Personal data processing policy
Approved by Order of the General Director
IP "Isabaev Sh.O"
(Order No. 01 dated April 10, 2023)
1. General Provisions
1.1. The personal data processing policy (hereinafter referred to as the "Policy") is published and applied on the Financial Bigwig platform (hereinafter referred to as the "Operator") in accordance with paragraph 2 of part 1 of Art. 18.1 of the Federal Law of July 27, 2006 N 152-FZ "On Personal Data".
This Policy defines the procedure and conditions of the Operator regarding the processing of personal data.
All issues related to the processing of personal data that are not regulated by this Policy are resolved in accordance with the current legislation of the Russian Federation in the field of personal data.
1.2. The purpose of personal data processing is:
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providing personal data subjects with the services of the Operator on the Financial Bigwig platform (hereinafter referred to as the "Platform"), which is legally owned by the Operator. Any user can register on the Platform for the purpose of subsequently providing such a user with the help of the platform to third parties with trainings, seminars, courses, face-to-face and online classes on the Internet.
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ensuring the protection of the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets;
1.3. Processing is organized by the Operator on the principles of:
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legitimacy of the purposes and methods of processing personal data, good faith and fairness in the activities of the Operator;
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the reliability of personal data, their sufficiency for the purposes of processing, the inadmissibility of processing personal data that is excessive in relation to the purposes stated when collecting personal data;
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processing only personal data that meet the purposes of their processing;
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compliance of the content and scope of the processed personal data with the stated purposes of processing. The processed personal data should not be excessive in relation to the stated purposes of their processing;
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the inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;
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ensuring the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data. The operator takes the necessary measures or ensures their adoption to remove or clarify incomplete or inaccurate data;
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storage of personal data in a form that allows you to determine the subject of personal data, no longer than required by the purposes of processing personal data.
1.4. Personal data is processed using automation tools.
1.5. The operator processes the following personal data:
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Full Name
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mobile phone
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passport details
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E-mail address
1.5.1. At the same time, some mandatory and / or voluntary personal data, at the personal will of the Platform user, are made publicly available by such user to any third parties in accordance with paragraph 10, paragraph 1 of article 6 of the Federal Law of July 27, 2006 N 152-ФЗ “On personal data".
1.6. When processing personal data, the Operator applies legal, organizational and technical measures to ensure the security of personal data in accordance with Art. 19 of the Federal Law of July 27, 2006 N 152-FZ “On Personal Data”, which are enshrined in the Regulation “On Ensuring the Security of Personal Data of Platform Users.
1.7. The Operator does not disclose to third parties and does not distribute personal data without the consent of the subject of personal data, unless it is provided for by the current legislation of the Russian Federation and this Policy.
1.8. The assessment of the harm that may be caused to personal data subjects in the event that the Operator violates the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” is determined in accordance with Art. Art. 15, 151, 152, 1101 of the Civil Code of the Russian Federation. The ratio of the specified harm and the measures taken by the Operator aimed at preventing, preventing and / or eliminating its consequences is established in the Regulation “On Ensuring the Security of the Personal Data of Platform Users”.
1.9. Conditions for processing personal data by the Operator:
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personal data is processed by the Operator after the conclusion by the subject of personal data of a license agreement - an offer to grant such subject the right to use the training Platform. According to paragraph 5 of Article 6 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”, the consent of the subject of personal data is not required, since the subject enters into an agreement on his own initiative and is the beneficiary under the agreement concluded by him.
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The operator does not transfer the personal data of the subject to third parties.
1.10. The storage of personal data of subjects who are users of the Platform is carried out in a form that allows determining the subject of personal data. Personal data is subject to destruction upon achievement of the purposes of processing. Deletion of personal data is carried out by deleting an account on the Platform, after which such a record cannot be restored.
1.11. Interaction with federal executive authorities on the processing and protection of personal data of subjects whose personal data is processed by the Operator is carried out within the framework of the legislation of the Russian Federation.
1.12. The processing of personal data is carried out automatically using computer technology.
2. Responsible for the processing of personal data
2.1. When processing personal data, the Operator issues an appropriate order to appoint a person responsible for the processing of personal data.
2.2. The person responsible for the processing of personal data is subordinate to the executive body of the Operator - the General Director, controls the process of processing personal data and ensures the implementation of all provisions of this Policy relating to his competence.
2.3. Responsible for the processing of personal data:
2.3.1. exercises internal control over compliance by the Operator and its employees with the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data.
2.3.2. controls the acceptance and processing of appeals and requests from personal data subjects or their representatives.
2.3.3. takes measures to detect facts of unauthorized access to personal data and immediately bring this information to the General Director.
2.3.4. constantly monitors the level of protection of personal data.
2.3.5. familiarizes, against signature, the Operator's employees who have access to personal data with the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, as well as with the local acts of the Operator that determine the procedure for processing Personal data.
2.3.6. carries out internal control and (or) audit of the compliance of the processing of personal data with the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" and the regulatory legal acts adopted in accordance with it, the requirements for the protection of personal data, the Operator's policy regarding the processing of personal data, local acts of the Operator.
3. The procedure for ensuring the rights of the subject of personal data
3.1. Subjects of personal data or their representatives have the rights provided for by the Federal Law of July 27, 2006 N 152-FZ "On Personal Data".
3.2. The operator ensures the rights of subjects of personal data in the manner prescribed by chapters 3 and 4 of the Federal Law of July 27, 2006 N 152-FZ "On Personal Data".
3.3. The authority of the representative to represent the interests of each subject of personal data is confirmed by an appropriate power of attorney.
3.4. The information specified in Part 7 of Art. 22 of the Federal Law of July 27, 2006 N 152-FZ “On Personal Data”, are provided to the subject of personal data in an accessible form without personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data, in in electronic format. At the request of the subject of personal data, they can be duplicated on paper. An accessible form on paper must be certified by the Director General.
3.5. The information specified in Part 7 of Art. 22 of the Federal Law of July 27, 2006 N 152-FZ “On Personal Data”, are provided to the subject of personal data or his representative upon personal contact or upon receipt of a request from the subject of personal data or his representative. The request must contain the number of the main document proving the identity of the subject of personal data or his representative, information about the date of issue of the specified document and the authority that issued it, information confirming the participation of the subject of personal data in relations with the Operator (contract number, date of conclusion of the contract, conditional verbal designation and (or) other information), or information otherwise confirming the fact of processing personal data by the Operator, the signature of the personal data subject or his representative. If it is technically possible, the request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
3.6. The right of the subject of personal data to access his personal data may be limited in accordance with federal laws.
3.7. The operator is obliged to immediately stop, at the request of the subject of personal data, the processing of his personal data specified in Part 1 of Art. 15 of the Federal Law of July 27, 2006 N 152-FZ "On Personal Data".
3.8. The operator is obliged to provide free of charge to the subject of personal data or his representative the opportunity to get acquainted with the personal data relating to this subject of personal data, at the place of his location during working hours.
3.9. The Operator, at the request of the subject of personal data or his authorized representative, provides for review the local acts of the Operator regarding the processing of personal data. The Operator's local regulations are the Regulations on the processing of personal data of Platform users and the Regulations on ensuring the security of personal data of Platform users in accordance with Article 19 of the Federal Law of July 27, 2006 N 152-FZ "On Personal Data".
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