I. General Provisions
These Provisions of the Privacy Policy (hereinafter referred to as Provisions) are an official document of the autonomous nonprofit organization Transparency International-R Centre for Anti-Corruption Research, located under the following address: Radio Str., 24-1, room XIII, Moscow, Russia 105005 (hereinafter referred to as Organization or Operator); they define the procedure for processing and protecting information on individuals (hereinafter referred to as Users) who use and receive the newsletter, use the feedback form on the website, as well as the donation form, e-mail addresses located under the domain name www.transparency.org.ru (hereinafter referred to as the Website).
We have developed a Privacy Policy that describes how we process personal data: any actions (operations) or sets of actions (operations), performed with or without means of automation, including collecting, recording, systematization, storage, revising (updating, modifying), extraction, usage, transferring (distributing, providing, accessing), depersonalization, locking, deletion, destruction of personal data.
Relations associated with processing of personal data and information on users of the Website are regulated by these Provisions, as well as other official documents of the Operator and the current laws of the Russian Federation.
Personal data is processed legally and on a fair basis, reasonably and in good faith, according to the following principles:
— lawfulness of the objectives and means of personal data processing;
— fairness and good faith;
— consistence of goals of personal data processing with the goals previously defined and revealed when gathering such data, as well as with the authority of the Organization;
— consistence of the amount and contents of the processed personal data, as well as the methods of personal data processing, with the goals of personal data processing
This Privacy Policy regulates all types of processing of personal data and all kinds of personal information (i.e. information that can be used to establish the identity, and any other types of related information) about individuals who are users of the Website.
This Policy concerns personal data processing gathered via any means, both active and passive, with or without using the Internet, from any individuals in any part of the world.
II. Collecting personal data
The objective of personal data processing is fulfilment of obligations of the Operator before the Users related to the Website and its services.
Personal data is processed only provided that the data subject consents to having their data processed.
Personal data means any information referring directly or indirectly to a particular or identified individual (the data subject) and which can be used to identify a particular individual or to contact them.
We may request your first and last name, patronymic and e-mail address to include you in our mailing list with your consent, and also to provide you with an answer if you contacted us through the feedback form on our Website.
III. Storage and usage of personal data
Personal data of Users is stored exclusively in electronic format and processed using automation systems except cases when non-automated processing of personal data is necessary due to legal requirements.
HOW WE USE YOUR PERSONAL DATA
The personal data that we collect allow us to send to your e-mail information about the news concerning the Organization, releases of new anti-corruption investigations and various events (mailing list). Also, your personal data may be used to provide you with an answer to your query sent via the feedback form or the Organization’s e-mail address, both available on the Organization’s Website.
If you have used the donation form on the Website, we may send you replies to your e-mail address and include you in the mailing list. If you do not wish to be included in our mailing lists, you can inform us about your wish not to receive out newsletter by using the specified means of feedback.
Occasionally, we can use your personal data to send important notifications that include information about changes in our terms, conditions and policies.
COLLECTING AND USAGE OF DATA THAT IS NOT PERSONAL
We also collect data that is not personal, i.e. data that can not be directly associated with a particular individual. We can collect, use, transfer and disclose data that is not personal for any purposes. Below are examples of data that is not personal which we collect, and how we may use it.
IDENTIFICATION FILES (COOKIES) AND OTHER TECHNOLOGIES
The Website, interactive services and applications, e-mail messages and any other communication by the Organization may use identification files (cookies) and other technologies, i.e. pixel tags and web beacons. Therefore when you’re using the Website or other services, your device may display a pop-up window with the notification on the use of cookies.
These technologies allow us to better understand the behaviour of the users; they show us which sections of our Website were visited by the users, and they help measure the efficiency of ads and online searches. We regard data gathered through cookies and other technologies as not personal.
You can control cookies by following the instructions from your browser or device. Usually you can change the cookie settings in the sections called Settings or System Preferences.
As most websites do, we collect some information automatically and store it in statistics files. Such information includes the IP address, the type and the language of the browser, information on the Internet service provider, information about the operating system, a date and time stamp and the clickstream data. We use this information to understand and analyze tendencies, to administer the Website, to study the behavior of users on the Website and to gather demographic information about our key audience in general. The Organization may use such information for its marketing purposes.
In some of our e-mail messages, we use interactive links to the information published on the Organization’s Website. When users follow such links, their requests are backlogged separately before they can access the requested page on the Website. We track such “transitional” data to help us identify the level of interest towards certain topics and measure the efficiency of our communication with users. If you prefer not to have your requests tracked in this way, you should not follow text or graphic links in the e-mail messages.
Pixel shortcuts allow us to send e-mail messages in a format readable to consumers, and they let us know whether such messages were read. We can use such information to limit the amount of messages sent to consumers, or to stop sending them.
IV. Transfer of personal data
Personal data of Users shall not be transferred to any third parties except cases directly provided for in this Regulation.
User’s personal data may be processed for an unlimited period of time by any legal means, including usage of personal data information systems and means of automation, or lack thereof.
Users who had provided their personal data to us before this Regulation’s entry into force automatically consent to use of their personal data. At the same time, they can at any time withdraw their consent to use of their personal data by using the feedback form.
Operator shall block the personal data of a User from the date of a request from the User, their legal representative or an authorized body for protection of the rights of subjects of personal data for the period of the examination in case inaccurate personal data or misconduct have been identified.
User’s personal data may only be transferred to authorized government agencies of the Russian Federation on the grounds and in the manner prescribed by the law of the Russian Federation.
OTHER PERSONS
Organization might have to — under the law, by a court order, in legal proceedings and/or in response to an enquiry from government bodies located in our outside of the country of your residence — to disclose your personal data. We may also disclose your personal data/information about you if we determine that such disclosure is necessary or appropriate for reasons of national security, maintenance of law and order, or in other cases of considerable importance to society.
V. Destruction of personal data
A User’s personal data shall be destroyed if the data subject withdraws their personal data processing consent.
VI. Data protection
The Organization takes precautionary measures — legal, organizational, technical and physical — to ensure the protection on your personal data in accordance with article 19 of the Russian Federal Law on Personal Data (No. 152-FZ) from 26 June 2006 in order to protect the User’s personal data from unauthorized or random access, destruction, modification, locking, copying, distributing, as well as other kinds of misconduct by third parties.
INTACTNESS AND PRESERVATION OF PERSONAL DATA
By interacting with the Organization, you can easily maintain your personal data up to date. We will store your personal data and information as long as it’s necessary to fulfill the goals described in this Privacy Policy except for the cases when a longer storage of data and information is required by the law or is allowed by the law.
We do not collect any data about underage persons. If we discover that we received personal data of an underage person, we will take measures to delete such information as soon as possible.
We highly recommend parents and other persons who care for underage persons (legal representatives — parents, adoptive parents or trustees) to control how underage persons use websites.
The Operator shall not be liable for actions of third persons who, by using the internet of the services of the Website. gained access to information on the User, or for the consequences of using the data and information that, due to the nature of the Website, are available to any Internet user.
RESPECT FOR YOUR PRIVACY AT THE ORGANIZATION LEVEL
To ensure the security of your personal data, we inform the employees of the Organization about the rules of maintaining privacy, and we strictly monitor the implementation of privacy maintaining measures within the Organization.
QUESTIONS REGARDING PRIVACY
If you should have any questions regarding the Organization’s Privacy Policy or data processing, you may contact us using the contact details on http://transparency.org.ru/contacts/
VII. User queries
This Privacy Policy and relations between the User and the Operator are subject to the current laws of the Russian Federation.
Users can send the Operator requests, including requests that concern the usage of their personal data and requests to withdraw their personal data processing consent to the address specified in the General Provisions section of this document, or in the form of an electronic document signed with a qualified electronic signature in accordance with the law of the Russian Federation and sent through the feedback form.
The Operator shall review the User’s query and reply to it within 30 days from the receipt of the query.
OTHER PROVISIONS
All other matters not covered by the present Privacy Policy shall be governed by the regulations and provisions of the Russian Federal Law on Personal Data (No. 152-FZ).
A visitor of the Organization’s Website who provides their personal data and information thereby consents to the terms and conditions of this Privacy Policy.
The Organization reserves the right to make any changes in the Policy at any time at its own discretion to further improve the system of protection of the personal data provided by the Users from unauthorized access without the User’s consent. When we make significant changes in the Privacy Policy, we publish a relevant notification on our website, along with the updated version of the Privacy Policy.
The present Policy does not cover the activities and Internet resources of third parties.