Personal Data Processing Policy
1. General Provisions
This Privacy Policy regarding the processing of personal data has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by MORION NETWORKS (M+ LLC) (hereinafter — the Operator).
1.1. The Operator's utmost goal and condition for carrying out its activities is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's Policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://morion-networks.com.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer software and databases, ensuring their availability on the internet at the network address https://morion-networks.com.
2.4. Personal data information system — a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation means or without such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, 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 the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://morion-networks.com.
2.9. Personal data permitted for dissemination by the data subject — personal data to which access by an unlimited circle of persons has been granted by the data subject by giving consent to the processing of personal data permitted for dissemination by the data subject in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://morion-networks.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publicly disclosing personal data in the media, posting on information and telecommunications 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 individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irrevocably destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
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 data subject;
— if the data subject revokes consent to the processing of personal data or submits a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by 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 data subject, upon their request, with information relating to the processing of their personal data;
— to organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— to respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to provide the authorized body for the protection of the rights of data subjects, upon its request, with the necessary information within 10 days of receiving such request;
— to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions with respect to personal data;
— to cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to perform other duties provided for by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right:
— to receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator to the data subject in an accessible form and shall not contain personal data relating to other data subjects, except where 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;
— to require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— to impose a condition of prior consent when processing personal data for the purpose of marketing goods, works and services;
— to revoke consent to the processing of personal data, as well as to submit a request to cease processing of personal data;
— to appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of any clarification (updating, changes) to their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another data subject without the latter's consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Processing Personal Data
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
5.4. Only personal data that meet the purposes of their processing may be processed.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and where necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achievement of processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Processing Personal Data
Purpose of processing: Informing the User by sending emails.
Personal data: Full name, email address, phone numbers.
Legal basis: Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ dated July 27, 2006.
Types of processing of personal data: Collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data. Sending informational emails to the email address.
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, or to carry out the functions, powers and duties assigned by the legislation of the Russian Federation to the Operator.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for concluding a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. 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 purposes, provided that this does not violate the rights and freedoms of the data subject.
7.6. Processing of personal data to which access by an unlimited circle of persons is provided by the data subject or at their request is carried out (hereinafter — publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of 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 safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator's email address info@morion-networks.com marked "Updating personal data".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by contract or current legislation. The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator's email address info@morion-networks.com marked "Revocation of consent to processing of personal data".
8.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor.
8.9. The termination of processing of personal data may be conditioned upon the achievement of the purposes of processing personal data, expiration of the consent of the data subject, revocation of consent by the data subject or a request to cease processing of personal data, as well as the discovery of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of received information over information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from foreign state authorities, foreign individuals, and 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 gained access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at info@morion-networks.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
This Privacy Policy regarding the processing of personal data has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by MORION NETWORKS (M+ LLC) (hereinafter — the Operator).
1.1. The Operator's utmost goal and condition for carrying out its activities is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's Policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://morion-networks.com.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer software and databases, ensuring their availability on the internet at the network address https://morion-networks.com.
2.4. Personal data information system — a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation means or without such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, 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 the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://morion-networks.com.
2.9. Personal data permitted for dissemination by the data subject — personal data to which access by an unlimited circle of persons has been granted by the data subject by giving consent to the processing of personal data permitted for dissemination by the data subject in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://morion-networks.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publicly disclosing personal data in the media, posting on information and telecommunications 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 individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irrevocably destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.
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 data subject;
— if the data subject revokes consent to the processing of personal data or submits a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by 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 data subject, upon their request, with information relating to the processing of their personal data;
— to organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— to respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to provide the authorized body for the protection of the rights of data subjects, upon its request, with the necessary information within 10 days of receiving such request;
— to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions with respect to personal data;
— to cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to perform other duties provided for by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right:
— to receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator to the data subject in an accessible form and shall not contain personal data relating to other data subjects, except where 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;
— to require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— to impose a condition of prior consent when processing personal data for the purpose of marketing goods, works and services;
— to revoke consent to the processing of personal data, as well as to submit a request to cease processing of personal data;
— to appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of any clarification (updating, changes) to their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another data subject without the latter's consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Processing Personal Data
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
5.4. Only personal data that meet the purposes of their processing may be processed.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and where necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achievement of processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Processing Personal Data
Purpose of processing: Informing the User by sending emails.
Personal data: Full name, email address, phone numbers.
Legal basis: Federal Law "On Information, Information Technologies and Information Protection" No. 149-FZ dated July 27, 2006.
Types of processing of personal data: Collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data. Sending informational emails to the email address.
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, or to carry out the functions, powers and duties assigned by the legislation of the Russian Federation to the Operator.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for concluding a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. 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 purposes, provided that this does not violate the rights and freedoms of the data subject.
7.6. Processing of personal data to which access by an unlimited circle of persons is provided by the data subject or at their request is carried out (hereinafter — publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of 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 safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator's email address info@morion-networks.com marked "Updating personal data".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by contract or current legislation. The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator's email address info@morion-networks.com marked "Revocation of consent to processing of personal data".
8.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the identification of the data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor.
8.9. The termination of processing of personal data may be conditioned upon the achievement of the purposes of processing personal data, expiration of the consent of the data subject, revocation of consent by the data subject or a request to cease processing of personal data, as well as the discovery of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of received information over information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from foreign state authorities, foreign individuals, and 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 gained access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at info@morion-networks.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. 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://morion-networks.com/policy.