Personal Data Processing Policy
- General provisions
This Personal data processing policy is compiled in accordance with the requirements of
Federal Law No. 152-FL of 27.07.2006 “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 Tatjana Hermann (hereinafter referred to as
the Operator).1.1. The operator sets as its most important goal and condition for the
implementation of its activities the observance of the rights and freedoms of man and citizen
in the processing of his 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 referred to as the Policy) applies to all information that the Operator can
receive about website https://hermann-health.com visitors . - Basic concepts 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 termination of processing of personal
data (except in cases where processing is necessary to clarify personal data).2.3. Website –
a set of graphic and informational materials, as well as computer programs and databases
that ensure their availability on the Internet at a network address
https://hermann-health.com.2.4. The personal data information system is a set of personal
data contained in databases, and information technologies and technical means that ensure
their processing.2.5. Depersonalization of personal data — actions as a result of which it is
impossible to determine, without the use of additional information, the identity of personal
data to a specific User or other subject of personal data.2.6. Personal data processing is 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), 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) processing personal data, as
well as determining the purposes of processing personal data, the composition of personal
data to be processed, 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://hermann-health.com.2.9. Personal data authorized by the subject of personal data for
distribution — personal data to which an unlimited number of persons have access by the
subject of personal data by giving consent to the processing of personal data authorized by
the subject of personal data for distribution in accordance with the procedure provided for by
the Law on Personal Data (hereinafter – personal data authorized for distribution).2.10. User
– any visitor to the website https://hermann-health.com.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 circle of persons (transfer of personal data) or familiarization with
personal data of an unlimited circle of persons, including the publication of personal data in
the media, placement in information and telecommunications networks or providing access
to personal data in any other way.2.13. Cross-border transfer of personal data is the transfer
of personal data to the territory of a foreign state to an authority of a foreign state, a foreign
individual or a foreign legal entity.2.14. Destruction of personal data – any actions as a result
of which personal data is permanently destroyed with the impossibility of further restoration
of the content of personal data in the personal data information system and (or) the material
carriers of personal data are destroyed. - Basic rights and obligations of the Operator
3.1. The operator has the right to:- to receive reliable information and /or documents
containing personal data from the subject of personal data;– if the subject of personal data
withdraws consent to the processing of personal data, the Operator has the right to continue
processing personal data without the consent of the subject of personal data if there are
grounds specified in the Law on Personal Data;– independently determine the composition
and list of measures necessary and sufficient to ensure the fulfillment of obligations provided
for by the Law on Personal Data and regulatory legal acts adopted in accordance with it,
unless otherwise provided by the Law on Personal Data or other federal laws.3.2. The
operator is obliged to:- provide the subject of personal data at his request with information
concerning the processing of his personal data; – organize the processing of personal data in
accordance with the procedure established by the current legislation of the Russian
Federation; – respond to applications and requests of personal data subjects and their legal
representatives in accordance with the requirements of the Law on Personal Data;- report to
the authorized body for the protection of the rights of personal data subjects at the request of
this body the necessary information within 30 days from the date of receipt of such a
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 unlawful or accidental access to them, destruction, modification,
blocking, copying, provision, dissemination of personal data, as well as from other unlawful
actions with respect to personal data;– stop transmitting (distributing, providing, accessing)
personal data, stop processing and destroy personal data in the manner and cases provided
for by the Law on Personal Data; – perform other duties provided for by the Law on Personal
Data. - Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:- receive information concerning the processing
of his 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 it should
not contain personal data related to other personal data subjects, except in cases where
there are legitimate grounds for disclosure of such personal data. The list of information and
the procedure for obtaining it is established by the Law on Personal Data; – require the
operator to clarify his personal data, block or destroy them if the personal data are
incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated
purpose of processing, as well as take measures provided by law to protect their rights;- to
put forward the condition of prior consent when processing personal data in order to promote
goods, works and services on the market;- to revoke consent to the processing of personal
data;– to appeal to the authorized body for the protection of the rights of personal data
subjects or in court against illegal actions or inaction of the Operator during the processing of
his personal data– – to exercise other rights provided for by the legislation of the Russian
Federation.4.2. Personal data subjects are obliged to:- provide the Operator with reliable
data about yourself; – inform the Operator about the clarification (updating, modification) of
your personal data.4.3. Persons who have provided the Operator with false information
about themselves or information about another personal data subject without the latter’s
consent are liable in accordance with the legislation of the Russian Federation. - The Operator may process the following personal data of the User
5.1. Surname, first name, patronymic.5.2. Email address.5.3. Phone numbers.5.4. Also on
site is the collection and processing of anonymous data about visitors (including cookies)
using Internet statistics (Yandex Metric and Google Analytics and others).5.5. The above
data, hereinafter referred to in the text of the Policy, are combined by the general concept of
Personal Data.5.6. Processing of special categories of personal data concerning race,
nationality, political views, religious or philosophical beliefs, intimate life is not carried out by
the Operator.5.7. Processing of personal data allowed for distribution from among the
special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law
is allowed if the prohibitions and conditions provided for in Article 10.1 of the Personal Data
Law are observed.5.8. The User’s consent to the processing of personal data allowed for
distribution is issued separately from other consents to the processing of his personal data.
At the same time, the conditions stipulated, in particular, by Article 10.1 of the Law on
Personal Data are observed. The requirements for the content of such consent are
established by the authorized body for the protection of the rights of personal data
subjects.5.8.1 Consent to the processing of personal data authorized for distribution, the
User provides the Operator directly.5.8.2 The Operator is obliged, no later than three
working days from the date of receipt of the User’s consent, to publish information on the
processing conditions, on the existence of prohibitions and conditions for processing by an
unlimited number of persons of personal data allowed for distribution.5.8.3 Transfer
(distribution, provision, access) of personal data authorized by the subject of personal data
for distribution must be terminated at any time at the request of the subject of personal data.
This requirement must include the surname, first name, patronymic (if any), contact
information (phone number, email address or postal address) of the personal data subject,
as well as a list of personal data whose processing is subject to termination. The personal
data specified in this request can only be processed by the Operator to whom it is sent.5.8.4
Consent to the processing of personal data permitted for distribution shall terminate upon
receipt by the Operator of the request specified in clause 5.8.3 of this Policy regarding the
processing of personal data. - Principles of personal data processing
6.1. The processing of personal data is carried out on a legal and fair basis.6.2. The
processing of personal data is limited to the achievement of specific, predetermined and
legitimate goals. Processing of personal data incompatible with the purposes of personal
data collection is not allowed.6.3. It is not allowed to combine databases containing personal
data, the processing of which is carried out for purposes incompatible with each other.6.4.
Only personal data that meet the purposes of their processing are subject to processing.6.5.
The content and volume of the processed personal data correspond to the stated purposes
of processing. Redundancy of the processed personal data in relation to the stated purposes
of their processing is not allowed.6.6. When processing personal data, the accuracy of
personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of
personal data processing is ensured. The Operator takes the necessary measures and/or
ensures that they are taken to delete or clarify incomplete or inaccurate data.6.7. The
storage of personal data is carried out in a form that allows determining the subject of
personal data, no longer than the purposes of personal data processing require, unless the
period of personal data storage is established by federal law, an agreement to which the
subject of personal data is a party, beneficiary or guarantor. The processed personal data is
destroyed or depersonalized upon achievement of the processing goals or in case of loss of
the need to achieve these goals, unless otherwise provided by federal law. - Purposes of personal data processing
7.1. Purpose of processing the User’s personal data:- informing the User by sending emails– - conclusion, execution and termination of civil law contracts; – providing the User with
access to services, information and/or materials contained on the website
https://hermann-health.com.7.2. The Operator also has the right to send notifications to the
User about new products and services, special offers and various events. The User can
always refuse to receive informational messages by sending an email to the Operator
[email protected] marked “Refusal of notifications about new products and
services and special offers”.7.3. Depersonalized User data collected using Internet statistics
services are used to collect information about User actions on the site, improve the quality of
the site and its content. Legal grounds for processing personal data
8.1. The legal grounds for processing personal data by the Operator are:- list the regulatory
legal acts regulating relations related to your activity, for example, if your activity is related to
information technology, in particular with the creation of websites, then here you can specify
the Federal Law “On Information, Information Technologies and Information Protection”
dated 27.07.2006 N 149-FL; – statutory documents of the Operator;- contracts concluded
between the operator and the subject of personal data;- federal laws, other regulatory legal
acts in the field of personal data protection;- Users’ consent to the processing of their
personal data, to the processing of personal data allowed for distribution.8.2. The Operator
processes the User’s personal data only if they are filled in and/or sent by the User
independently through special forms located on the website https://hermann-health.com or
sent to the Operator via e-mail. By filling out the appropriate forms and/or sending their
personal data to the Operator, the User agrees with this Policy.8.3. The Operator processes
depersonalized data about the User if this is allowed in the User’s browser settings (the
saving of cookies and the use of JavaScript technology are enabled).8.4. The subject of
personal data independently decides on the provision of his personal data and gives consent
freely, of his own free will and in his own interest. - Terms of personal data processing
9.1. The processing of personal data is carried out with the consent of the personal data
subject to the processing of his personal data.9.2. The processing of personal data is
necessary to achieve the goals stipulated by an international agreement of the Russian
Federation or a law, to carry out the functions, powers and duties assigned to the operator
by the legislation of the Russian Federation.9.3. The processing of personal data is
necessary for the administration of justice, the execution of a judicial act, an act of another
body or 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 beneficiary or
guarantor, as well as for the conclusion of a contract on the initiative of 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 to exercise the rights and
legitimate interests of the operator or third parties or to achieve socially significant goals,
provided that the rights and freedoms of the personal data subject are not violated.9.6.
Personal data is processed, access to which is granted to an unlimited number of persons
by the subject of personal data or at his request (hereinafter referred to as publicly available
personal data).9.7. Personal data subject to publication or mandatory disclosure in
accordance with federal law is processed. - Procedure for the collection, storage, transfer and other types of personal data
processing
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.10.1. The
Operator ensures the safety of personal data and takes all possible measures to exclude
access to the personal data of unauthorized persons.10.2. 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 subject of personal data has given consent
to the Operator to transfer data to a third party to fulfill obligations under a civil contract.10.3.
In case of identification of inaccuracies in personal data, the User can update them
independently by sending a notification to the Operator to the Operator’s email address
[email protected] marked “Updating of personal data”.10.4. The term of
personal data processing is determined by the achievement of the purposes for which
personal data was collected, unless another term is stipulated by the contract or the current
legislation.The User can withdraw his consent to the processing of personal data at any time
by sending a notification to the Operator via e-mail to the Operator’s e-mail address
[email protected] marked “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 themselves with these
documents in a timely manner. The Operator is not responsible for the actions of third
parties, including the service providers specified in this paragraph.10.6. The prohibitions
established by the subject of personal data on the transfer (except for granting access), as
well as on the processing or processing conditions (except for obtaining access) of personal
data permitted for distribution, do not apply in cases of processing personal data in the state,
public and other public interests defined by the legislation of the Russian Federation.10.7.
When processing personal data, the Operator ensures the confidentiality of personal
data.10.8. The operator stores personal data in a form that allows determining the subject of
personal data, no longer than the purposes of personal data processing require, unless the
period of personal data storage is established by federal law, an agreement to which the
subject of personal data is a party, beneficiary or guarantor.10.9. The condition for the
termination of personal data processing may be the achievement of the purposes of
personal data processing, the expiration of the consent of the personal data subject or the
withdrawal of consent by the personal data subject, as well as the identification of unlawful
processing of personal data. - List of actions performed by the Operator with the received personal data
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates,
changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks,
deletes and destroys personal data.11.2. The Operator performs automated processing of
personal data with or without receiving and/or transmitting the received information via
information and telecommunication networks. - Cross-border transfer of personal data
12.1. Before the start of the cross-border transfer of personal data, the Operator is obliged to
make sure that the foreign state to whose territory the transfer of personal data is supposed
to be carried out provides reliable protection of the rights of personal data subjects.12.2. The
cross-border transfer of personal data on the territory of foreign states that do not meet the
above requirements may be carried out only if the personal data subject has written consent
to the cross-border transfer of his personal data and/or the execution of the contract to which
the personal data subject is a party. - Confidentiality of personal data
The operator and other persons who have gained access to personal data are obliged not to
disclose to third parties and not to distribute personal data without the consent of the subject
of personal data, unless otherwise provided by federal law. - Final provisions
14.1. The User can receive any clarifications on issues of interest concerning the processing
of his personal data by contacting the Operator via e-mail
[email protected] This document will reflect any changes to 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
https://hermann-health.com/privacy-policy .
