data using computer technology;
2.2. Blocking of Personal Data — the temporary suspension of the processing of personal data, except where processing is necessary to rectify personal data;
2.3. Website — a collection of graphical and informational materials, together with the computer programs and databases that make them available on the Internet at https://gias-consulting.com;
2.4. Personal Data Information System — a collection of personal data contained in databases, together with the information technologies and technical resources used to process such data;
2.5. De-identification of Personal Data — actions as a result of which personal data cannot be attributed to a specific User or another data subject without the use of additional information;
2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed on personal data, whether by automated means or otherwise, including collection, recording, systematisation, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), de-identification, blocking, deletion and destruction of personal data;
2.7. Operator — a state authority, municipal authority, legal entity or natural person that, independently or jointly with other persons, organises and/or carries out the processing of personal data and determines the purposes of such processing, the personal data to be processed and the actions (operations) to be performed on personal data;
2.8. Personal Data — any information relating directly or indirectly to an identified or identifiable User of the website https://gias-consulting.com;
2.9. User — any visitor to the website hhttps://gias-consulting.com;
2.10. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a defined group of persons;
2.11. Dissemination of Personal Data — any actions aimed at disclosing personal data to an unspecified group of persons (transferring personal data) or making personal data available to an unlimited group of persons, including publishing personal data in the media, posting such data on information and telecommunications networks, or providing access to personal data by any other means;
2.12. Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state, to an authority of that foreign state, a foreign natural person or a foreign legal entity;
2.13. Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore their content in the Personal Data Information System, and/or the destruction of physical media containing personal data.
Personal Data of the User That the Operator May Process
3.1. Surname, first name and patronymic;
3.2. Telephone numbers;
3.3. The website also collects and processes de-identified data about visitors, including cookies, using web analytics services such as Yandex Metrica, Google Analytics and others.
3.4. The data listed above are hereinafter collectively referred to in this Policy as “Personal Data”.
Purposes of Personal Data Processing
4.1. The purpose of processing the User’s personal data is the conclusion, performance and termination of civil-law contracts.
4.2. The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User may opt out of receiving informational messages at any time by sending an email to the Operator at anastasia.flasshoff@gias-consulting.com with the subject line “Unsubscribe from notifications about new products and services and special offers”.
4.3. De-identified User data collected through web analytics services are used to gather information about Users’ activities on the website and to improve the quality of the website and its content.
Legal Grounds for Personal Data Processing
5.1. The Operator processes the User’s personal data only when the User personally enters and/or submits such data through the designated forms available on the website gias-consulting.com. By completing the relevant forms and/or submitting their personal data to the Operator, the User expresses their agreement with this Policy.
5.2. The Operator processes de-identified data about the User where this is permitted by the User’s browser settings, namely where cookie storage and the use of JavaScript are enabled.
Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of the legal, organisational and technical measures necessary to comply fully with the requirements of applicable personal data protection legislation.
6.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorised persons from accessing such data.
6.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases involving compliance with applicable law.
6.3. If inaccuracies in personal data are identified, the User may update such data themselves by sending a notification to the Operator’s email address anastasia.flasshoff@gias-consulting.com with the subject line “Updating personal data”.
6.4. The period for processing personal data is unlimited. The User may withdraw their consent to the processing of personal data at any time by sending an email notification to the Operator at anastasia.flasshoff@gias-consulting.com with the subject line “Withdrawal of consent to the processing of personal data”.
Cross-Border Transfer of Personal Data
7.1. Before commencing any cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data are to be transferred provides reliable protection of the rights of data subjects.
7.2. Cross-border transfers of personal data to the territories of foreign states that do not meet the above requirements may be carried out only where the data subject has provided written consent to the cross-border transfer of their personal data and/or where such transfer is carried out for the performance of a contract to which the data subject is a party.
Final Provisions
8.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator by email at anastasia.flasshoff@gias-consulting.com.
8.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.
8.3. The current version of the Policy is publicly available on the Internet at https://gias-consulting.com/privacy-policy/en.