Privacy policy

The policy of processing of personal data is made according to requirements of the Federal law from 27.07.2006. This policy defines the procedure of personal data processing and measures to ensure security of personal data taken by Elite Real Estate LLC (hereinafter, the «Operator»).

1. The Operator's most important goal and condition for carrying out its activities is to observe human and civil rights and freedoms when processing personal data, including protection of rights to privacy, personal and family confidentiality.
2. This Operator's personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the https://prime.su website.

1. Automated processing of personal data - processing of personal data by means of computer technology.
2. Blocking of personal data - temporary suspension of processing of personal data (unless the processing is necessary to clarify personal data).
3. Website is an aggregate of graphic and informational materials as well as computer programs and databases making them available on the Internet at the network address https://prime.su.
4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring processing of personal data.
5. De-identification of personal data - actions, as a result of which it is impossible to determine, without the use of additional information, the identity of personal data to a specific User or other subject of personal data.
6. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data.
7. Operator - a state body, municipal authority, legal entity or individual, independently or jointly with other persons, arranging and/or performing the processing of personal data, as well as determining the purpose of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the https://prime.su website.
9. Personal data, authorised by the subject of personal data for distribution - personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, authorised by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, authorised for distribution).
10. A user is any visitor to the https://prime.su website.
11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data to an unlimited circle of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity.
14. Destruction of personal data is any action, as a result of which personal data is destroyed irretrievably with the impossibility of further restoration of personal data content in the information system of personal data and/or destruction of material media of personal data.

1. The operator has the right:
   

   — Receive from the subject of personal data reliable information and/or documents containing personal data;

   — In case the personal data subject withdraws consent to personal data processing, as well as in case of sending a request to cease personal data processing, the Operator shall be entitled to continue personal data processing without personal data subject's consent, if there are grounds specified in the Personal Data Law;

   — Independently determine the composition and list of measures necessary and sufficient to ensure fulfilment of obligations provided by the Personal Data Law and regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

2. The operator is obligated to:

   — Provide the personal data subject, at his or her request, with information relating to the processing of his or her personal data;

   — Organise personal data processing in the manner prescribed by the applicable laws of the Russian Federation;

   — To respond to requests and enquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Law on personal data

   — Notify the authority responsible 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 request

   — Publish or otherwise ensure unrestricted access to this Policy on personal data processing

   — To take legal, organisational and technical measures for protection of personal data from unauthorised or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful acts in relation to personal data

   — Cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law

   — Perform other duties provided by the Personal Data Law.

1. Personal data subjects have the right:

   — To receive information relating to the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the operator in an accessible form and shall not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it are set out in the Personal Data Act;

   — to require the operator to clarify his personal data, to block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and to take statutory measures to protect his rights;

   — to condition prior consent when processing personal data for the purpose of promoting goods, works and services on the market

   — to withdraw the consent to the processing of personal data, as well as to request the termination of personal data processing

   — complain to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the operator in the processing of his personal data

   — Exercise other rights provided by the legislation of the Russian Federation.

2. Personal data subjects is obligated to:

   — Provide the Operator with reliable data about themselves;

   — Inform the operator of any clarification (updating, modification) of their personal data.

3. Persons who have provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.

1. Processing of personal data shall be limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.
2. Databases containing personal data whose processing is incompatible with each other shall not be merged.
3. Only personal data that meets the purposes for which it is being processed shall be processed.
4. The content and scope of the processed personal data correspond to the stated processing purposes. No excessive processing of personal data in relation to the stated processing purposes shall be permitted.
5. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purpose of personal data processing shall be ensured. The operator shall take necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
6. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than the purposes of personal data processing require, unless the period of storage of personal data is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor under which the personal data subject is a beneficiary. Processed personal data shall be destroyed or depersonalised upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.

Purpose of processing:

* informing the User by sending emails

Personal data:

* first name, surname and patronymic
* email address
* telephone numbers

Legal basis

* Federal Law "On Information, Information Technologies and Information Security" dated 27.07.2006 N 149-FZ

Types of personal data processing

* Collection, recording, systematisation, accumulation, storage, destruction and anonymization of personal data
* Sending information letters to an email address

1. Processing of personal data shall be carried out with the consent of the personal data subject to processing of his/her personal data.
2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
3. Processing of personal data shall be necessary for administration of justice, execution of a judicial act, act of another authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
4. Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or a guarantor under which the personal data subject is a party, as well as for conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or a guarantor.
5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant objectives, provided that the rights and freedoms of the personal data subject are not thereby violated.
6. Personal data may be processed to which access has been granted to an unlimited number of persons by the personal data subject or at the subject's request (hereinafter, "publicly available personal data").
7. Personal data subject to publication or compulsory disclosure in accordance with federal law shall be processed.

Security of personal data processed by the Operator shall be ensured by implementing legal, organisational and technical measures necessary to comply fully with the requirements of applicable legislation in the area of personal data protection.

1. The Operator ensures the security of personal data and takes all possible measures to exclude access to personal data by unauthorised persons.
2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases connected with the execution of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfil obligations under a civil law contract.
3. If inaccuracies in the personal data are identified, the User may update the personal data themselves by sending a notification to the Operator's e-mail address info@prime.su, marked "Update of personal data".
4. The time period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different time period is stipulated by the agreement or applicable law. The user may withdraw his consent to the processing of personal data at any time by sending the Operator a notification via e-mail to the Operator's e-mail address info@prime.su with the note "Withdrawal of consent to the processing of personal data".
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 said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or with the said documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
6. The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than gaining access) of personal data permitted for distribution shall not apply in cases of processing of personal data for state, public and other public interests as defined by Russian law.
7. The Operator shall ensure the confidentiality of personal data when processing personal data.
8. The operator shall store personal data in a form enabling the identification of the personal data subject, for no longer than is required by the objectives of personal data processing, unless the period of storage of personal data is established by federal law, by a contract to which the personal data subject is a party, a beneficiary or a guarantor under which the personal data subject is a beneficiary.
9. A condition for termination of personal data processing may be achievement of the personal data processing objectives, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject

1. The operator shall collect, record, systematise, accumulate, store, clarify (update, change), extract, use, transmit (distribute, provide, access), anonymise, block, delete and destroy personal data.
2. The operator carries out automated processing of personal data with or without receipt and/or transmission of received information via information and telecommunication networks.

1. The operator shall notify the competent authority for personal data protection of its intention to transfer personal data across borders (such notification shall be sent separately from the notification of intention to process personal data) before carrying out the transborder transfer of personal data.
2. The Operator shall, prior to submitting the aforementioned notice, obtain the relevant information from the foreign authorities, foreign natural persons, foreign legal persons to whom the cross-border transfer of personal data is intended to take place.

The operator and other persons who have obtained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

1. The User may obtain any clarification on questions of interest regarding the processing of their personal data by contacting the Operator by email at info@prime.su.
2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
3. The current version of the Policy is freely available on the Internet at https://prime.su/privacy/.