Data Processing Policy

1. General provisions
This personal data processing policy is drawn up in accordance with the requirements of the Federal Law from 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "Alpha Marketing"(hereinafter - the Operator).
1.1. The operator sets as its most important goal and condition for the performance of its activities respect for the rights and freedoms of a person 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 Personal Data Processing Policy (the "Policy") applies to all information that the Operator may obtain about visitors to the website https://bulksmm.com/.

2. Key concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer equipment.
2.2. Blocking of personal data - temporary termination of processing of personal data (except if processing is necessary to clarify personal data).
2.3. The website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at a network address https://bulksmm.com/.
2.4. Personal data information system is a set of personal data contained in databases and providing their processing of information technologies and technical means.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a particular User or another subject of personal data.
2.6. Personal data processing - any action (operation) or a set of actions (operations) performed using automation means or without the use of such means 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, a municipal body, a legal entity or a natural person organizing and/or performing personal data processing independently or jointly with other persons, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal Data - any information relating directly or indirectly to a specific or defined Website User https://bulksmm.com/.
2.9. Personal data allowed by the personal data subject for distribution - personal data, access of an unlimited number of persons to which is provided by the personal data subject by giving consent to the processing of personal data allowed by the personal data subject for distribution in the manner provided for by the Law on Personal Data (hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://bulksmm.com/.
2.11. Provision of personal data - actions aimed at revealing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at revealing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing with personal data of an unlimited circle of persons, including the publication of personal data in the mass media, posting in information and telecommunication networks or providing access to personal data in some other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to an authority of a foreign state, to a foreign natural or foreign legal person.
2.14. Destruction of personal data - any actions as a result of which personal data is irretrievably destroyed with the inability to further restore the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3. 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 personal data subject;
- in case of revocation by the personal data subject of consent to personal data processing, the Operator has the right to continue processing personal data without the consent of the personal 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 the fulfillment of the obligations stipulated 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 shall:
- provide the personal data subject at his request with information relating to 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 requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- to inform the authorized body for protection of 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;
- publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
- take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
- perform other duties stipulated by the Personal Data Act.

4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- Obtain information relating to the processing of his personal data, except as provided by federal laws. The information shall be provided to the personal data subject by the Operator in accessible form and shall not contain personal data related to other personal data subjects, unless there are legal grounds for disclosure of such personal data. The list of information and the procedure for its receipt is established by the Law on Personal Data;
- require the operator to clarify his personal data, block or destroy it if the personal data is incomplete, obsolete, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights;
- to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
- to withdraw consent to personal data processing;
- to appeal to the authorized body for protection of rights of personal data subjects or in court against unlawful actions or omissions of the Operator in processing his personal data;
- to exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
- provide the Operator with reliable data about himself;
- inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who transfer to the Operator inaccurate information about themselves or information about another personal data subject without the consent of the latter are liable in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User
5.1. Last name, first name, patronymic;
5.2. Phone number;
5.3. E-mail address;
5.4. Also, the site collects and processes impersonal data about visitors (including cookies) using Internet statistics services (Yandex Metrics and Google Analytics and others).
5.5. The above-mentioned data in the text of the Policy are combined by the general concept of Personal Data.
5.6. The Operator shall not process special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data allowed for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data is allowed if the prohibitions and conditions stipulated in Art. 10.1 of the Law on Personal Data are observed.
5.8. The User's consent to the processing of personal data allowed for distribution shall be drawn up separately from other consents to the processing of his personal data. At the same time, the conditions stipulated, in particular, by Art. 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 processing of personal data allowed for distribution by the User shall be granted to the Operator directly.
5.8.2. The Operator shall publish information on processing conditions, prohibitions and conditions for processing personal data allowed for distribution by an unlimited number of persons within three working days after receipt of the User's consent.
5.8.3. The transfer (distribution, provision, access) of personal data authorized by the personal data subject for distribution shall be terminated at any time at the request of the personal data subject. This requirement shall include the name, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data, the processing of which is subject to termination. Personal data specified in this requirement may be processed only by the Operator to whom it is directed.
5.8.4. Consent to processing of personal data allowed for distribution shall cease to be valid from the moment the Operator receives the requirement specified in Clause 5.8.3 of this Policy regarding personal data processing.

6. Principles of Personal Data Processing

6.1. Personal data processing 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. Personal data processing incompatible with the purpose of personal data collection is not allowed.
6.3. Databases containing personal data that are processed for incompatible purposes cannot be merged.
6.4. Only personal data that meets the purposes of processing is subject to processing.
6.5. Content and scope of processed personal data correspond to declared purposes of processing. Redundancy of processed personal data with respect to declared purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data is ensured, their sufficiency, and, if necessary, relevance to the purposes of personal data processing. The operator shall take the necessary measures and/or ensure that they are taken to delete or refine incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the goals of personal data processing require, if the period of storage of personal data is not established by federal law, by a contract to which the beneficiary or guarantor is a personal data subject. Personal data processed shall be destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of the necessity to achieve these goals, unless otherwise provided by federal law.

7. Personal Data Processing Objectives
7.1. Purpose of User personal data processing:
- informing the User by sending e-mails;
- Conclusion, execution and termination of civil contracts;
- providing the User with access to the services, information and/or materials contained on the website https://bulksmm.com/;
- clarification of order parts.
7.2. The Operator also has the right to notify the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending the Operator a letter to the e-mail address [email protected] marked "Refusal to notify of new products and services and special offers."
7.3. The non-personal data of Users, collected using Internet statistics services, are used to collect information about the actions of Users on the site, improve the quality of the site and its content.

8. Legal basis of personal data processing
8.1. The legal grounds for processing personal data by the Operator are:
- list the regulations governing the relations related to your activities, for example, if your activities are related to information technologies, in particular to the creation of sites, here you can specify the Federal Law "On Information, Information Technologies and on the Protection of Information" from 27.07.2006 N 149-FZ;
- the Operator's statutory documents;
- contracts concluded between the operator and the personal data subject;
- federal laws, other regulatory acts in the field of personal data protection;
- consent of Users to processing of their personal data, to processing of personal data allowed for distribution.
8.2. The Operator processes the personal data of the User only if it is filled out and/or sent by the User by itself through special forms located on the https://bulksmm.com/ website or sent to the Operator by electronic mail. By completing the relevant forms and/or sending its personal data to the Operator, the User expresses its consent to this Policy.
8.3. The Operator processes impersonal data about the User in case it is allowed in the settings of the User's browser (saving cookies and using JavaScript technology are enabled).
8.4. The personal data subject independently decides to provide his personal data and gives consent freely, by his will and in his interest.

9. Personal Data Processing Terms
9.1. Personal data processing is carried out with the consent of the personal data subject to the processing of his personal data.
9.2. Processing of personal data is necessary to achieve the goals stipulated by the international agreement of the Russian Federation or by law, to fulfill the functions, powers and duties assigned by the legislation of the Russian Federation to the operator.
9.3. Processing of personal data is necessary for the implementation of justice, 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. Personal data processing is necessary for the execution of an agreement to which either the beneficiary or guarantor is a personal data subject, as well as for the conclusion of an agreement on the initiative of a personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5. Processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Personal data is processed, access of an unlimited number of persons to which is provided by the personal data subject or at his request (hereinafter - publicly available personal data).
9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

10. Procedure for collection, storage, transfer and other types of personal data processing
The security of personal data, which is processed by the Operator, is ensured through the implementation of legal, organizational and technical measures necessary to fully fulfill the requirements of the current legislation in the field of personal data protection.
10.1. The operator ensures the security of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
10.2. The personal data of the User will never, under any conditions, be transferred to third parties, except in cases related to the implementation of the current legislation or if the personal 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.
10.3. In case of identification of inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the Operator's e-mail address [email protected] marked "Personal Data Updating."
10.4. The term for processing personal data is determined by achieving the goals for which personal data were collected, if another period is not provided for by the contract or current legislation.
The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator by 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, shall be stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The Personal Data Subject and/or the User shall be obliged to familiarize themselves with these documents in a timely manner. The Operator shall not be liable for the actions of third parties, including service providers specified in this clause.
10.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions for processing (except for obtaining access) personal data allowed for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
10.7. The Operator shall ensure confidentiality of personal data when processing personal data.
10.8. The operator shall store personal data in a form that allows determining the subject of personal data no longer than the purpose of personal data processing requires, if the term of personal data storage is not established by federal law, by a contract to which the personal data subject is a party, beneficiary or guarantor.
10.9. The condition for termination of personal data processing may be achievement of goals of personal data processing, expiration of the term of consent of the personal data subject or withdrawal of consent by the personal data subject, as well as identification of illegal personal data processing.

11. List of actions performed by the Operator with received personal data
11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
11.2. Operator performs automated processing of personal data with receipt and/or transfer of received information via information and telecommunication networks or without it.

12. Cross-border transfer of personal data
12.1. The operator must ensure that the rights of personal data subjects are securely protected by the foreign state to whose territory personal data is supposed to be transferred before the beginning of the cross-border transfer of personal data.
12.2. Cross-border transfer of personal data in the territory of foreign countries that do not meet the above requirements can be carried out only if there is written consent of the personal data subject to cross-border transfer of his personal data and/or execution of the contract to which the personal data subject is a party.

13. Privacy 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 personal data subject, unless otherwise provided by federal law.
14. Final provisions
14.1. The User may obtain any clarifications concerning the processing of his personal data by contacting the Operator by e-mail [email protected]
14.2. 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://bulksmm.com/privacy/.



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