Personal data processing policy

Personal data processing policy

1. Basic concepts used in the Policy

Automated processing of personal data is the processing of personal data using computer technology.

Blocking of personal data is the temporary cessation of the processing of personal data (except for cases where the processing is necessary to clarify personal data).

Website is a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://w.fcdynamo.ru/.

Legal representative is a person authorized by the Subject of personal data or by Russian legislation to act on behalf of the Subject of personal data.

Personal data information system is a collection of personal data contained in databases and the information technologies and technical means that ensure their processing.

Club is a limited liability company "Women's Football Club "Dynamo-Moscow".

Depersonalization of personal data — actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data by a specific User or another subject of personal data.

Processing of personal data — any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools 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.

Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

Personal data (PD) — any information related directly or indirectly to a specific or determinable User of the website https://w.fcdynamo.ru/.

Personal data permitted for distribution - personal data, access to which by an unlimited number of persons is provided by the subject of personal data or his legal representative by giving consent to the processing of personal data permitted for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data permitted for distribution).

User - any visitor to the website https://w.fcdynamo.ru/.

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

Distribution of personal data - any actions aimed at disclosing personal data to an unlimited number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including disclosure of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way.

Subject of personal data - an individual who is directly or indirectly determined or determinable using personal data.

Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign government body, foreign individual or foreign legal entity.

Destruction of personal data – any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the destruction of tangible media of personal data.

2. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. №152-FZ "On Personal Data" (hereinafter referred to as 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 "Women's Football Club "Dynamo-Moscow", which is a legal entity created in accordance with the legislation of the Russian Federation, OGRN 1247700665871, INN 9710138641, KPP 771001001, address 125047, Moscow, internal territory of the Tverskoy municipal district, 4-y Lesnoy lane, 4 (hereinafter referred to as the Operator).

2.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

2.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about Users when they use the Club's services on the Club's official website https://w.fcdynamo.ru/ (hereinafter referred to as the Site) on the Internet.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:

receive reliable information and/or documents containing personal data from the personal data subject or his/her legal representative;

provide the User with the opportunity to use a particular service of the site only after the User has registered on the site;

if the personal data subject or his/her legal representative revokes consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject or his/her legal representative if there are grounds specified in the Law on Personal Data;

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.

The operator has the right to entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by federal law, on the basis of an agreement concluded with this person.

3.2. The operator is obliged to:

provide the personal data subject or his legal representative upon request with information regarding the processing of personal data of the personal data subject;

organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

respond to requests and inquiries of personal data subjects or their legal representatives in accordance with the requirements of the Law on Personal Data;

notify the authorized body for the protection of the rights of personal data subjects, upon request of this body, of the necessary information within ten working 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, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal 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;

fulfill other obligations stipulated by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects or their legal representatives have the right to:

receive information concerning the processing of personal data of the personal data subject, except for cases stipulated by federal laws. Information is provided to the personal data subject or his legal representative by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except for cases when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;

require the operator to clarify personal data related to the personal data subject, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;

put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;

to revoke consent to the processing of personal data;

to appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inaction of the Operator when processing personal data related to the Personal Data Subject;

to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects (legal representatives of personal data subjects) are obliged to:

provide the Operator with reliable data about themselves/the personal data subject;

inform the Operator about clarification (update, change) of their personal data / personal data of the subject of personal data.

4.3. Persons who have transferred false information to the Operator, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Categories of personal data processed by the Operator

5.1. The Operator may process the following personal data of the User:

5.1. The website also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics).

5.2. The above data are hereinafter referred to as Personal Data.

5.3. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.4. The processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is permitted if the prohibitions and conditions stipulated by Article 10.1 of the Law on Personal Data are observed.

5.5. The consent of the subject of personal data or his legal representative to the processing of personal data permitted for distribution is drawn up separately from other consents to the processing of personal data. In this case, the conditions stipulated, in particular, by Article 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.

5.5.1. The consent to the processing of personal data permitted for distribution is provided directly to the Operator by the personal data subject or his legal representative.

5.5.2. The Operator is obliged, no later than three working days from the date of receipt of the said consent of the User, to publish information on the conditions of processing, on the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.

5.5.3. The transfer (distribution, provision, access) of personal data permitted for distribution by the personal data subject or his legal representative must be terminated at any time at the request of the personal data subject or his legal representative. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data subject / legal representative, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is sent.

5.5.4. Consent to the processing of personal data permitted for distribution shall cease to be valid from the moment the Operator receives the request specified in paragraph 5.7.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1. Personal data shall be processed on a lawful and fair basis.

6.2. Personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data shall not be permitted.

6.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.

6.4. Only personal data that meet the purposes of their processing shall be processed.

6.5. The content and volume of personal data being processed correspond to the stated purposes of processing. Excessive amounts of personal data in relation to the stated purposes of their processing shall not be allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.

6.7. Personal data shall be stored in a form that allows the subject of personal data to be identified, for no longer than required for the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, or a beneficiary or guarantor. The personal data being processed shall be destroyed or depersonalized upon achievement of the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. Purpose of processing the User's personal data:

Providing the User with personalized Services;

Communicating with the User, including sending notifications, requests and information regarding the use of the Services, rendering services, as well as processing requests and applications from the user (for example, if the User has forgotten their password - in relation to Services containing a password);

Improving the quality of the Services, the ease of use, developing new Services and services;

Conducting statistical and other research in order to determine the information that Users need;

Conducting news and advertising and information mailings about the Club Services, special offers; products and services of selected partners to the extent permitted by applicable law.

7.2. The Operator also 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 an email to the Operator at office@w-fcdm.ru with the subject line "Opt-out of notifications about new products and services and special offers".

7.3. Anonymized User data collected using Internet statistics services is used to collect information about the actions of Users on the site, improve the quality of the site and its content.

8. Legal grounds for processing personal data

8.1. The legal grounds for processing personal data by the Operator are:

Federal Law "On Information, Information Technology and Information Protection" dated 27.07.2006 N 149-FZ;

Federal Law dated 27.07.2006 N 152-FZ "On Personal Data"

Federal Law dated 12.01.1996 N 7-FZ "On Non-Commercial Organizations";

Operator Charter;

federal laws, other regulatory legal acts in the field of personal data protection;

consent of 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 they are filled in and/or sent by the User independently through special forms located on the website https://w.fcdynamo.ru/ or sent to the Operator by e-mail. By filling in the relevant 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 this is permitted in the User's browser settings (the saving of cookies and the use of JavaScript technology are enabled).

8.4. The subject of personal data or his legal representative makes a decision on the provision of the personal data of the subject of personal data and gives consent freely, of his own free will and in his own interests.

9. Terms of personal data processing

9.1. Personal data shall be processed with the consent of the personal data subject or his/her legal representative to the processing of the personal data of the personal data subject.

9.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

9.3. The processing of personal data is necessary for the administration of justice, the 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. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, or a beneficiary or guarantor, as well as for concluding an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary to exercise 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. The processing of personal data is carried out, to which the subject of personal data or his legal representative has granted access to an unlimited number of persons (hereinafter referred to as publicly available personal data).

9.7. The processing of personal data is carried out, subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for collecting, storing, transferring and other types of processing of personal data

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 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 persons from accessing personal data.

10.2. The User's personal data for the purposes specified in paragraph 5.1 may be transferred to third parties, namely: JSC Football Club Dynamo Moscow, which is a legal entity created in accordance with the legislation of the Russian Federation, OGRN 1027700547511, INN 7714067099, KPP 771401001, registered address 125167, Moscow, Leningradsky Prospekt, Building 36, Floor 3, Office 198, https://fcdynamo.ru/, as well as in cases related to the implementation of current legislation.

10.3. In the event that inaccuracies are detected in personal data, the subject of personal data or his legal representative may update them independently by sending a notification to the Operator to the Operator's e-mail address office@w-fcdm.ru with the subject "Updating personal data".

10.4. The personal data processing period is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or applicable law. The personal data subject or his/her legal representative may revoke consent to the processing of personal data at any time by sending the Operator a notification by e-mail to the Operator's e-mail address office@w-fcdm.ru 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 the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject (legal representative) and/or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. The prohibitions on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution established by the personal data subject or his legal representative shall not apply in cases of personal data processing in state, public and other public interests determined by the legislation of the Russian Federation.

10.7. The operator ensures the confidentiality of personal data when processing personal data.

10.8. The operator stores personal data in a form that allows identifying the personal data subject for no longer than required for the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.

10.9. The condition for termination of personal data processing may be the achievement of the personal data processing purposes, the expiration of the consent of the personal data subject or his legal representative or the withdrawal of consent by the personal data subject (his legal representative), as well as the detection of unlawful processing of personal data.

11. List of actions performed by the Operator with the 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. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.

12. Cross-border transfer of personal data (if performed by the Operator)

12.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is supposed to be transferred ensures reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent from the subject of personal data or his legal representative to the cross-border transfer of his personal data and/or the execution of an agreement to which the subject of personal data is a party.

13. Confidentiality of personal data

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

14. Final Provisions

14.1. The personal data subject or his/her legal representative may obtain any clarifications on issues of interest regarding the processing of the personal data of the personal data subject by contacting the Operator by e-mail office@w-fcdm.ru.

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 User Agreement is freely available on the Internet at https://w.fcdynamo.ru/club/agreement/.