privacy
policy

1. General Provisions
This personal data processing policy has been prepared in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "DAVAS PRIME" (hereinafter referred to as the Operator).
1.1. The Operator's primary objective and condition for its activities is the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://davasprime.com/eng
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at https://davasprime.com/eng.
2.4. Personal data information system – a collection of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data – actions that make it impossible to determine the ownership of personal data to a specific User or another subject of personal data without additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a state authority, municipal authority, legal or natural person that independently or jointly with others organizes and/or performs the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://davasprime.com/eng
2.9. Personal data authorized by the subject of personal data for dissemination – personal data to which an unlimited number of persons have access, provided by the personal data subject by giving consent for the processing of personal data authorized for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. User – any visitor to the website https://davasprime.com/eng
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, 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. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign natural or legal person. 2.14. Destruction of personal data – any actions that result in the permanent destruction of personal data with no possibility of further recovery in the personal data information system and/or destruction of physical carriers of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
·Receive accurate information and/or documents containing personal data from the personal data subject;
·Continue processing personal data without the consent of the personal data subject in cases provided by the Personal Data Law;
·Independently determine the composition and list of necessary and sufficient measures to ensure the fulfillment of obligations under the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the personal data subject with information regarding the processing of their personal data upon request;
— Organize the processing of personal data in accordance with applicable Russian legislation;
— Respond to inquiries from personal data subjects and their legal representatives in accordance with the Personal Data Law;
— Report necessary information to the authorized body for the protection of personal data subjects' rights upon request within 10 days from the date of receipt of such a request;
— Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as other unlawful actions;
— Stop the processing and destroy personal data in cases and under the procedure stipulated by the Personal Data Law;
— Fulfill other obligations as required by the Personal Data Law.
4. Main 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, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— Request the Operator to clarify, block, or delete their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated processing purpose, as well as take legal measures to protect their rights;
— Set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent for the processing of personal data and submit a request to cease the processing of personal data;
— Appeal to the authorized body for the protection of personal data subjects' rights or to a court against unlawful actions or inaction of the Operator in processing their personal data;
— Exercise other rights provided by Russian law.
4.2. Personal data subjects are obliged to:
— Provide the Operator with accurate data about themselves;
— Notify the Operator of any clarifications (updates, changes) to their personal data.
4.3. Individuals who have provided inaccurate information about themselves to the Operator or have provided information about another personal data subject without their consent bear responsibility in accordance with Russian law.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data that is processed for purposes incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. Excessive processing of personal data relative to the stated purposes is not permitted.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of its processing are ensured. The Operator takes necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the personal data subject no longer than required for the purposes of processing, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or if the necessity to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purpose of Personal Data Processing
Purpose of Processing:
Informing the User by sending emails.
Personal Data:
Surname, first name, patronymic
Email address
Phone numbers
Legal Grounds:
The Operator’s statutory (founding) documents
Types of Personal Data Processing:
Sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties assigned to the Operator by Russian legislation.
7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or an act of another authority or official subject to execution in accordance with Russian legislation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. The processing of personal data is carried out for personal data that is publicly available, to which an unlimited number of persons have been granted access by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data is carried out for personal data that is subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given their consent to the Operator for the transfer of data to a third party for the fulfillment of contractual obligations.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator's email address davasprime@gmail.com with the subject "Personal Data Update."
8.4. The processing period of personal data is determined by achieving the purposes for which the personal data was collected unless another period is provided by contract or applicable law. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at davasprime@gmail.com with the subject "Revocation of Consent for Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for familiarizing themselves with these documents. The Operator is not responsible for the actions of third parties, including service providers mentioned in this section.
8.6. Restrictions imposed by the personal data subject on the transfer (except for granting access) and processing conditions of personal data authorized for dissemination do not apply in cases of processing personal data in state, public, and other public interests as defined by Russian legislation.

8.7. When processing personal data, the Operator ensures the confidentiality of the data.
8.8. The Operator stores personal data in a format that allows the identification of the personal data subject for no longer than necessary to achieve the processing purposes, unless a storage period is established by federal law, a contract to which the personal data subject is a party, a beneficiary, or a guarantor. Personal data that has been processed is destroyed or anonymized upon achieving the processing purposes or if there is no longer a need to achieve those purposes unless otherwise provided by federal law.
8.9. The processing of personal data may be terminated upon achieving the purposes of processing, the expiration of the consent period, the revocation of consent by the personal data subject, a request to cease processing, or the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of received information through information and telecommunication networks or without them.
10. Cross-Border Transfer of Personal Data
10.1. Before beginning cross-border transfers of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfers (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the necessary information from foreign government authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at davasprime@gmail.com
12.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://davasprime.com/privacy_policy_eng.