1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of 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 taken by LLC "Optima" (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals when processing their personal data, including the protection of the rights to privacy, personal, and family secrets, as its most important goal and condition for carrying out its activities.
1.2. This Operator's policy regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may obtain about visitors to the website https://tk-optima.com/en-optima.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology means.
2.2. Blocking of personal data - temporary cessation 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 providing their availability on the Internet at the network address https://tk-optima.com/en-optima.
2.4. Personal data information system - a set of personal data contained in databases and providing their processing by information technologies and technical means.
2.5. Depersonalization of personal data - actions that result in the impossibility of determining the belonging 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 a set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or natural person, acting alone or jointly with other persons, organizing and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://tk-optima.com/en-optima.
2.9. Personal data allowed by the subject of personal data for distribution - personal data, access to which by an unlimited circle of persons is provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner provided by the Personal Data Law (hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://tk-optima.com/en-optima.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including disclosing personal data in the media, posting in information and telecommunication networks or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual, or foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and (or) the destruction of material carriers of personal data.
3. Main Rights and Duties of the Operator
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4. Main Rights and Duties of Personal Data Subjects
4.1. Personal data subjects have the right to:
4.2. Personal data subjects are obliged to:
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.
5. The Operator may process the following User's personal data
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Also, the website collects and processes anonymized data about visitors (including "cookie" files) using Internet statistics services (Yandex Metrica and Google Analytics, among others).
5.5. The above-mentioned data are further referred to in this Policy as Personal Data.
5.6. The Operator does not process special categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data permitted for distribution from 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 permitted for distribution is formalized separately from other consents to the processing of their personal data. At the same time, the conditions provided for, in particular, in Article 10.1 of the Personal Data Law, 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. The User provides the Operator with consent to the processing of personal data permitted for distribution directly.
5.8.2. The Operator is obliged, within a period not exceeding three working days from the moment of receiving the specified consent from the User, to publish information about the conditions for processing, about the prohibitions and conditions on the processing of personal data permitted for distribution to an unlimited circle of persons.
5.8.3. The transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be terminated at any time at the request of the personal data subject. 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, the processing of which is subject to termination. The specified personal data in this requirement can only be processed by the Operator to whom it is addressed.
5.8.4. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the requirement specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to achieving specific, predefined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
6.3. The combination of databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data that meets the purposes of their processing is subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identifying the personal data subject no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract, a party to which, the beneficiary, or the guarantor of which is the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case the necessity to achieve these purposes is lost unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data includes:
7.2. Additionally, the Operator has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt-out of receiving informational messages by sending a letter to the Operator at the email address admin@tk-optima.com with the subject "Refusal of notifications about new products and services and special offers."
7.3. Anonymized data of Users collected through Internet statistics services serve to gather information about Users' actions on the website, improve the quality of the site and its content.
8. Legal Basis for Personal Data Processing
8.1. The legal grounds for processing personal data by the Operator include:
8.2. The Operator processes the User's personal data only if it is filled out and/or sent by the User independently through special forms located on the website https://tk-optima.com/en-optima or sent to the Operator via email. By filling out the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (enabling the storage of "cookie" files and using JavaScript technology).
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, voluntarily, and in their own interest
9. Conditions of Personal Data Processing
9.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform 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 administration of justice, execution of a judicial act, an act of another authority or official that must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the performance of a contract, the party to which, the beneficiary, or the guarantor under which is the personal data subject, 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 the beneficiary or guarantor.
9.5. Processing of personal data is necessary to protect 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. Processing of personal data is carried out for personal data made public by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for 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 fully comply with the requirements of the 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 prevent unauthorized access to personal data.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
10.3. In case inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator at the Operator's email address admin@tk-optima.com with the subject "Personal Data Update."
10.4. The processing period of personal data is determined by achieving the purposes for which personal data were collected unless another period is provided by the contract or current legislation. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address admin@tk-optima.com with the subject "Revocation of consent to the processing of personal data."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
10.6. Prohibitions established by the personal data subject on the transfer (except for providing access) or processing conditions (except for gaining access) of personal data permitted for distribution do not apply in cases of personal data processing in the public, social, and other public interests determined by Russian legislation.
10.7. The Operator ensures the confidentiality of personal data during its processing.
10.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than necessary to achieve the purposes of personal data processing unless the storage period of personal data is established by federal law, a contract, the party to which, the beneficiary or the guarantor under which is the personal data subject.
10.9. The termination of personal data processing may be a result of achieving the purposes of personal data processing, expiration of the consent period of the personal data subject, or revocation of consent by the personal data subject, as well as the identification of unauthorized processing of personal data.
11. List of Actions Performed by the Operator with the Obtained Personal Data
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information over information and telecommunication networks or without such transmission.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to which the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may only be carried out with the written consent of the personal data subject to the cross-border transfer of their personal data and/or the execution of a contract in which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other individuals who have access to personal data are obliged not to disclose personal data 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 can obtain any clarifications on questions related to the processing of their personal data by contacting the Operator via email at admin@tk-optima.com.
14.2. Any changes to the policy for processing personal data by the Operator will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is publicly available on the Internet at https://tk-optima.com/privacypolicyeng.
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of 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 taken by LLC "Optima" (hereinafter referred to as the Operator).
1.1. The Operator considers compliance with the rights and freedoms of individuals when processing their personal data, including the protection of the rights to privacy, personal, and family secrets, as its most important goal and condition for carrying out its activities.
1.2. This Operator's policy regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may obtain about visitors to the website https://tk-optima.com/en-optima.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology means.
2.2. Blocking of personal data - temporary cessation 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 providing their availability on the Internet at the network address https://tk-optima.com/en-optima.
2.4. Personal data information system - a set of personal data contained in databases and providing their processing by information technologies and technical means.
2.5. Depersonalization of personal data - actions that result in the impossibility of determining the belonging 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 a set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or natural person, acting alone or jointly with other persons, organizing and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://tk-optima.com/en-optima.
2.9. Personal data allowed by the subject of personal data for distribution - personal data, access to which by an unlimited circle of persons is provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner provided by the Personal Data Law (hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://tk-optima.com/en-optima.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including disclosing personal data in the media, posting in information and telecommunication networks or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual, or foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and (or) the destruction of material carriers of personal data.
3. Main Rights and Duties of the Operator
3.1. The Operator has the right to:
- receive from the subject of personal data accurate information and/or documents containing personal data;
- in case of the withdrawal of the subject of personal data's 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 Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and adopted in accordance with it normative legal acts, 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 their 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;
- provide the necessary information to the authorized body for the protection of the rights of personal data subjects upon the request of this body within 30 days from the date of receipt of such request;
- publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with respect to personal data;
- cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- fulfill other obligations provided for by the Personal Data Law.
4. Main Rights and Duties of Personal Data Subjects
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except for cases provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
- demand from the operator clarification of their personal data, their blocking, or destruction in cases where personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
- impose a condition for prior consent when processing personal data for marketing purposes;
- withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court the unlawful actions or inaction of the Operator in the processing of their personal data;
- exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate information about themselves;
- inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.
5. The Operator may process the following User's personal data
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Also, the website collects and processes anonymized data about visitors (including "cookie" files) using Internet statistics services (Yandex Metrica and Google Analytics, among others).
5.5. The above-mentioned data are further referred to in this Policy as Personal Data.
5.6. The Operator does not process special categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data permitted for distribution from 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 permitted for distribution is formalized separately from other consents to the processing of their personal data. At the same time, the conditions provided for, in particular, in Article 10.1 of the Personal Data Law, 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. The User provides the Operator with consent to the processing of personal data permitted for distribution directly.
5.8.2. The Operator is obliged, within a period not exceeding three working days from the moment of receiving the specified consent from the User, to publish information about the conditions for processing, about the prohibitions and conditions on the processing of personal data permitted for distribution to an unlimited circle of persons.
5.8.3. The transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be terminated at any time at the request of the personal data subject. 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, the processing of which is subject to termination. The specified personal data in this requirement can only be processed by the Operator to whom it is addressed.
5.8.4. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the requirement specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing
6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to achieving specific, predefined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
6.3. The combination of databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data that meets the purposes of their processing is subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identifying the personal data subject no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract, a party to which, the beneficiary, or the guarantor of which is the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case the necessity to achieve these purposes is lost unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data includes:
- informing the User by sending emails;
- conclusion, execution, and termination of civil contracts.
7.2. Additionally, the Operator has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt-out of receiving informational messages by sending a letter to the Operator at the email address admin@tk-optima.com with the subject "Refusal of notifications about new products and services and special offers."
7.3. Anonymized data of Users collected through Internet statistics services serve to gather information about Users' actions on the website, improve the quality of the site and its content.
8. Legal Basis for Personal Data Processing
8.1. The legal grounds for processing personal data by the Operator include:
- statutory documents of the Operator;
- contracts concluded between the operator and the personal data subject;
- federal laws, other regulatory legal acts in the field of personal data protection;
- consent of the Users to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if it is filled out and/or sent by the User independently through special forms located on the website https://tk-optima.com/en-optima or sent to the Operator via email. By filling out the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (enabling the storage of "cookie" files and using JavaScript technology).
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, voluntarily, and in their own interest
9. Conditions of Personal Data Processing
9.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform 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 administration of justice, execution of a judicial act, an act of another authority or official that must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the performance of a contract, the party to which, the beneficiary, or the guarantor under which is the personal data subject, 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 the beneficiary or guarantor.
9.5. Processing of personal data is necessary to protect 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. Processing of personal data is carried out for personal data made public by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for 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 fully comply with the requirements of the 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 prevent unauthorized access to personal data.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
10.3. In case inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator at the Operator's email address admin@tk-optima.com with the subject "Personal Data Update."
10.4. The processing period of personal data is determined by achieving the purposes for which personal data were collected unless another period is provided by the contract or current legislation. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address admin@tk-optima.com with the subject "Revocation of consent to the processing of personal data."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
10.6. Prohibitions established by the personal data subject on the transfer (except for providing access) or processing conditions (except for gaining access) of personal data permitted for distribution do not apply in cases of personal data processing in the public, social, and other public interests determined by Russian legislation.
10.7. The Operator ensures the confidentiality of personal data during its processing.
10.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than necessary to achieve the purposes of personal data processing unless the storage period of personal data is established by federal law, a contract, the party to which, the beneficiary or the guarantor under which is the personal data subject.
10.9. The termination of personal data processing may be a result of achieving the purposes of personal data processing, expiration of the consent period of the personal data subject, or revocation of consent by the personal data subject, as well as the identification of unauthorized processing of personal data.
11. List of Actions Performed by the Operator with the Obtained Personal Data
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information over information and telecommunication networks or without such transmission.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to which the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may only be carried out with the written consent of the personal data subject to the cross-border transfer of their personal data and/or the execution of a contract in which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other individuals who have access to personal data are obliged not to disclose personal data 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 can obtain any clarifications on questions related to the processing of their personal data by contacting the Operator via email at admin@tk-optima.com.
14.2. Any changes to the policy for processing personal data by the Operator will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is publicly available on the Internet at https://tk-optima.com/privacypolicyeng.
Policy on personal
data processing
data processing