TokenFiDe considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and personal and family secrets, to be its most important goal and a condition for carrying out its activities.
TokenFiDe has the right to:
- receive from the subject of personal data reliable information and/or documents containing personal data;
- in the event that the subject of personal data withdraws their consent to the processing of personal data, TokenFiDe 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 the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
TokenFiDe is obliged to:
- provide the personal data subject, at their request, with information concerning the processing of their personal data;
- organize the processing of personal data in accordance with the procedure established by current legislation;
- respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized body for the protection of the rights of personal data subjects with the necessary information at the request of that body within 30 days from the date of receipt of such a request;
- publish or otherwise provide unrestricted 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, destruction, alteration, 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 in the cases provided for by the Personal Data Law;
- perform other duties provided for by the Personal Data Law.
Basic rights and obligations of personal data subjects
Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data TokenFiDe in an accessible form and must not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- require TokenFiDe to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- to set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
- to withdraw consent to the processing of personal data.
Personal data subjects are obliged to:
- provide TokenFiDe with accurate data about themselves;
- inform TokenFiDe about the clarification (update, change) of their personal data.
TokenFiDe may process the following personal data of the User:
- Last name, first name, patronymic.
- Email address.
- Phone numbers.
- Company, position.
- The above data is hereinafter referred to in the Policy as Personal Data.
Principles of personal data processing
- Personal data processing is carried out on a lawful and fair basis.
- Personal data processing is limited to the achievement of specific, predefined, and lawful purposes. Personal data processing that is incompatible with the purposes of personal data collection is not permitted.
- It is not permitted to combine databases containing personal data that are processed for purposes that are incompatible with each other.
- Only personal data that meets the purposes of its processing shall be processed.
- The content and scope of the personal data processed shall correspond to the stated purposes of processing. The processing of personal data shall not be excessive in relation to the stated purposes of processing.
Purposes of personal data processing
The purpose of processing the User’s personal data:
TokenFiDe 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 TokenFiDe an email to [email protected] with the subject line “Opt out of notifications about new products and services and special offers.”
Legal grounds for processing personal data
The legal grounds for TokenFiDe’s processing of personal data are:
- TokenFiDe’s charter (constituent) documents;
- federal laws and other regulatory acts in the field of personal data protection;
- TokenFiDe’s statutory (founding) documents;
- federal laws and other regulatory acts in the field of personal data protection;
- Users’ consent to the processing of their personal data and to the processing of personal data permitted for distribution.
Terms and conditions for the processing of personal data
- Personal data is processed with the consent of the personal data subject to the processing of their personal data.
- The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or the beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
- The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
- Personal data is processed, access to which is provided to an unlimited number of persons by the personal data subject or at his or her request (hereinafter referred to as publicly available personal data).
- Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
Procedure for the collection, storage, transfer, and other types of processing of personal data
The security of personal data processed by TokenFiDe is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
- TokenFiDe ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
- The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of applicable law or if the subject of the personal data has given consent to the Operator to transfer the data to a third party in order to fulfill obligations under a civil law contract.
- If inaccuracies are found in personal data, the User may update them independently by sending a notification to TokenFiDe at the email address [email protected] with the subject line “Update of personal data.”
The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending TokenFiDe a notification by email to TokenFiDe’s email address [email protected] marked “Withdrawal of consent to the processing of personal data”.
TokenFiDe stores personal data in a form that allows the personal data subject to be identified for no longer than is necessary for the purposes of processing personal data, unless the storage period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
List of actions performed by TokenFiDe with the personal data received
TokenFiDe collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
TokenFiDe performs automated processing of personal data with the receipt and/or transfer of the information received via information and telecommunications networks or without them.
Cross-border transfer of personal data
Before starting to transfer personal data across borders, TokenFiDe has to make sure that the foreign country where the personal data is supposed to be transferred provides reliable protection of the rights of personal data subjects.
Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only be carried out with the written consent of the data subject to the cross-border transfer of their personal data and/or the performance of a contract to which the data subject is a party.
Confidentiality of personal data
TokenFiDe and other persons who have 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.
Final provisions
The user can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting TokenFiDe by email at [email protected].
This document will reflect any changes to TokenFiDe’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.