А. INTRODUCTION 

The privacy of our website is very important to us, and we are committed to protecting it. This policy explains what we will do with your personal data.

This Security and Personal Data Protection Policy (hereinafter referred to as the “Policy”) covers issues related to the personal data of individuals collected and processed by the Municipality of Smyadovo through the website https://smiadovovetrinoboliarovo.com/ (hereinafter referred to as the “Site,” “Website,” or “Internet page”) electronically (via email), by phone, or through other means by which an individual (hereinafter referred to as the “Data Subject”) voluntarily provides their data. The website is administered by employees of the Municipality of Smyadovo. In the processing of personal data, the data controller complies with all applicable regulations concerning the protection of personal data, including but not limited to Regulation (EU) 2016/679 (“Regulation”) and the Personal Data Protection Act, because the security of personal data of individuals (inquirers, clients, suppliers, employees, others) is of paramount importance to us. You can contact us through the Site or by other means.

The Policy contains information about individuals who provide their personal data or data of third parties. The document describes in detail who processes the data (data controller), whose data the data controller processes (categories of data subjects), what data of individuals are processed, how the data controller collects, processes, uses, and protects this data, and what rights data subjects have regarding the processing of their data in accordance with Regulation (EU) 2016/679 – the General Data Protection Regulation (commonly known as the GDPR). Any individual who has provided data on any occasion should familiarize themselves with this Security and Personal Data Protection Policy.

No third party can access personal data without having previously entered into a data confidentiality agreement, which imposes obligations on the third party no less burdensome than those undertaken by the municipality and grants the same the right to perform checks on compliance with the obligations imposed by the agreement.

This policy also applies to all employees of the company and to external suppliers of products and services with whom it has contracts. Any breach of the General Regulation will be treated as a violation of labor discipline or as non-performance of contracts with partners, and if there is a suspicion of a committed crime, the matter will be submitted for review to the relevant state authorities.

For visitors to the Site who do not submit inquiries through the contact form but only view our internet page, the Cookie Policy published on the Site applies. Please note that this Security and Personal Data Protection Policy does not apply to legal entities (commercial companies and non-profit legal entities).

B. COLLECTION OF PERSONAL DATA

The following types of personal information may be collected, stored, and used:

• Information about your computer, including your IP address, geographical location, type and version of your browser, and operating system;
• Information about your visits and usage of this website, including referral source, visit duration, page views, and website navigation;
• Information such as your email address that you enter when registering on our website;
• Information you enter when creating a profile on our website, such as your name, profile picture, gender, date of birth, marital status, interests and hobbies, education, and occupation;
• Information such as your name and email address that you have provided to set up subscriptions to our emails and/or newsletters;
• Information you enter while using our website’s services;
• Information generated while you use our website, including when, how often, and under what circumstances you use it;
• Information related to everything you purchase, services you use, or transactions you make through our website, which may include your name, address, phone number, email address, and credit card information;
• Information you post on our website with the intention of publishing it on the internet, including your username, profile picture, and the content of your posts;
• Information contained in any communication with us, sent via email or through our website, including the content of the communication and metadata;

• Any other personal information that you send to us.

Before you share your personal data with us, we must obtain your consent for this disclosure and for the processing of this personal information in accordance with this policy.

C. USE OF PERSONAL DATA

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website. We may use your personal information for:

• Administering our website and business.
• Personalizing our website for you.
• Enabling your use of the services available on our website.
• Sending you articles purchased through our website.
• Delivering services purchased through our website.
• Sending you statements, invoices, and payment reminders, as well as collecting payments from you.
• Sending you non-marketing communication.
• Sending you email notifications that you have specifically requested.
• Sending you our email newsletter, if you have subscribed (you can inform us at any time if you no longer wish to receive the newsletter).
• Sending you marketing communications related to our business or the businesses of carefully selected third parties that we believe may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer wish to receive marketing communications).
• Providing third parties with statistical information about our users (but those third parties will not be able to identify individual users from that information).
• Dealing with inquiries and complaints made by or about you relating to our website.
• Keeping our website secure and preventing fraud.
• Verifying compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website service).
• Other purposes.

If you provide personal information for publication on our website, we will publish it, and otherwise, we will use this information in accordance with the permission you provide us.

Your personal settings can be used to limit the publication of your information on our website and can be managed through our website’s control panel.

We will not provide your personal information to third parties for their or anyone else’s direct marketing without your explicit consent.

Depending on the reason necessitating the processing of personal data, the type of data may vary. The functionalities provided on the website are not intended for storing and processing special categories of data within the meaning of Article 9 and Article 10 of the Regulation (see Article 9 and Article 10 of the Regulation here). We only require personal data that is necessary for providing the service requested by the individual. During the use of the website https://smiadovovetrinoboliarovo.com/ by individuals, employees may also process other data that do not contain personal information but pertain to the subject, such as their IP address, data about their activity on the website, and similar information.

Depending on the specific action, we collect the following data:

Your names.
Address.
Email address.
Contact phone number.

If you provide your personal data via Viber, Skype, Facebook, or any other platform/social network, please be aware that these platforms/websites/social networks have their own privacy policies, and we do not take any responsibility for these policies since their processing cannot be controlled by us. In this regard, we recommend that you review these policies before sending us your personal data via these websites/applications/platforms.

If you leave a comment or post on the website, your IP address will be saved. This is for the security of the website operator. Additionally, because sending comments, inquiries, and other messages to the website, Facebook page/group, or their administrators constitutes sending an electronic statement according to the Electronic Document and Electronic Authentication Services Act (“EDEASA”), OSА is obligated to maintain logs of the submission of the statement for a period of 1 year. The log includes the date of the statement, the name, and email address of the sender if provided.

If you provide us with personal information about someone else, you should only do so with their authorization. You should inform them about how we collect, use, disclose, and store personal information in accordance with this Security Policy for the personal data of individuals.

When connecting your profile on the website to your Facebook or Google profile or to other third-party services (currently, this functionality is not available), we receive information from those profiles (e.g., friends or contacts). The information we receive from these services depends on their settings and privacy statements, so each individual should check what they are.

During the execution of our activities:

In the course of carrying out our activities, we may obtain a variety of personal data concerning both you and third parties. Therefore, it is not excluded that in the performance of our services, it may be necessary for us to process personal data, including:

• Sensitive personal data – these are data that reveal racial or ethnic origin; political, religious, or philosophical beliefs; membership in trade unions; genetic and biometric data; data concerning health, as well as data concerning sexual life or sexual orientation; bank accounts and banking transactions, data from intimate life, and so on;
• Other data, including personal data – data concerning property status, marital status, employment history, financial status, legal and extrajudicial claims against and by you, data concerning cases filed against and by you, data regarding counterparties, and so on;
• Personal data for individuals under and over the age of 16.

D. NOTIFICATION OF PERSONALDATA

We may disclose your personal data to any of our employees, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

• To the extent that we are required to do so by law.
• In connection with any ongoing or prospective legal proceedings.
• In order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
• To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling.

Except as provided in this policy, we will not provide your personal information to third parties.

E. INTERNATIONAL DATA TRANSFERS

The information we have collected may be stored, processed, and transferred between any of the countries in which we operate to enable us to use the information in accordance with this policy.

The information we have collected may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: United States, Russia, Japan, China, and India.

Personal information that you publish or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

You expressly agree to the transfers of personal data described in this section E.

F. RETENTION OF PERSONAL INFORMATION

This Section F outlines our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Without prejudice to Section E-2, we will usually delete personal data falling into the categories set out below at the time or date specified below:

Personal data will be deleted within 12 months of its provision.

Notwithstanding the other provisions of Section F, we may retain documents (including electronic documents) containing personal data:

• To the extent that we are required to do so by law.
• If we believe that the documents may be relevant to any ongoing or prospective legal proceedings.
• In order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

G. SECURITY OF YOUR PERSONAL INFORMATION

We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.

We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

H. CHANGES

From time to time, we may update this policy by publishing a new version on our website. You should check this page to ensure that you understand all the changes to the policy. We may notify you of changes to this policy by sending you an email or through our website’s personal messaging system.

I. YOUR RIGHTS

You can instruct us to provide you with any personal information we hold about you – providing such information will be subject to the following:

We may withhold personal information that you request to the extent permitted by law.

You can instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.

J. THIRD-PARTY WEBSITES 

Our website includes hyperlinks to websites of third parties and details about them. We have no control and are not responsible for the privacy policies and practices of third parties.

K. UPDATING INFORMATION

Please let us know if your personal information we store needs to be corrected or updated.

L. DATA PROTECTION OFFICER

The Data Protection Officer is ____

Mailing Address: ____