Personal data processing policy

1. General. This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 On Personal Data and sets forth the personal data processing procedure of actions to be taken by LLC Avalon Estate (further – the Operator) to ensure personal data security.

1.1. The most important goal and precondition for the Operator's business activities is respect for each individual's civil rights and freedoms in the processing of their personal data, including the right to to personal and family privacy.

1.2. This Operator's personal data processing policy (further – the Policy) applies to any information which the Operator may receive in respect of the website https://avalon-estate.ru visitors.

2. Main terms used in the Policy. 2.1 Automatic processing of personal data means personal data processing by the use of computers;

2.2. Personal data blocking means the temporary suspension of personal data processing (unless such processing is required for the clarification of personal data);

2.3. Website means a combination of graphical and informational resources, as well as the software and databases needed to ensure their accessibility on the Internet at: https://avalon-estate.ru;

2.4. Personal data information system means a combination of the personal data contained in databases and the information technologies and equipment used for their processing;

2.5. Personal data depersonalization means actions whereupon it is impossible to identify personal data belonging to a specific User or other personal data owner without using any additional information;

2.6. Personal data processing means any action (operation) or combination of actions (operations) performed with or without the use of automatic means involving personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, revision), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, removal and/or destruction of personal data;

2.7. Operator means a governmental authority, municipal body, legal entity or individual, independently or jointly with other persons organizing processing and/or processing personal data, as well as defining the objectives of personal data processing, the contents of personal data subject to processing, the actions (operations) performed with personal data;

2.8. Personal data means any information directly or indirectly relating to an identified or identifiable User of the website https://avalon-estate.ru;

2.9. User means any visitor to the website https://avalon-estate.ru;

2.10. Provision of personal data means actions aimed at disclosing personal data to a certain person or specific range of persons;

2.11. Distribution of personal data means any actions aimed at disclosing personal data to the general public (transfer of personal data) or at familiarizing the general public with personal data, including the publishing of personal data in the mass media, its posting in information and telecommunication networks or providing access to personal data by any other means;

2.12. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual or foreign legal entity;

2.13. Destruction of personal data means any actions resulting in the irreparable destruction of personal data without any further possibility of the recovery of the personal data contents in the personal data information system, and/or the destruction of tangible media containing personal data.

3. The Operator may process the User's personal data as follows: 3.1. Surname, name, patronymic;

3.2. E-mail;

3.3. Phone numbers;

3.4. The website also collects and processes depersonalized visitor data (including by cookies) by means of Internet statistics services (Yandex Metrics and Google Analytics, etc.).

3.5. The above data are hereinafter referred to as Personal Data.

4. Personal data processing objective. 4.1. The objectives of User personal data processing include notification of the User by e-mail; the signing, execution and termination of service agreements, provision of the User's access to the services, information and/or materials contained in the website.

4.2. The Operator may also send notices to the User on new products and services, special offers and various events. The User may always refuse receiving such notices by sending an e-mail to the Operator to info@avalon-estate.ru entitled "Waiver of notices on new products, services and special offers."

4.3. Depersonalized User data collected by means of Internet statistics are used for the collection of information on the User's actions on the website, improvement of website quality and contents.

5. Legal grounds for personal data processing. 5.1. The Operator will process the User's personal data only when the User fills them in and/or sends them independently via special templates available at website: https://avalon-estate.ru. By filling-in the respective templates and/or sending his/her personal data to the Operator, the User acknowledges this Policy.

5.2. The Operator will process the depersonalized User data when it is permitted in the User's browser settings (cookies and use of JavaScript are allowed).

6. Procedure for personal data collection, storage, transfer and other types of processing. The security of the personal data processed by the Operator is maintained through the legal, organizational and technical arrangements necessary to ensure full compliance with the statutory requirements relating to the protection of personal data.

6.1. The Operator shall ensure the security of personal data and make its best efforts to prevent the access of unauthorized persons to personal data.

6.2. Under no circumstances shall the User's personal data be provided by any means whatsoever to any third parties, except where required to ensure compliance with applicable law.

6.3. If any inaccuracies in personal data are identified, the User may update them independently by sending the respective notice to the Operator's e-mail: info@avalon-estate.ru entitled "Personal data updating."

6.4. The period of personal data processing is unlimited. The User may at any time waive his/her consent to personal data processing by sending the respective notice to the Operator's e-mail: info@avalon-estate.ru entitled "Waiver of consent to personal data processing."

7. Cross-border transfer of personal data. 7.1. Prior to the cross-border transfer of personal data, the Operator will make sure that the foreign state into whose territory the personal data are to be transferred makes provisions for the reliable protection of personal data owner rights.

7.2. The cross-border transfer of personal data into the territory of foreign states that do not comply with the above requirements may only take place provided the written consent of the personal data owner to the cross-border transfer of his/her personal data and/or execution of the respective contract to which the personal data owner is a party.

8. Concluding provisions. 8.1. The User is entitled to receive clarifications on any of his/her concerns regarding the processing of his/her personal data by addressing the Operator by e-mail: info@avalon-estate.ru.

8.2. This document will reflect any changes made by the Operator in its personal data processing policy. The Policy will remain in effect for an indefinite term until replaced by a new version.

8.3. The latest version of the Policy is available at the website: https://avalon-estate.ru/privacy.