Personal Data Processing Policy

  1. General Provisions

This personal data processing policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal information taken by Oriental City Soft LLC (hereinafter referred to as the Operator). 

1.1 The Operator's most important goal is to respect human and civil rights and freedoms while processing personal data, including protecting the right to privacy and personal and family secrets.

1.2 This Policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information the Operator receives about visitors to our website https://oriental-consulting.cn.com.

  1. The main concepts used in the Policy:

2.1 Automated processing of personal data - processing of personal information using computer technology.

2.2 Blocking of personal data - temporary termination of processing personal data (except in cases where processing is necessary for clarifying personal data).

2.3 Website - a set of graphical and informational materials, as well as computer programs and databases, which ensure their availability on the internet at the address https://oriental-consulting.cn.com.

2.4 Personal data information system - a set of personal information contained in databases, and information technologies and technical means that support their processing.

2.5 Depersonalization of personal data - actions that make it impossible to identify whether personal data belongs to a particular user or another subject without additional information.

2.6. Processing of Personal Data - Any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collecting, recording, organizing, accumulating, storing, clarifying (updating, modifying), extracting, using, transferring (distributing, providing, access), depersonalizing, blocking, deleting, or destroying personal data.

2.7. Operator - A state body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or processes personal data, determines the purpose of processing, the composition of data to be processed, and the actions to be taken with personal data.

2.8. Personal data - Any information directly or indirectly related to a specific user of the website https://oriental-consulting.cn.com.

2.9 Personal data authorized for distribution by the data subject - personal data that any number of people have access to, given by the data subject's permission to process personal data, which is authorized for distribution in accordance with the procedures provided for in the Personal Data Protection Law (hereinafter referred to as "personal data authorized for distribution").

2.10 User - any person visiting the website https://oriental-consulting.cn.com.

2.11. Providing personal data - actions aimed at revealing personal data to a specific person or a group of people.

2.12. Sharing personal data - any actions aimed at sharing personal data with an indefinite number of people (transfer of personal data), or making personal data accessible to an unlimited number of individuals, including publishing it in mass media, posting it on information and telecommunication networks, or otherwise providing access to it.

2.13. Transborder transfer of personal data - transfer of personal data outside the country's territory to a foreign authority, a foreign natural person, or a foreign legal entity.

2.14. Erasing personal data - any action that permanently destroys personal data, rendering it impossible to recover the content of the data in the information system, and/or destroys the material carriers.

  1. Basic Rights and Obligations of the Operator

3.1 The Operator has the right to:

3.2 The Operator is obligated to:

  1. Basic Rights and Obligations of personal data subjects

4.1. Personal data subjects have the right to:

- receive information related to the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject in an accessible form by the Operator, and it should not contain personal data related to other personal data subjects, unless there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;

- require the operator to clarify their personal data, block or delete it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;

- set a condition for prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market.

- To withdraw consent to the processing of personal data and send a request to stop the processing of their personal data;

- Appeal to the authorized body for protection of personal data rights or in court against any illegal actions or omissions by the Operator while processing their personal information;

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

4.2. Data subjects are required to: 

- Provide the Operator with accurate information about themselves;

- Inform the Operator about clarifications (updates or changes) to their personal details.

4.3. People who provide false information to the Operator or share information about other people without their consent are liable in accordance with the laws of the Russian Federation.

  1. Principles of Personal Data Processing

5.1. Personal data is processed in a lawful and fair manner.

5.2. Personal data is only processed to achieve specific, clearly defined, and legitimate objectives. It is not allowed to process personal data for purposes that are not compatible with the original reasons for collecting it.

5.3. Databases containing personal data processed for incompatible purposes must not be combined.

5.4. Only personal data relevant to the purposes of its processing should be processed.

5.5. The content and scope of the processed personal data must align with the stated objectives of processing. It is not acceptable to have excessive personal data processed when it is not necessary for the stated purposes.

5.6. The accuracy, completeness, and relevance of personal data are ensured during the processing. If necessary, the Operator takes the necessary measures to delete or clarify any incomplete or inaccurate information.

5.7. Personal data is stored for as long as necessary to complete the purpose of processing, but not longer than is required. This period may be extended if permitted by federal laws, agreements to which the individual is a party or beneficiary, or guarantor. Once the purposes of processing are achieved or no longer require personal data, it is either destroyed or made anonymous. However, this may not apply if the law requires otherwise.

6. Purposes of Personal Data Processing
Purpose of Processing: Informing the User through Emails
Personal Data: Last name, First name, Patronymic, Email address, Phone numbers
Legal Grounds: Statutory (Constituent) Documents of the Operator
Types of Personal Data Processing: Sending Informational Letters to the Email Address
  1. Conditions for personal data processing

7.1. Personal data processing is carried out only with the consent of the data subject, who has the right to object to such processing.

7.2. Personal data is processed to achieve goals specified by the international agreement of the Russian Federation or by law, for the purpose of fulfilling the functions and duties assigned by the operator to the legislation of the Russian Federation.

7.3. Personal data may also be processed for the purpose of administering justice, executing a judicial decision, or an act issued by another body or official, which is subject to enforcement in accordance with Russian legislation on enforcement proceedings.

7.4. Processing of personal data is necessary for the execution of a contract in which the data subject is a party, beneficiary, or guarantor. It is also necessary for concluding a contract at the initiative of the data subject or for a contract under which the data subject will become a beneficiary or guarantor.

7.5. Processing is necessary to protect the rights and interests of the controller or third parties or to achieve social goals, provided that the data subject's rights and freedoms are not violated.

7.6. Personal data that is publicly available, i.e., data that has been made available to an unlimited number of people by the data subject or upon their request, is processed. 

7.7. Data subject to publication or mandatory disclosure under federal law is also processed.

  1. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data

The security of personal data processed by the Company is ensured by implementing legal, organizational, and technical measures necessary to comply fully with the requirements of current legislation in the field of data protection.

8.1 The Company ensures the safety of personal data and takes all possible measures to prevent unauthorized access to such data.

8.2 The Company will never transfer the User's personal data to third parties under any circumstances, except in cases related to compliance with current legislation or when the data subject has provided consent to such transfer to a third party to fulfill obligations under a civil agreement.

8.3. If any inaccuracies in the user's personal data are detected, the user can update them by sending a message to the operator's email address, info@orientalcity.org, with the subject "Updating personal data".

8.4. The period of time during which the operator will process the user's data is determined by the purpose for which the data was collected. Unless another time period is specified in the contract or applicable laws, the user may withdraw their consent to have their personal data processed at any time by contacting the operator via email at the operator's address info@orientalcity.org with the subject line "Revocation of Consent to Personal Data Processing".

8.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by the specified parties (Operators) in accordance with their respective requirements. The User Agreement and Our Privacy Policy govern the use of personal data, and the Operator is not liable for the actions of third parties, including service providers mentioned in this clause.

8.6. The restrictions that a person places on the transfer (except for providing access), processing, or conditions of processing (except for gaining access) of personal data intended for dissemination do not apply in cases where personal data is processed in the interests of the state, public, or other public interests as defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data while processing it.

8.8. The Operator stores personal data in a way that allows identification of the data subject, for no longer than necessary for the purposes of processing the personal data, unless a longer storage period is mandated by federal law or an agreement where the subject of personal data is a party, beneficiary, or guarantor.

8.9. The reasons for stopping the processing of personal data can be:

  1. List of Actions Performed by the Operator with Received Personal Data

9.1 The Operator collects, records, organizes, stores, updates, extracts, uses, distributes, provides access to, anonymizes, blocks, removes, and destroys personal data.

9.2 The Operator performs automatic processing of personal data, with or without the receipt and/or transmission of the received information through information and communication networks.

  1. Cross-border Transfer of Personal Data

10.1 The Operator is required to notify the relevant authority for the protection of personal data rights of its intention to transfer personal data across borders (this notification should be sent separately from the notice of intent to process personal data).

10.2 Before submitting this notification, the operator must obtain relevant information from authorities of the foreign state, as well as from foreign individuals and legal entities to whom the transfer of personal data will be made.

  1. Confidentiality of Personal Data

The operator and any other persons who have access to personal data must not disclose or share personal data with third parties without the individual's consent, unless otherwise required by federal law.

  1. Final Provisions

12.1 The User may contact the Operator via email at info@orientalcity.org to obtain any clarifications regarding questions related to the processing of their personal data.

12.2 This document will be updated to reflect any changes to the Operator's policy on the processing of personal data. The policy will remain in effect until a new version replaces it.

12.3 The current version of this Policy is available on the internet at https://oriental-consulting.cn.com/privacy/