Policy regarding the processing of personal data
Политика обработки персональных данных
Please read the following statement carefully, then acknowledge that you have read and agree to it.
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by “Beko” LLC, “IHP Appliances Sales” LLC, “IHP Appliances” JSC, (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors to the http://www.ethicsline.ru/ website.
2. General definitions used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data is a temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address of the http://www.ethicsline.ru/.
2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data - actions, as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. 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 to be processed, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the http://www.ethicsline.ru/ website.
2.9. Personal data authorized by the subject of personal data for distribution - personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data permitted for distribution).
2.10. User - any visitor to the website http://www.ethicsline.ru/.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquaintance with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and / or material carriers of personal data are destroyed.
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 subject of personal data;
- if the subject of personal data withdraws consent to the processing of personal data, as well as sending an appeal with a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 provided for 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.
3.2. The Operator shall:
- provide the subject of personal data, at his request, with information regarding the processing of his personal data;
- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 10 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 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 provided for by the Law on Personal Data;
- perform other duties provided for by the Law on Personal Data.
4. Basic rights and obligations of subjects of personal data
4.1. Subjects of personal data have the right to:
- receive information regarding the processing of his personal data, with the exception of cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should 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 is established by the Law on Personal Data;
- require the operator to clarify his personal data, block or destroy them 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;
- put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
- to withdraw consent to the processing of personal data, as well as to send a request to stop the processing of personal data;
- appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or inaction of the Operator in the processing of his personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
- rovide the Operator with reliable data about themselves;
- inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, 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. Principles of personal data processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is ensured. The operator takes the necessary measures and / or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that makes it possible to determine the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
6. Purposes and methods of personal data processing
Purpose of processing
processing of the User's messages about the facts of theft, fraud, corruption or other violations of the Operator's policy in the field of ethical business conduct and other issues in the field of ethics and compliance;
Categories of subjects of personal data
representatives or employees of the Operator's clients and contractors
Personal data
- surname, name, patronymic
- e-mail address
- phone Number
- post
Legal basis
- The Operator processes the personal data of the Clients on the basis of contracts concluded with the Users, in relation to the personal data of the Users, or on other grounds provided for by law;
- The operator takes all necessary measures to comply with the requirements of the law, does not process personal data in cases where this is not allowed by the legislation of the Russian Federation, does not use personal data to the detriment of the subjects of such data
Methods of collecting and processing personal data
- Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data;
- Filling out the relevant forms on the website by the User;
- Sending letters to the e-mail address report@ethicsline.ru;
- The operator has the right to transfer (provide, access) my personal data for the purpose specified in this Policy to the following third parties: DRT Consulting LLC, address: Russia, 125047, Moscow, Lesnaya str., 5; JSC "Business Solutions and Technologies", address: Russia, 125047, Moscow, Lesnaya str., 5; “Beko” LLC, “IHP Appliances Sales” LLC, “IHP Appliances ” JSC, address: 398040, Lipetsk region, Lipetsk, Metallurgov Square, 2; LLC "BEKO", address: 601021, Russia, Vladimir region, Kirzhach district, municipal formation rural settlement Pershinskoye, Fedorovskoye village, Selskaya street, 49; as well as the sole founder of the Operator - ARÇELIK A.Ş. JOINT STOCK COMPANY (ARÇELIK A. Ş.), established and registered in accordance with the laws of Turkey, registration number 54957, whose registered office is located at the address: Turkey, Istanbul, 34445, Sütlüce Karaağaç Street No. 2-6 Beyoğlu, as well as other organizations providing audit or consulting services under an agreement with the Operator for the purpose of conducting an audit and / or verifying information, contained in the User's message.
- The operator entrusts the processing of personal data to DRT Consulting LLC, address: 5 Lesnaya St., Moscow, 125047, Russian Federation; JSC "Business Solutions and Technologies", address: Russia, 125047, Moscow, Lesnaya str., 5, in order to consider appeals on ethics and compliance;
- The operator has the right to entrust the processing of personal data to “Beko” LLC, “IHP Appliances Sales” LLC, “IHP Appliances ” JSC, address location: 398040, Lipetsk region, Lipetsk, Metallurgov Square, 2; LLC "BEKO", address location: 601021, Russia, Vladimir region, Kirzhach district, Pershinskoye rural settlement, Fedorovskoye village, Selskaya street, 49; as well as the sole founder of the Operator - ARÇELIK A.Ş. Joint Stock Company, established and registered in accordance with the laws of Turkey, registration number 54957, whose registered office is located at the address: Turkey, Istanbul, 34445, Sütlüce Karaağaç Street No. 2-6 Beyoğlu, as well as other organizations that provide audit or consulting services under an agreement with the Operator for the purpose of considering an appeal on ethics and compliance issues.
Storage limitation
During the term of the contract with the User (unless otherwise provided by the Agreement and the legislation of the Russian Federation)
Order of destruction
- Destruction of paper carriers containing personal data is carried out by shredding papers by means of a shredder;
- The destruction of personal data from information systems is carried out by the built-in means of the information system
7. Conditions for the processing of personal data
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. 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.
7.4. The processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.
7.5. 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 subject of personal data are not violated.
7.6. The processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. The procedure for the collection, storage, transfer and other types of processing of personal data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's e-mail address dataprivacy@ihpappliances.ru marked "Updating personal data".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or applicable law.
The user can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator's email address dataprivacy@ihpappliances.ru marked "Revocation of consent to the processing of personal data".
8.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and / or with the specified documents. The operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public and other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the operator ensures the confidentiality of personal data.
8.8. The operator stores personal data in a form that makes it possible to determine the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or the requirement to stop processing personal data, as well as the identification of illegal processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The operator carries out automated processing of personal data with or without the receipt and / or transmission of the received information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Prior to the start of activities for the cross-border transfer of personal data, the operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above notification, the operator is obliged to receive relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final provisions
12.1. The user can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail dataprivacy@ihpappliances.ru.
12.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://www.ethicsline.ru/.
"I have always tried to do the right thing,
I feel great peace in the belief that
I am serving my family, my country
and the era in which I live."
Vehbi Koç, Founder
"Koç Group" means Joint Stock Company "Koç Holding" (Koç Holding A.Ş.), companies which are controlled directly or indirectly by Koç Holding A.Ş. and any other its affiliated and / or subsidiaries.
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