1. General provisions This personal data processing policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the Personal Data Law). It establishes the personal data processing procedure and security measures adopted by Novy Gorod LLC (OGRN 1215000103273, INN 5040175398), registered under Russian law at 6 Raduzhnaya Street, Building 2, Vidnoye, Moscow Region (the Operator). 1.1. The Operator's foremost objective and a condition of its activities is to respect human and civil rights and freedoms when processing personal data, including the rights to privacy and personal and family confidentiality. 1.2. This Operator's personal data processing policy (the Policy) applies to all information the Operator may obtain about visitors to the website https://newcitymsk.ru/.
2. Key terms used in the Policy 2.1. Automated personal data processing means processing personal data using computing equipment. 2.2. Blocking personal data means temporarily suspending its processing, except when processing is necessary to clarify the personal data. 2.3. Website means the collection of graphic and informational materials, computer programs and databases that make them available online at https://newcitymsk.ru/. 2.4. A personal data information system is the personal data held in databases together with the information technologies and technical means used to process it. 2.5. Anonymisation means actions that make it impossible, without additional information, to determine whether personal data belongs to a particular User or another data subject. 2.6. Personal data processing means any operation or set of operations performed on personal data, with or without automation, including collection, recording, organisation, accumulation, storage, clarification (updating or alteration), retrieval, use, transmission (dissemination, provision or access), anonymisation, blocking, deletion and destruction. 2.7. Operator means a state or municipal body, legal entity or individual that, independently or jointly, organises or carries out personal data processing and determines its purposes, the data to be processed and the operations to be performed. 2.8. Personal data means any information directly or indirectly relating to an identified or identifiable User of the website https://newcitymsk.ru/. 2.9. Personal data authorised by the data subject for dissemination means personal data made accessible to an unlimited number of persons by the subject's consent to its processing for dissemination in the manner established by the Personal Data Law (data authorised for dissemination). 2.10. User means any visitor to the website https://newcitymsk.ru/. 2.11. Provision of personal data means actions aimed at disclosing personal data to a particular person or defined group of persons. 2.12. Dissemination of personal data means actions aimed at disclosing it to an undefined group of persons (transmission) or making it accessible to an unlimited number of persons, including publication in the media, placement on information and telecommunications networks or providing access by other means. 2.13. Cross-border transmission means transferring personal data to a foreign country, to a foreign state authority, individual or legal entity. 2.14. Destruction means actions that irreversibly destroy personal data so its contents cannot be recovered within the personal data information system, and/or destroy the physical media containing it.
3. Main rights and obligations of the Operator 3.1. The Operator may: – obtain reliable information and/or documents containing personal data from the data subject; – continue processing without consent after a data subject withdraws consent, where grounds under the Personal Data Law exist; – independently determine the measures necessary and sufficient to fulfil its obligations under the Personal Data Law and regulations adopted pursuant to it, unless that Law or other federal laws provide otherwise. 3.2. The Operator must: – provide information concerning processing to the data subject on request; – organise processing in accordance with applicable Russian law; – respond to data subjects and their lawful representatives as required by the Personal Data Law; – provide the competent data protection authority with the information it requests within 30 days of receiving its request; – publish or otherwise ensure unrestricted access to this Policy; – take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions; – cease transmission (dissemination, provision or access), stop processing and destroy personal data in the manner and cases established by the Personal Data Law; – fulfil other obligations established by the Personal Data Law.
4. Main rights and obligations of data subjects 4.1. Data subjects have the right to: – receive information concerning the processing of their personal data, except where federal law provides otherwise. The Operator must provide it in an accessible form without other subjects' personal data, unless there are lawful grounds for disclosure. The Personal Data Law establishes the information to be provided and the procedure for obtaining it; – require the Operator to clarify, block or destroy personal data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the declared purpose, and take legal measures to protect their rights; – require prior consent for processing intended to promote goods, works or services; – withdraw consent to personal data processing; – challenge the Operator's unlawful actions or omissions in processing before the competent data protection authority or a court; – exercise other rights under Russian law. 4.2. Data subjects must: – provide the Operator with accurate information about themselves; – inform the Operator of clarifications, updates or changes to their personal data. 4.3. Persons who provide false information about themselves or another subject's information without that subject's consent are liable under Russian law.
5. The Operator may process the following User personal data 5.1. Your name and any other information you voluntarily provide when contacting us by email, telephone or messenger. 5.2. Contact details provided for a reply: telephone number, email address or messenger username. 5.3. With separate consent to analytics, technical information about site visits processed by Yandex Metrica: cookie identifiers, browser and device information, IP address, page addresses viewed, referral sources and interaction events. Session Replay is disabled. 5.4. The above data is collectively referred to in this Policy as Personal Data. 5.5. The Operator does not process special categories of data concerning race, nationality, political views, religious or philosophical beliefs or intimate life. 5.6. Processing data authorised for dissemination within the special categories listed in Article 10(1) of the Personal Data Law is permitted if the prohibitions and conditions in Article 10.1 are observed. 5.7. Language and theme preferences are stored in the browser's localStorage as newcity-language and newcity-theme. These settings work independently of analytics consent and can be deleted in the browser settings. 5.8. Your analytics choice is stored in localStorage under newcity-analytics-consent-v1 for 180 days. You can change it using Analytics settings at the bottom of any page. 5.9. Before analytics is allowed, the site does not load the Yandex Metrica tag or send events to it. Declining leaves the site's main features available. Withdrawing consent stops the tag and removes Metrica identifiers accessible to the site from cookies and browser storage. 5.10. Yandex Metrica's cookies and their lifetimes are described in its documentation: https://yandex.ru/support/metrica/ru/general/cookie-usage.html 5.7. Consent to processing data authorised for dissemination is given separately from other processing consents. The conditions of, in particular, Article 10.1 of the Personal Data Law apply. The competent data protection authority sets the requirements for such consent. 5.7.1. The User provides consent to processing data authorised for dissemination directly to the Operator. 5.7.2. Within three working days of receiving consent, the Operator must publish the processing terms and any prohibitions or conditions on processing data authorised for dissemination by an unlimited number of persons. 5.7.3. Transmission (dissemination, provision or access) of data authorised for dissemination must stop at any time upon the data subject's request. The request must state the subject's surname, first name, patronymic if applicable, contact details (phone, email or postal address) and the data whose processing must stop. The data stated in that request may be processed only by the Operator receiving it. 5.7.4. Consent to processing data authorised for dissemination ends when the Operator receives the request described in clause 5.7.3 of this Policy.
6. Principles of personal data processing 6.1. Personal data is processed lawfully and fairly. 6.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes of collection is not permitted. 6.3. Databases containing personal data processed for mutually incompatible purposes must not be combined. 6.4. Only data relevant to the processing purposes is processed. 6.5. The content and amount of processed data must match the declared purposes. Excessive processing relative to those purposes is not permitted. 6.6. Processing ensures accuracy, sufficiency and, where necessary, relevance to its purposes. The Operator takes or ensures measures to delete or clarify incomplete or inaccurate data. 6.7. Personal data is kept in an identifiable form no longer than required for its processing purposes, unless federal law or a contract to which the subject is a party, beneficiary or guarantor establishes a retention period. Data is destroyed or anonymised once the purposes are achieved or no longer needed, unless federal law provides otherwise.
7. Purposes of personal data processing 7.1. Information provided when contacting us is processed to respond to the enquiry, discuss transportation, agree services and fulfil obligations related to the enquiry.
7.2. Consent to analytics does not mean consent to promotional mailings. Where such mailings require consent, it is obtained separately. 7.3. Visit information obtained through Yandex Metrica after the user's consent is used to analyse traffic and improve the site.
8. Legal grounds for processing personal data 8.1. The Operator's legal grounds for processing include: – Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”; – federal laws and other regulations governing personal data protection; – Users' consent to processing their personal data and data authorised for dissemination. 8.2. The site has no personal-data collection forms. When contacting us by email, telephone or messenger, users choose what information to provide. The Operator processes it to handle the enquiry where a legal basis exists. 8.3. Yandex Metrica is enabled only after a separate affirmative choice in the analytics banner. Allowing cookies or JavaScript in browser settings does not by itself count as this consent. 8.4. The data subject independently decides whether to provide personal data and gives consent freely, voluntarily and in their own interest.
9. Conditions for personal data processing 9.1. Processing is carried out with the data subject's consent. 9.2. Processing is necessary to achieve purposes established by a Russian international treaty or law, or to perform functions, powers and duties assigned to the Operator by Russian legislation. 9.3. Processing is necessary for the administration of justice or enforcement of a judicial act, or an act of another authority or official enforceable under Russian enforcement legislation. 9.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, or conclude a contract at the subject's initiative or under which they will be a beneficiary or guarantor. 9.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or achieve socially important purposes, provided the data subject's rights and freedoms are respected. 9.6. Processing concerns personal data made accessible to an unlimited number of persons by the subject or at their request (publicly available personal data). 9.7. Processing concerns personal data subject to publication or mandatory disclosure under federal law.
10. Collection, storage, transmission and other personal data processing procedures Personal data security is ensured through legal, organisational and technical measures necessary to fully meet the requirements of applicable data protection legislation. 10.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorised access. 10.2. The User's personal data will not be transferred to third parties under any circumstances, except to comply with applicable law or where the subject has consented to transfer for fulfilment of obligations under a civil contract. 10.3. If the User identifies inaccuracies in personal data, they can update it by sending a notification to the Operator's email address info@newcitymsk.ru with the subject “Personal data update”. 10.4. The processing period is determined by achievement of the purposes for which the data was collected, unless a contract or applicable law provides otherwise. The User may withdraw consent at any time by sending an email notification to the Operator at info@newcitymsk.ru with the subject “Withdrawal of consent to personal data processing”. 10.5. Information collected by third-party services, including payment systems, communications providers and other service providers, is stored and processed by those operators under their own user agreements and privacy policies. The data subject or User must familiarise themselves with those documents in a timely manner. The Operator is not responsible for third-party actions, including those of the providers described here. 10.6. The subject's prohibitions on transmission (other than access), or on processing and its conditions (other than obtaining access), do not apply to data authorised for dissemination when it is processed for state, social or other public interests established by Russian law. 10.7. The Operator ensures confidentiality when processing personal data. 10.8. The Operator retains identifiable personal data no longer than necessary for processing purposes, unless federal law or a contract to which the subject is a party, beneficiary or guarantor establishes a retention period. 10.9. Processing may cease upon achievement of its purposes, expiry or withdrawal of consent, or discovery of unlawful processing.
11. Operations performed by the Operator on personal data received 11.1. The Operator collects, records, organises, accumulates, stores, clarifies (updates or alters), retrieves, uses, transmits (disseminates, provides or grants access to), anonymises, blocks, deletes and destroys personal data. 11.2. The Operator performs automated processing, with or without transmitting or receiving information over information and telecommunications networks.
12. Cross-border transmission of personal data 12.1. When planning cross-border transfers of personal data, the Operator complies with Article 12 of the Personal Data Law, including prior notification of the authorised authority where required by law. 12.2. Connecting new services involving cross-border transfers of personal data requires a prior review of legal grounds and applicable restrictions. Cookie consent does not replace compliance with these requirements.
13. Personal data confidentiality The Operator and anyone who gains access to personal data must not disclose or disseminate it without the subject's consent, unless federal law provides otherwise.
14. Final provisions 14.1. The User can obtain explanations on any personal data processing questions by emailing the Operator at info@newcitymsk.ru. 14.2. Any changes to the Operator's personal data processing policy will be reflected here. The Policy remains effective indefinitely until replaced by a new version. 14.3. The current version of this Policy is published on this page. Changes are reflected in a new revision of the document.
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