Privacy Policy

This Personal Data Processing Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (Федеральный закон «О персональных данных» от 27.07.2006 №152-ФЗ, hereinafter referred to as the Personal Data Law), and establishes the procedure for processing personal data as well as the measures taken by OOO "DVIP" (ООО «ДВИП», hereinafter referred to as the Operator) to ensure their security.

1.1. The Operator considers the protection of the rights and freedoms of individuals and citizens in the processing of their personal data—including the right to privacy and to personal and family secrecy—to be its utmost priority and a fundamental condition for undertaking its activities.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://mobile.feip.co.

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of processing of personal data (except in cases where such processing is required for clarification of personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases making them available on the internet at the network address https://mobile.feip.co.

2.4. Personal data information system – a set of personal data stored in databases and the information technologies and technical means that process them.

2.5. De-identification of personal data – actions making it impossible to determine the affiliation of personal data to a specific User or other subject of personal data without using 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, modifying), retrieval, use, transfer (distribution, provision, access), de-identification, blocking, deletion, and destruction of personal data.

2.7. Operator – a state authority, municipal authority, legal or natural person who independently or jointly with others organizes and/or processes personal data, and also defines the purposes of 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 relating to a defined or identifiable User of the website https://mobile.feip.co.

2.9. Personal data permitted for dissemination – personal data access to which has been granted by the subject of personal data to an unrestricted circle of persons by giving consent to the processing of personal data permitted for dissemination in the manner defined by the Law on Personal Data (hereinafter referred to as personal data permitted for dissemination).

2.10. User – any visitor to the website https://mobile.feip.co.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data accessible to an unrestricted circle of persons, including publication of personal data in the mass media, posting on information and telecommunication networks, or granting access to personal data in other ways.

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 natural or legal person.

2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the contents of the personal data within the personal data information system and/or destruction of physical carriers of personal data.

3.1. The Operator has the right to:
— Receive reliable information and/or documents containing personal data from the subject of personal data;
— If the subject of personal data withdraws consent for the processing of personal data or submits a request to stop processing 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 provided for in the Personal Data Law;
— Independently determine the scope and list of measures necessary and sufficient to fulfill the obligations stipulated 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 subject of personal data, upon request, with information regarding the processing of his or her personal data;
— Organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— Notify the authorized body for the protection of the rights of personal data subjects, within 10 days of receiving a request from such body, of the necessary information;
— Publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
— Implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, or dissemination of personal data, as well as from other unlawful actions regarding personal data;
— Stop the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the cases and in the manner provided for by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.

4.1. Personal data subjects have the right to:
— Receive information regarding the processing of their personal data, except in cases stipulated by federal laws. Such information shall be provided by the Operator to the subject of personal data in an accessible form and must not contain personal data relating to other personal data subjects, except when there are lawful grounds for disclosing such personal data. The scope of information and the procedure for obtaining it are established by the Personal Data Law;
— Request that the Operator clarify, block, or delete their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not required for the stated processing purposes, and to take legally established measures to protect their rights;
— Set a condition for prior consent when processing personal data for promotional purposes regarding goods, works, or services;
— Withdraw consent for the processing of their personal data and/or demand the cessation of the processing of their personal data;
— Lodge a complaint with the authorized body for the protection of the rights of personal data subjects or with a court regarding unlawful actions or inaction of the Operator in the processing of their personal data;
— Exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:
— Provide the Operator with accurate information about themselves;
— Notify the Operator about any clarification (updating, modification) of their personal data.

4.3. Individuals who have provided the Operator with false information about themselves, or information about another personal data subject without that subject’s consent, shall be held liable in accordance with the legislation of the Russian Federation.

5.1. The processing of personal data shall be carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, pre-defined, 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 processed for incompatible purposes is not permitted.

5.4. Only personal data that correspond to the purposes of their processing shall be processed.

5.5. The content and scope of processed personal data shall 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. Processing of personal data shall ensure the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing. The Operator shall take necessary measures, and/or ensure they are taken, to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than is required for the purposes of processing, unless the storage period is established by federal law or by agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or de-identified upon achieving the purposes of processing or when the necessity for achieving these purposes has been lost, unless otherwise provided by federal law.

Purpose of processing:
To provide the User with access to services, information, and/or materials contained on the website.

Personal data:
Last name, first name, patronymic (if applicable);
Phone numbers.

Legal basis:
The Operator’s statutory (founding) documents.

Types of personal data processing:
Collection, recording, systematization, accumulation, storage, destruction, and de-identification of personal data.

7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his or her 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 by law, for the performance of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority or official, subject to enforcement 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 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. 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 objectives, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing is carried out in relation to personal data to which access by an unlimited number of persons has been granted by the personal data subject or at his or her request (hereinafter referred to as publicly available personal data).

7.7. Processing is carried out in relation to personal data subject to publication or mandatory disclosure in accordance with federal law.

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 on the protection of personal data.

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 required by current legislation or when the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil contract.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator at the Operator’s email address hello@feip.co with the subject line “Updating Personal Data.”

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is established by a contract or by current legislation.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator at the Operator’s email address hello@feip.co with the subject line “Withdrawal of Consent to Personal Data Processing.”

8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreements and Privacy Policy. The personal data subject is encouraged to 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 imposed by the personal 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 as defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data during their processing.

8.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to stop processing personal data, as well as upon identification of unlawful processing of personal data.

9.1. The Operator carries out the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), de-identification, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data, with or without the receipt and/or transfer of the received information via information and telecommunication networks.

10.1. Prior to 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 personal data subjects of its intention to carry out such cross-border transfers (this notification is submitted separately from the notification of intent to process personal data).

10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, as well as from foreign natural persons and legal entities to whom the cross-border transfer of personal data is planned.

The Operator and any other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12.1. The User may obtain any clarifications regarding questions related to the processing of his or her personal data by contacting the Operator via email at hello@feip.co.

12.2. Any changes to this personal data processing policy made by the Operator 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://mobile.feip.co/en/privacy