1. DEFINITION OF CONCEPTS
"Law" means the Federal Law of the Russian Federation "On Personal Data" with all amendments and additions, as well as other legislative acts of the Russian Federation.
"Controller" means a person who is responsible for the processing and protection of Personal Data of Users located in the EU within the meaning of the General Data Protection Regulation of April 27, 2016 (hereinafter referred to as the "GDRP").
"Site" means an information unit on the Internet, a resource of web pages (documents) that are united by a common theme and linked to each other by means of links. It is registered to the Copyright Holder and is necessarily linked to a specific domain, which is its address. This Policy has been developed for the following website: ccam.info
"Personal data" means a set of personal data and/or non-personalized information about the User, provided by him to the Copyright Holder and/or automatically collected by the Copyright Holder and/or third parties.
"Policy" means this Website Privacy Policy (as amended and amended as may be).
"User" means a legal or natural person who uses the Site and / or has accessed it from any device.
"User Agreement" means an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of using the Site. The user joins such an agreement and does not have the right to make and / or demand any changes or additions to it. The User can read the terms of the User Agreement at the following link: https://ckam.info/privacy.html.
"Copyright Holder" means the following person in whose name the Site is registered:
Melnikov Maxim Alexandrovich
Address: 143000, Moscow region, Odintsovo, Novo-Sportivnaya st., 6, 3.
Tel.: +7(916)182-39-71
Email: i@ckam.info
"Cookies" means small files sent by a website and placed on the User's computers, smartphones, tablets, watches and other mobile devices to improve the operation of the websites, as well as the quality of the content posted on them.
2. RELATIONSHIPS TO WHICH THE POLICY APPLYS
General provisions
This Policy is used and applicable solely to Personal Data received from the User in connection with his use of the Site. The provisions of this Policy are aimed at:
(1) determination of the types and types of personal data received, directions and purposes of use (processing) of personal data, as well as sources of obtaining such personal data; And
(2) determination of the rights of the User in relation to the protection of the confidentiality of the Personal Data transmitted by him; And
(3) identification of persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).
The rules of this Policy do not apply in the case of processing by third parties of Personal Data that is voluntarily provided by the User.
By using the Site, the User agrees to the terms of this Policy and gives his consent to the Copyright Holder for the collection, processing, retention and storage of Personal Data in the manner and under the conditions provided for in this Policy.
If the User does not agree with the terms of the Policy and / or certain terms of the Policy are not clear to him, in this case the User is obliged to immediately stop using the Site.
User rights for the protection of personal data
In connection with the provision of Personal Data, the User automatically receives the following rights:
(1) receive data relating to their processing (grounds and purposes of such processing, methods of processing used, information about persons who have access to them or to whom they can be disclosed on the basis of an agreement or the Law).
(2) receive data on the location and identification data of the persons performing the processing of Personal Data.
(3) receive data on the retention periods of Personal Data.
(4) to receive information about the completed or proposed cross-border transfer of Personal Data.
(5) appeal against the actions or inaction of the Copyright Holder to the authorized body for the protection of the rights of personal data subjects or in court.
(6) receive compensation for losses and / or compensation for moral damage in a judicial proceeding as a result of violations of the User's rights to the protection and protection of his Personal Data committed by the Copyright Holder and / or third parties.
(7) to exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.
3. LIST OF PERSONAL DATA COLLECTED
Non-personally identifiable user information
In connection with the use of the Site, the Copyright Holder may automatically collect and process the following non-personalized information about the User:
(1) information about traffic, the possible number of clicks made, logs and other data.
(2) device information (identification number of the device from which you are logging in, operating system, platform, browser type and other information about the browser, IP address).
Personal data about users
The User provides the Copyright Holder with the following personal data:
(1) the following data: Phone or Email, in case of sending an appeal through the contact form or through other means of communication indicated on the "Contacts" page (ckam.info/booking.html)
(2) data and information obtained as a result of combining certain Personal data of a particular User, as well as data and information received data about the User received from third parties (partners, marketers, researchers).
The user is the only person responsible for the completeness of the personal (personal) data provided and is obliged to change them in a timely manner (update, check, correct) on a regular basis.
The Copyright Holder assumes that all personal (personal) data provided by the User are reliable, and that the User keeps such information up to date.
Use of cookies
The Site uses certain Cookies to save the IP address, User preferences or the type of device used in order to (1) keep statistics of visits and site traffic, and (2) personalize the data displayed on the User's screen, and (3) save data necessary for identification the User, including when accessed from different devices, and (4) showing ads in accordance with the interests and preferences of the User. The Site may use both its own Cookies belonging to the Copyright Holder and Cookies of third parties.
The site uses the following Cookies:
(1) Technical (functional) cookies that are needed to control traffic and data transfer, to identify Users and provide access to the content for the User and without which the use of the Site is functionally limited, as well as to prevent the provision of recommendations that do not correspond to the interests of the User.
(2) Statistical Cookies, which are needed to track the frequency of visits to the Site by Users, to identify ways in which the Site is used, and to identify the type and type of content that is popular or interesting to the User.
(3) Third party cookies, which are set by third parties with the permission of the User and are intended to carry out statistical research regarding the User's behavior on the Internet and / or the sending of personalized advertising or marketing materials to the User and / or the provision of goods or services.
The user has the right to disable cookies at any time by changing certain settings in his browser. Such disabling does not entail limiting or changing the User's access to the functionality of the Site and / or its content. To disable Cookies, follow these steps:
Go to the browser settings on the device you are using (section "Settings"), then select "Cookies", then "Change settings" and set the desired configuration.
4. PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL DATA
Determining the purposes of processing
The collection and processing of Personal Data is carried out for the following purposes:
(1) to analyze the User's behavior, as well as to identify the User's preferences for a particular type of content.
(2) for the operational and correct operation of the Site, improving its functionality and content.
(3) to identify the User.
(4) to comply with the requirements of the Law.
(5) for technical support of the Site, identification of problems in its operation and their elimination.
(6) to maintain communication with the User (communication).
(7) to fulfill other obligations of the Copyright Holder that arose before the User.
(8) to conduct statistical research.
(9) for any other purpose, subject to obtaining separate consent from the User.
The processing of Personal Data is carried out on the basis of the following principles: (1) the lawfulness of the purposes and methods of processing; and (2) good faith; and (3) suitability of the purposes of the processing of Personal Data for the purposes predetermined and declared at the time of collection of such Personal Data; and (4) suitability of the scope and nature of the Personal Data being processed for the stated purposes of their processing.
Conditions for the processing of personal data
The processing of Personal Data is carried out in the following cases: (1) obtaining consent from the User; or (2) achievement by the Copyright Holder of the goals provided for by an international treaty or the Law; or (3) the provision by the User of his Personal Data to an unlimited circle of persons; or (4) fulfillment of other obligations of the Copyright Holder to the User, including, but not limited to, provision of certain content to the User; or (5) saving the life or health of the User when consent to the processing of his Personal Data cannot be obtained in advance.
In case of depersonalization of Personal Data, which does not allow to directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy are no longer applied to them.
The Rightholder takes all possible measures to protect the confidentiality of the received Personal Data, except when the User has made such data publicly available.
The processing of Personal Data is carried out using automation tools and without the use of such automation tools.
5. THIRD PARTY ACCESS TO PERSONAL DATA
Using remarketing services
The Copyright Holder uses remarketing to advertise the Site content to the User on other sites visited by the User.
Remarketing services are provided to the Copyright Holder through the following platform: Yandex.Advertising.
The specified provider collects and processes non-personalized data that does not directly allow to identify or identify the User. The information collected may typically include (1) the content the User viewed, (2) the date and time the User viewed the content, (3) geolocation data. The collection and processing of such non-personalized information allows the User to be provided with more targeted advertising or marketing content.
By using the Site, the User agrees to the Privacy Policy and Terms of Use of the specified remarketing service provider, as well as to the automatic installation of appropriate Cookies on the User's device.
The user has the right to opt out of such advertising at any time by changing the appropriate browser settings.
Use of analytical platforms
The Copyright Holder uses the following analytical platform: Yandex.Metrika, Google.Analytics to (1) track the frequency of site visits by Users; and (2) tracking how the User uses the Site and/or its content; and (3) identifying the type and type of content that is popular among Users; and (4) determining the location of the User. The User also gives his consent to the Copyright Holder to use the information received about the User from another option.
For these purposes, the following analytical platform: Yandex.Metrika, Google.Analytics may collect data about the IP address, geolocation, User behavior, as well as his preferences and interest in relation to certain content.
The following analytical platform: Yandex.Metrika, Google.Analytics gains access to Personal data in order to provide the Copyright Holder with an understanding of how efficiently his Website works, what kind of content is popular, how effective it is to place certain advertisements in it, and also for the purposes of development and/or improvement of the existing marketing strategy of the Copyright Holder.
From the moment of using the Site, the User agrees to the privacy policy (Privacy Policy) of the following analytical platform: Yandex.Metrika, Google.Analytics, as well as to the automatic installation of appropriate Cookies on the User's device.
Disclosure of personal data to third parties
The Copyright Holder has the right to disclose Personal Data (1) to its affiliates, branches and representative offices opened both on the territory of the Russian Federation and on the territory of other states; (2) successors of the Copyright Holder, which arose as a result of its liquidation, reorganization or bankruptcy, and who received exclusive rights to own the Site; (3) to third parties solely for the purpose of providing the User with certain content or access to it; (4) to third parties when the User has given consent to the disclosure, transfer or processing of their Personal Data, as well as in other cases expressly provided for by the Law or this Policy.
The Right Holder discloses Personal Data only if (1) it is sure that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data that the Right Holder takes, and (2) consent to such disclosure has been previously expressed User and/or permitted by law.
6. ADVERTISING
Advertising on the website
The Copyright Holder does not place advertisements on the Site.
7. SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER
Request to stop processing personal data
Each User has the right to express his objection to the Rightholder against the processing and / or storage of his Personal Data. Such an objection can be expressed as follows:
the request must be sent to the copyright holder at the following address: i@ckam.info
Request for information about personal data
If the User has questions related to the procedure for applying or using this Policy, the procedure and / or method of processing Personal Data, the User can ask such a question as follows:
the question should be sent to the copyright holder at the following address: i@ckam.info
Change (update, addition, correction) or deletion of personal data
The User has the right to change or delete Personal Data at any time by sending a special request to the Copyright Holder at the following address: i@ckam.info.
The Rightholder has the right to refuse to change or delete Personal Data if such actions will lead (1) to a violation of the rules of this Policy; or (2) in violation of the Law; or (3) the nature of the Personal Data is evidence in any litigation that has arisen between the Copyright Holder and the User.
8. TERMS AND PROCEDURE FOR STORING PERSONAL DATA
Storage is carried out independently by the Copyright Holder.
Storage is carried out for the entire period necessary to achieve the stated purposes of processing Personal Data.
The Rightholder undertakes to destroy or depersonalize them immediately after achieving the goals of processing Personal Data.
9. ACCESS OF MINORS TO THE SITE
Users in the Russian Federation
The Site may be used by persons under the age of 18.
The Site collects personal data about Users only when they send messages to the Copyright Holder through the feedback form or by other means specified in the "Contacts" section (ckam.info/booking.html), therefore, the use of this function of this Site by minor Users is allowed only subject to obtaining prior consent from the legal representative (guardian) for the processing of Personal data. Such consent must be given in the following way:
send a scan of the representative's passport to the following email address: i@ckam.info
If the minor User cannot provide consent to the processing of his Personal Data from the legal representative (guardian), in this case, such User is obliged not to use the function of sending messages to the Copyright Holder using the feedback form and in other ways specified in the "Contacts" section (ckam.info/booking.html) or stop using the Site immediately.
Users in the European Union
The Site and/or its content is intended for persons under the age of 16.
Since the Site collects personal data about Users, the use of this Site by Users under the age of 16 (unless a lower threshold is established by the national legislation of the Member State of the European Union in whose territory access to the Site is provided) is allowed only subject to obtaining prior consent from the legal representative (guardian) to the processing of Personal Data, which must be provided in the following way:
send a scan of the representative's passport to the following email address: i@ckam.info
10. PERSONAL DATA PROTECTION
Protecting the confidentiality of Personal Data is a paramount and important task for the Copyright Holder. The Rightholder adheres to all required international standards, rules and recommendations for the protection of Personal Data.
The Rightholder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties. To ensure the safety and confidentiality of the received Personal Data, the Copyright Holder uses the following means of protection:
(1) SSL (Security Sockets Layer) protocol.
11. USERS LOCATED IN THE EUROPEAN UNION
General provisions
Since the Site is accessible to users from the European Union, the Copyright Holder undertakes to additionally comply with the provisions of the GDPR.
The controller in the understanding of this Policy is the Copyright Holder.
The Rightholder shall store Personal Data for a reasonable period of time necessary to achieve the purposes of processing, but not less than the period established by the local legislation of the Member State of the European Union, in whose territory the Site is available, for storing one or another type of Personal Data. Upon the expiration of the period established for storage, the Copyright Holder undertakes to immediately destroy or depersonalize such data.
Official representative
Since the Controller is located outside the territory of the European Union, the following person is appointed as its official representative for the protection of Personal Data of Users in the European Union: Maksim Alexandrovich Melnikov, contact details: i@ckam.info.
User rights in the field of personal data protection
Under Chapter 3 of the GDPR, Users located in the European Union have the following rights in the field of Personal Data protection: (1) the right to receive information about their Personal Data ("the right to be informed"); and (2) the right to access your Personal Data ("the right of access"); and (3) the right to rectification of Personal Data ("the right to rectification"); and (4) the right to erasure of Personal Data ("the right to erasure"); and (5) the right to restrict processing of Personal Data ("the right to restrict processing"); and (6) the right to portability of Personal Data to third parties ("the right to data portability"); and (7) the right to object ("the right to object").
12. FINAL PROVISIONS
Availability of policy text for review
Users can view the terms of this Policy at the following link: https://ckam.info/privacy.html.
This Policy may be translated into a foreign language for those Users who access the Site outside the Russian Federation. In case of discrepancy between the original text (Russian) and its translation, the original language shall prevail.
This version of the Policy is effective from January 1, 2023.
Changing and supplementing the policy
This Policy may be changed from time to time. The Copyright Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and / or consent of the User.
The user himself undertakes to regularly check the provisions of this Policy for possible changes or additions.
Applicable law
This Policy has been developed in accordance with the current legislation on the protection of personal data of the Russian Federation, in particular, with the provisions of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (with all additions and changes), the Federal Law of July 21, 2014 No. 242-FZ "On Amending Certain Legislative Acts of the Russian Federation in Part of Clarifying the Procedure for Processing Personal Data in Information and Telecommunication Networks" (with all additions and amendments), as well as the provisions of the General Data Protection Regulation dated April 27, 2016 GDRP.
Disclosure risk
Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the personal data received, the User is hereby considered to be properly aware that any transfer of Personal data on the Internet cannot be guaranteed secure, and therefore the User carries out such transfer at his own risk.
The document is available in Russian: download