Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy (hereinafter referred to as the "Policy") has been prepared in accordance with Federal Law No. 152-FZ dated July 27, 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 undertaken by Cappuccino Estate (hereinafter referred to as the "Operator").
1.1. The Operator considers its most important objective and condition for conducting its activities to be the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy, personal and family confidentiality.
1.2. This Policy applies to all information that the Operator may obtain about visitors of the website https://cappuccino-estate.com/.
2. Key Terms Used in This Policy
2.1. Automated processing of personal data — processing of personal data using computing equipment.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is required to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://cappuccino-estate.com/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical tools that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine the ownership of personal data by a specific User or other 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), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a government body, municipal authority, legal or natural person that independently or jointly organizes and/or performs the processing of personal data, as well as determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to an identified or identifiable User of the website https://cappuccino-estate.com/.
2.9. Personal data authorized by the subject for dissemination — personal data made publicly available by the data subject by giving consent for their processing for dissemination in accordance with the Personal Data Law (hereinafter referred to as "data authorized for dissemination").
2.10. User — any visitor of the website https://cappuccino-estate.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a defined group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons or providing access to personal data, including publication in the media, placement in information and telecommunication networks, or access in any other manner.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data making further restoration of personal data content in the information system impossible and/or physical destruction of personal data storage media.ё
3. Operator’s Rights and Obligations
3.1. The Operator has the right to:
– receive accurate information and/or documents containing personal data from the data subject;
– continue processing personal data without the consent of the data subject in cases provided by the Personal Data Law, even after the withdrawal of consent or a request to stop processing;
– independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law, unless otherwise provided by law.
3.2. The Operator is obliged to:
– provide the data subject, upon request, with information regarding the processing of their personal data;
– organize the processing of personal data in accordance with the laws of the Russian Federation;
– respond to requests from data subjects and their legal representatives in accordance with the Personal Data Law;
– provide the authorized data protection authority with the required information within 10 days of receiving such a request;
– publish or otherwise ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, and other unauthorized actions;
– stop data transmission, processing, and destroy personal data as prescribed by law;
– fulfill other obligations stipulated by the Personal Data Law.
4. 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 as provided by federal law. This information shall be provided in an accessible form and must not contain personal data relating to other individuals unless there are legal grounds for such disclosure;
– request the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing;
– request prior consent for the use of their personal data for marketing purposes;
– withdraw consent to the processing of personal data and request termination of its processing;
– file complaints with the authorized data protection authority or in court regarding unlawful actions or inactions of the Operator;
– exercise other rights provided by Russian law.
4.2. Personal data subjects must:
– provide accurate information about themselves to the Operator;
– inform the Operator of any updates or changes to their personal data.
4.3. Individuals who provide the Operator with inaccurate information or data about another person without proper consent are liable under the laws of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing is carried out lawfully and fairly.
5.2. Processing is limited to achieving specific, predefined, and lawful purposes.
5.3. Processing of personal data incompatible with the stated purposes is not allowed.
5.4. Only personal data that meets the purpose of processing is processed.
5.5. The scope of processed data must be relevant and not excessive.
5.6. Personal data must be accurate, sufficient, and, where necessary, up to date. The Operator must take measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data must not be stored longer than necessary for processing purposes unless otherwise required by federal law or contract. Once the purposes are achieved or become unnecessary, the data must be deleted or depersonalized unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose:
To establish and maintain communication with the User, process inquiries, provide consultation and information about real estate properties, and facilitate the sale of the Operator’s services, including remotely.
Personal Data Processed:
– Full name
– Email address
– Phone number(s)
– Country of residence
Legal Grounds:
Contracts concluded between the Operator and the data subject.
Types of Processing:
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
7. Conditions for processing personal data
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, and to fulfill the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a court decision, or an act of another authority or official subject to enforcement under the legislation of the Russian Federation 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 entering into a contract initiated by the personal data subject or a contract under which the 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 the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data that has been made accessible to an unlimited number of persons by the data subject or at their request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8 .Procedures 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 comply fully with the requirements of applicable 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 access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or when the data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the email address info@cappuccino-estate.com with the note "Updating personal data".
8.4. The processing period for personal data is determined by achieving the purposes for which the personal data was collected, unless another period is provided for by contract or applicable law.
8.5. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at info@cappuccino-estate.com with the subject “Withdrawal of consent to the processing of personal data”.
8.6. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreements and Privacy Policies. The data subject agrees with these conditions by accepting the terms of use of the respective services.
8.7. The Operator is not responsible for the actions of third parties, including service providers or partners, to whom the User independently provides personal data.
8.8. The prohibitions established by the data subject on the transfer (except granting access), as well as on the processing or conditions of processing (except for gaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by Russian legislation.
8.9. The Operator ensures the confidentiality of personal data when processing it.
8.10. The Operator stores personal data in a form that allows identification of the data subject no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor.
8.11. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, expiration of the data subject’s consent, withdrawal of consent by the data subject, or a demand to cease personal data processing, as well as the detection of unlawful processing of personal data.
9. List of actions performed by the Operator with received personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with or without receiving it via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state, to which the personal data is to be transferred, provides reliable protection of the rights of personal data subjects.
10.2. The cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out if there is written consent from the personal data subject to the cross-border transfer of their personal data and/or the execution of an agreement to which the personal data subject is a party.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute the 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 clarification on questions regarding the processing of their personal data by contacting the Operator via email at info@cappuccino-estate.com.
12.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy remains valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://cappuccino-estate.com/privacy_eng.
This Personal Data Processing Policy (hereinafter referred to as the "Policy") has been prepared in accordance with Federal Law No. 152-FZ dated July 27, 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 undertaken by Cappuccino Estate (hereinafter referred to as the "Operator").
1.1. The Operator considers its most important objective and condition for conducting its activities to be the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy, personal and family confidentiality.
1.2. This Policy applies to all information that the Operator may obtain about visitors of the website https://cappuccino-estate.com/.
2. Key Terms Used in This Policy
2.1. Automated processing of personal data — processing of personal data using computing equipment.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is required to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://cappuccino-estate.com/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical tools that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine the ownership of personal data by a specific User or other 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), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a government body, municipal authority, legal or natural person that independently or jointly organizes and/or performs the processing of personal data, as well as determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to an identified or identifiable User of the website https://cappuccino-estate.com/.
2.9. Personal data authorized by the subject for dissemination — personal data made publicly available by the data subject by giving consent for their processing for dissemination in accordance with the Personal Data Law (hereinafter referred to as "data authorized for dissemination").
2.10. User — any visitor of the website https://cappuccino-estate.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a defined group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons or providing access to personal data, including publication in the media, placement in information and telecommunication networks, or access in any other manner.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data making further restoration of personal data content in the information system impossible and/or physical destruction of personal data storage media.ё
3. Operator’s Rights and Obligations
3.1. The Operator has the right to:
– receive accurate information and/or documents containing personal data from the data subject;
– continue processing personal data without the consent of the data subject in cases provided by the Personal Data Law, even after the withdrawal of consent or a request to stop processing;
– independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law, unless otherwise provided by law.
3.2. The Operator is obliged to:
– provide the data subject, upon request, with information regarding the processing of their personal data;
– organize the processing of personal data in accordance with the laws of the Russian Federation;
– respond to requests from data subjects and their legal representatives in accordance with the Personal Data Law;
– provide the authorized data protection authority with the required information within 10 days of receiving such a request;
– publish or otherwise ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, and other unauthorized actions;
– stop data transmission, processing, and destroy personal data as prescribed by law;
– fulfill other obligations stipulated by the Personal Data Law.
4. 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 as provided by federal law. This information shall be provided in an accessible form and must not contain personal data relating to other individuals unless there are legal grounds for such disclosure;
– request the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing;
– request prior consent for the use of their personal data for marketing purposes;
– withdraw consent to the processing of personal data and request termination of its processing;
– file complaints with the authorized data protection authority or in court regarding unlawful actions or inactions of the Operator;
– exercise other rights provided by Russian law.
4.2. Personal data subjects must:
– provide accurate information about themselves to the Operator;
– inform the Operator of any updates or changes to their personal data.
4.3. Individuals who provide the Operator with inaccurate information or data about another person without proper consent are liable under the laws of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing is carried out lawfully and fairly.
5.2. Processing is limited to achieving specific, predefined, and lawful purposes.
5.3. Processing of personal data incompatible with the stated purposes is not allowed.
5.4. Only personal data that meets the purpose of processing is processed.
5.5. The scope of processed data must be relevant and not excessive.
5.6. Personal data must be accurate, sufficient, and, where necessary, up to date. The Operator must take measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data must not be stored longer than necessary for processing purposes unless otherwise required by federal law or contract. Once the purposes are achieved or become unnecessary, the data must be deleted or depersonalized unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose:
To establish and maintain communication with the User, process inquiries, provide consultation and information about real estate properties, and facilitate the sale of the Operator’s services, including remotely.
Personal Data Processed:
– Full name
– Email address
– Phone number(s)
– Country of residence
Legal Grounds:
Contracts concluded between the Operator and the data subject.
Types of Processing:
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
7. Conditions for processing personal data
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, and to fulfill the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a court decision, or an act of another authority or official subject to enforcement under the legislation of the Russian Federation 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 entering into a contract initiated by the personal data subject or a contract under which the 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 the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data that has been made accessible to an unlimited number of persons by the data subject or at their request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8 .Procedures 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 comply fully with the requirements of applicable 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 access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or when the data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the email address info@cappuccino-estate.com with the note "Updating personal data".
8.4. The processing period for personal data is determined by achieving the purposes for which the personal data was collected, unless another period is provided for by contract or applicable law.
8.5. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at info@cappuccino-estate.com with the subject “Withdrawal of consent to the processing of personal data”.
8.6. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreements and Privacy Policies. The data subject agrees with these conditions by accepting the terms of use of the respective services.
8.7. The Operator is not responsible for the actions of third parties, including service providers or partners, to whom the User independently provides personal data.
8.8. The prohibitions established by the data subject on the transfer (except granting access), as well as on the processing or conditions of processing (except for gaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by Russian legislation.
8.9. The Operator ensures the confidentiality of personal data when processing it.
8.10. The Operator stores personal data in a form that allows identification of the data subject no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, an agreement to which the data subject is a party, beneficiary, or guarantor.
8.11. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, expiration of the data subject’s consent, withdrawal of consent by the data subject, or a demand to cease personal data processing, as well as the detection of unlawful processing of personal data.
9. List of actions performed by the Operator with received personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with or without receiving it via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state, to which the personal data is to be transferred, provides reliable protection of the rights of personal data subjects.
10.2. The cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out if there is written consent from the personal data subject to the cross-border transfer of their personal data and/or the execution of an agreement to which the personal data subject is a party.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute the 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 clarification on questions regarding the processing of their personal data by contacting the Operator via email at info@cappuccino-estate.com.
12.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy remains valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://cappuccino-estate.com/privacy_eng.
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cappuccinoestate@gmail.com
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