Approved by the General Director of LLC “ТАС”
Order № 1-ПДн dated «05» February 2026
1. GENERAL PROVISIONS
1.1.This policy regarding the processing of personal data (hereinafter — “Policy”) has been developed in compliance with the requirements of part 1 of article 18.1 of the Federal Law of 27.07.2006 No. 152-ФЗ “On Personal Data” (hereinafter — “Personal Data Law”) in order to ensure the protection of the rights and freedoms of a person and citizen when processing his personal data, including protection of the rights to privacy, personal and family secrecy.
1.2.This Policy applies to the following categories of personal data subjects processed by the Operator:
- Representatives of customers — natural persons acting as representatives of legal entities, individual entrepreneurs, state authorities, state corporations, public-law companies, management bodies of state extra-budgetary funds, state budgetary institutions and enterprises with which the Operator concludes contracts or negotiates contracts, as well as interacts in the course of contract performance;
- End users of the VideoGrace software — natural person users of the cloud demonstration version of the VideoGrace software;
- Users of the Operator’s Site videograce.ru — natural persons registering on the Site, submitting requests for consultation or demonstration, contacting support service, subscribing to mailings or otherwise interacting with the Operator through the Site.
1.3.Key concepts used in the Policy:
Personal data — any information relating to a directly or indirectly identified or identifiable natural person (data subject);
Personal data operator (Operator) — Limited Liability Company “ТАС” (TIN 7814784685, OGRN 1207800176561, address: 197375, Saint Petersburg, Verbnaia St., 27, building A, room 4N, office 103), independently or jointly with other persons organizing and/or carrying out the processing of personal data, and also determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
Processing of personal data — any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools. Processing of personal data includes, among other things: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction;
Automated processing of personal data — processing of personal data using computing equipment;
Distribution of personal data — actions aimed at disclosing personal data to an indefinite circle of persons;
Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons;
Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data);
Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or as a result of which the material carriers of personal data are destroyed;
Anonymization of personal data — actions as a result of which it becomes impossible, without using additional information, to determine the belonging of personal data to a specific data subject;
Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing;
Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a state authority of a foreign state, a foreign natural person or a foreign legal entity;
Site — a set of programs for electronic computing machines and other information contained in the information system, access to which is provided via the information and telecommunications network Internet and located at: https://videograce.ru/.
VideoGrace software — software constituting a videoconferencing, messenger and CRM system developed by the Operator.
On-premise version — the version of the VideoGrace software installed on the purchaser company’s servers.
Cloud version - the demonstration version of the VideoGrace software, access to which is provided to end users and customer representatives for a limited period of time to familiarize themselves with the software functionality.
1.4.Main rights and obligations of the Operator.
1.4.1.The Operator has the right to:
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws;
- entrust the processing of personal data to another person with the consent of the data subject, unless otherwise provided by federal law, on the basis of a contract concluded with that person. A person performing the processing of personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by the Personal Data Law;
- in the event of withdrawal by the data subject of consent to the processing of personal data, the Operator shall have the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law.
1.4.2.The Operator is obliged to:
- organize the processing of personal data in accordance with the requirements of the Personal Data Law;
- respond to appeals and requests of data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized body for the protection of the rights of data subjects (hereinafter — “Roskomnadzor”) with the necessary information at the request of that body within 30 days from the date of receipt of such request.
1.5.Main rights of Data Subjects. A data subject has the right to:
- receive information concerning the processing of his personal data, except in cases provided for by federal laws. Information is provided to the Data Subject by the Operator in an accessible form, and it must not contain personal data relating to other Data Subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
- require the Operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the declared processing purpose, as well as to take measures provided by law to protect his rights;
- appeal to Roskomnadzor or in court against unlawful actions or inaction of the Operator in processing his personal data.
- require cessation of personal data processing and their deletion (the right to be forgotten);
- challenge decisions made solely on the basis of automated processing of personal data;
- require the transfer of personal data to another operator.
A Data Subject may exercise the rights to receive information concerning the processing of his personal data, as well as the rights to clarify his personal data, to block or destroy them, by addressing the Operator with the corresponding request at: 197375, Saint Petersburg, Verbnaia St., 27, building A, room 4N, office 103 or by addressing the Operator with the corresponding request by e-mail to contact@videograce.ru. In both cases, the request must be drawn up in compliance with the requirements of article 7.1. of this Policy.
1.6.Control over compliance with the requirements of this Policy is exercised by an authorized person responsible for organizing the processing of personal data at the Operator.
1.7.Liability for violation of the requirements of the legislation of the Russian Federation and the Operator’s internal acts in the field of processing and protection of personal data is determined in accordance with the legislation of the Russian Federation.
2. PRINCIPLES OF PERSONAL DATA PROCESSING
2.1.Personal data processing is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation and on the basis of the following principles:
- legality and fairness;
- limitation of personal data processing to achieving specific, predetermined and lawful purposes;
- prevention of processing of personal data incompatible with the purposes of collecting personal data;
- prevention of merging databases containing personal data the processing of which is carried out for purposes incompatible with each other;
- processing only those personal data that correspond to the purposes of their processing;
- correspondence of the content and scope of processed personal data to the declared purposes of processing;
- prevention of processing of excessive personal data in relation to the declared purposes of their processing;
- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
- destruction or anonymization of personal data upon achievement of the purposes of their processing or in case of loss of necessity to achieve these purposes, if it is impossible for the Operator to eliminate the violations allowed in relation to personal data, unless otherwise provided by federal law.
3. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
3.1.The legal basis for the processing of personal data is the set of regulatory legal acts in execution of and in accordance with which the Operator processes personal data, including:
- The Constitution of the Russian Federation;
- The Civil Code of the Russian Federation;
- The Tax Code of the Russian Federation;
- Federal Law of December 6, 2011 No. 402-ФЗ “On Accounting”;
- Federal Law of 27.07.2006 No. 149-ФЗ “On Information, Information Technologies and Information Protection”;
- Federal Law of 13.03.2006 No. 38-ФЗ “On Advertising”;
- other regulatory legal acts governing relations related to the Operator’s activities.
3.2.The legal basis for the processing of personal data also includes:
- the Operator’s Charter;
- agreements concluded with the Data Subject (license agreements, agreements for the provision of communication / access to the software, provision of technical support services, etc.);
- user agreement;
- consent of the Data Subject to the processing of personal data ;
- consent to receive news and marketing mailings.
3.3.Consent to the processing of personal data is executed as a separate document in accordance with the requirements of article 9 of Federal Law No. 152-ФЗ and contains:
- Full name of the data subject ;
- name and address of the Operator;
- purpose of processing;
- list of personal data to be processed: full name, email, telephone, position, as well as other data allowing identification of the PD subject.
- processing methods;
- term of validity of the consent and procedure for its withdrawal;
3.3.1.If the consent is executed in written form by signing a separate document, it must contain the signature of the data subject and the date.
3.3.2.If the consent is executed in electronic form — it is provided by the data subject performing conclusive actions expressing his will: placing a mark (checkbox) in an electronic form on the Site confirming consent to the terms of personal data processing, followed by pressing the button to submit the completed form (registration, request, subscription, etc.).
When obtaining consent in electronic form, the Operator ensures:
* fixation of the fact, content and time of obtaining the consent;
* the ability to confirm the fact of obtaining the consent when presenting requirements of the authorized body;
* storage of the record of the act of consent for the duration of personal data processing and for at least 5 years from the date of termination of processing.
Electronic consent is considered obtained from the moment the mark (checkbox) is placed and the confirmation button is pressed, provided that prior to performing these actions the data subject was provided with complete information on the purposes, scope and terms of personal data processing in accordance with part 2 of article 9 of Federal Law No. 152-ФЗ.
3.4.The processing of personal data of end users in the on-premise version of the software is carried out by the purchaser company as an independent personal data operator on the basis of the agreement with the Operator and/or the customer’s internal documents. The Operator is not the personal data operator of the end users when using the on-premise version and does not have access to them.
4. PURPOSES AND CONDITIONS OF PERSONAL DATA PROCESSING
4.1.The processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed. Only personal data that meet the purposes of their processing are subject to processing.
4.2.The content and scope of processed personal data must correspond to the declared purposes of processing provided for in this section. Processed personal data must not be excessive in relation to the declared purposes of their processing.
4.3.In accordance with this Policy, the Operator may process personal data belonging to the following categories of Data Subjects:
- Representatives of customers — natural persons acting as representatives of legal entities, individual entrepreneurs, state authorities, state corporations, public-law companies, management bodies of state extra-budgetary funds, state budgetary institutions and enterprises with which the Operator concludes contracts or negotiates contracts, as well as interacts in the course of contract performance;
- End users of the VideoGrace software — natural person users of the cloud demonstration version of the VideoGrace software;
- Users of the Operator’s Site videograce.ru — natural persons registering on the Site, submitting requests for consultation or demonstration, contacting support service, subscribing to mailings or otherwise interacting with the Operator through the Site
4.3.1.Representatives of customers
4.3.1.1.The Operator processes personal data of customer Representatives for purposes including:
- Conclusion and performance of contracts (license agreements, agreements for the provision of communication / access to the software / technical support agreements).
- Processing an order for paid access to the VideoGrace software.
- Provision of access to the software version.
- Compliance with legislation (accounting and tax records, compliance with legal requirements, response to lawful requests of authorized bodies).
- provision of technical support.
4.3.1.2.Processing of personal data of representatives of purchaser companies does not require obtaining additional consent where the processing of personal data is in accordance with paragraph 5 of part 1 of article 6 of the Personal Data Law (performance of a contract to which the data subject is a party). Obtaining consents is carried out in cases of:
- Sending advertising information about goods and services (planned marketing email mailings).
- Participation in a loyalty program (if any).
4.3.1.3.For the purposes provided above, the Operator processes the following categories of personal data of representatives of purchaser companies:
* Surname, given name, patronymic.
* Position.
* Contact telephone.
* Email address (corporate / personal).
4.3.1.4.The Operator does not process biometric personal data of customer Representatives (information that characterizes a person's physiological and biological features on the basis of which his identity can be established).
4.3.1.5.The Operator does not process special categories of personal data of representatives of purchaser companies.
4.3.1.6.Customer Representatives provide personal data when concluding a contract through a manager, by email or via forms on the Site. Personal data of representatives of purchaser companies are stored for the term of performance of contractual obligations and/or for the periods established by law (with respect to accounting and tax documents — not less than 5 years).
4.3.1.7.The Operator carries out automated, non-automated, and mixed processing of personal data of representatives of purchaser companies with reception and/or transmission of the obtained information via information and telecommunication networks.
4.3.1.8.The list of actions for processing personal data of representatives of purchaser companies: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
4.3.1.9.Disclosure to third parties and distribution of personal data without the consent of the representative of the purchaser company is not allowed, unless otherwise provided by federal law.
4.3.1.10.Within the country the Operator may transfer personal data of representatives of purchaser companies for the purposes specified in this section to the following third parties:
- Yandex.Cloud (hosting / cloud server for the SaaS version, located in the Russian Federation) LLC “Yandex.Cloud”, TIN 7704458262.
4.3.1.11.The Operator does not perform cross-border transfer of personal data of representatives of purchaser companies.
4.3.2.End users of the demonstration cloud version of the VideoGrace software — natural persons
4.3.2.1.The Operator processes the personal data of end users for such purpose(s) as:
- Registration in the VideoGrace software and creation of an account.
- Providing access to the cloud version of the software.
- Creating an account in the software to join a conference.
- Technical support.
- Usage analytics of the software.
- Interface personalization.
- Local AI transcription of conferences.
4.3.2.2.The processing of personal data of end users of the demonstration version of the software by the Operator is carried out on the basis of the user agreement provided that a separate consent is obtained.
4.3.2.3.For the purposes specified above, the Operator processes the following categories of personal data of end users:
* Surname, given name, patronymic.
* Email address.
* Contact phone number.
* Login / password.
* Photo / avatar (at the user's option).
* Voice / video (during the conference — processed in the course of the conference for audio/video transmission; recording and storage are performed only when the corresponding function is enabled or according to settings/agreement).
* IP address (automatically in technical logs for service operation, security and diagnostics).
* Device data (OS, browser, screen resolution).
* Profile, interface, device, notification settings and user preferences.
4.3.2.4.The Operator does not process biometric personal data of end users (information that characterizes a person's physiological and biological features on the basis of which their identity can be established). Photos, voice and videos of conference participants are not used for biometric identification or authentication of users. If such processing becomes necessary in the future, the Operator will obtain a separate written consent from each subject (article 10 of the Personal Data Law).
4.3.2.5.The Operator does not process special categories of personal data of end users.
4.3.2.6.End users provide personal data when registering in the software, on the Website or through support request forms. Personal data of end users are subject to storage for the duration of the account, agreement or license. After cessation of use — until deletion upon request of the subject/administrator or until the expiration of the periods necessary for performance of the agreement, protection of rights and compliance with legal requirements.
4.3.2.7.The Operator carries out automated, non-automated, as well as mixed processing of personal data of end users with reception and/or transmission of the obtained information via information and telecommunication networks.
4.3.2.8.The list of actions for processing personal data of end users: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
4.3.2.9.Disclosure to third parties and dissemination of personal data without the consent of the end user is not permitted, unless otherwise provided by federal law.
4.3.2.10.Within the country the Operator may transfer personal data of end users for the purposes specified in this section to the following third parties:
- Yandex.Cloud (hosting / cloud server for the SaaS version, placement in the Russian Federation) ООО «Яндекс.Облако», INN 7704458262.
4.3.2.11.The Operator does not perform cross-border transfer of personal data of end users.
4.3.2.12.When using the on-premise version of the software, processing of personal data of end users is carried out on the customer's servers. The customer is an independent operator of the personal data of its users. The Operator does not have access to the personal data of end users processed in the on-premise version and is not responsible for their protection.
In the event that the customer is an educational institution, a government institution or another organization in whose activities minors are personal data subjects, the customer independently undertakes:
обеспечить защиту персональных данных несовершеннолетних в соответствии с требованиями Федерального закона от 27.07.2006 № 152-ФЗ «О персональных данных» и иного применимого законодательства Российской Федерации;
получить согласие законных представителей несовершеннолетних субъектов персональных данных на обработку их персональных данных в ПО, а также на обработку специальных категорий персональных данных и биометрических персональных данных, если таковые обрабатываются в рамках использования ПО;
нести полную ответственность перед несовершеннолетними субъектами персональных данных и их законными представителями за соблюдение режима защиты персональных данных, включая, но не ограничиваясь, обеспечение конфиденциальности, целостности и доступности таких данных.
The Operator does not monitor the customer's activities in processing personal data of minors in the on-premise version of the software and is not responsible for the actions or omissions of the customer in that respect.
4.3.3.Users of the Operator's Website videograce.ru
4.3.3.1.The Operator processes the personal data of Website users for such purpose(s) as:
- Processing requests on the Website (demo request, consultation, order).
- Registration on the Website / in the personal account (upon launch).
- Sending promotional information about goods and services (with consent).
- Website usage analytics (technical logs, cookies).
4.3.3.2.Processing of personal data of Website users is carried out subject to obtaining prior consent.
4.3.3.3.For the purposes specified above, the Operator processes the following categories of personal data of Website users:
- Surname, given name, patronymic.
- Contact phone number.
- Email address.
- Position (when filling out a request on behalf of a company).
- Date and time of Website visit.
- IP address assigned to the device for Internet access.
- Type of browser and operating system.
- URL of the site from which the transition to the Website was made.
- Cookies files (technical and functional).
- Data collected via website visitor analytics aggregators (if connected).
4.3.3.4.The Operator does not process biometric personal data of Website users (information that characterizes a person's physiological and biological features on the basis of which their identity can be established).
4.3.3.5.The Operator does not process special categories of personal data of Website users.
4.3.3.6.The Operator carries out automated, non-automated, as well as mixed processing of personal data of Website users with reception and/or transmission of the obtained information via information and telecommunication networks.
4.3.3.7.The list of actions for processing personal data of Website users: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
4.3.3.8.Disclosure to third parties and dissemination of personal data without the user's consent is not permitted, unless otherwise provided by federal law.
4.3.3.9.The Operator does not perform cross-border transfer of personal data of Website users.
4.3.3.10.On the first visit to the Website the User is shown an informational banner about the use of cookies files. The User is provided with the opportunity to express their choice by clicking the corresponding button: "Accept" (consent to processing of all categories of cookies), "Decline" (refusal to process all cookies, except those strictly necessary for the Website to function) or "Configure" (selection of individual categories of cookies). Strictly necessary (technical) cookies are processed without the User's consent, as they ensure the basic functioning of the Website. Other categories of cookies (analytical, statistical, advertising) are processed only subject to the User's prior consent expressed in the specified manner. Refusal of non-essential cookies should not prevent access to the main functionality of the Website.
4.3.3.11.Although most browsers accept cookies automatically, the user can configure their browser so that only they decide whether to accept or block cookies (refer to the "Tools" or "Settings" menu of the browser used). The user can delete cookies from their device at any time. It should be borne in mind that if the user does not accept cookies, some Website functions may be lost. More detailed information on managing cookies can be found in the browser help file or on specialized websites.
5. PROCEDURE FOR COLLECTION, STORAGE AND DESTRUCTION OF PERSONAL DATA
5.1.Consent to the processing of personal data is given by the user voluntarily and is confirmed by ticking a box (checkbox) in the electronic form on the Website, confirming consent to the terms of personal data processing, followed by clicking the button to submit the completed form (registration, request, subscription, etc.).
This consent includes permission to collect, store, use and transfer personal data necessary for the performance of contractual obligations, as well as for sending informational and promotional mailings, if the user has given consent to this by a separate checkbox.
5.2.When collecting personal data, including via the information and telecommunication network Internet, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), retrieval of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.
5.3.Persons who have provided the Operator with information about another Personal Data Subject, including via the Website, without having the consent of the subject whose personal data were provided, bear responsibility in accordance with the legislation of the Russian Federation.
5.4.The Operator stores personal data in a form that allows the identification of the personal data subject no longer than is required by the purposes of processing personal data, unless the retention period for personal data is established by federal law, a contract to which the Personal Data Subject is a party, beneficiary or guarantor.
Personal data of active users are stored for the duration of the account, agreement or license. After cessation of use, personal data are stored until deletion at the request of the subject or administrator or until the expiration of the periods necessary for performance of the agreement, protection of rights and compliance with legal requirements.
Personal data after the expiration of a license or subscription are stored for the period necessary to perform and close the contract or license, settle possible claims and comply with legal requirements. Accounting and tax documents are stored for periods established by the tax and accounting legislation of the Russian Federation, usually not less than 5 years.
Conference recordings, if recording is enabled, are stored for the period set by the settings, agreement or administrator. For the cloud version recordings are stored on infrastructure in the Russian Federation until deletion or expiration of the agreed period. For the on-premise version recordings are stored on the customer's server.
Software usage logs are stored for the period determined by server settings, the agreement and security requirements. For the cloud version the recommended log retention period is up to 12 months. For the on-premise version logs are stored by the customer.
Automatic deletion of inactive accounts is not currently used. Deletion is performed at the request of the user or administrator or under the terms of the agreement.
5.5.Processed personal data are subject to destruction in the event of:
- expiration of the period for processing personal data;
- achievement of the purposes of personal data processing;
- loss of necessity to achieve the purposes of personal data processing;
- receipt of withdrawal of consent to the processing of personal data;
- exclusion of the Operator from the Unified State Register of Legal Entities.
5.6.Destruction of personal data is carried out by deleting records from the Operator's information systems with impossibility of restoring the content of personal data. Destruction of physical media containing personal data is carried out by their physical destruction.
5.7.A Personal Data Subject may request deletion/destruction of their data by contacting support or the person responsible for personal data by email. The request is processed after identification of the applicant within 10 working days from the date of receipt. The period within which the Operator undertakes to delete the data of such a subject in accordance with part 4 of art. 14 of 152-ФЗ "On Personal Data" - no more than thirty days from the date of receipt of the specified request for deletion/destruction of personal data.
6. PROTECTION OF PERSONAL DATA
6.1.The Operator takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, dissemination and other unauthorized actions, including:
- identifies threats to the security of personal data during their processing;
- adopts local regulatory acts and other documents regulating relations in the field of processing and protection of personal data;
- appoints persons responsible for ensuring the security of personal data in structural subdivisions and information systems of the Operator;
- creates the necessary conditions for working with personal data;
- organizes accounting of documents containing personal data;
- organizes work with information systems in which personal data are processed;
- stores personal data under conditions that ensure their safety and exclude unlawful access to them.
6.2.Software and technical measures for protection of personal data.
The Operator applies technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying and dissemination, including: secure data transfer protocols (TLS/HTTPS), access control based on roles and accounts, password protection, network protection means (firewalling), backup and protection against unauthorized access to conferences (participant authorization, rights management, moderation, access restriction in conference settings). Encryption of data during transmission is not required; data are transmitted via protected channels.
The specific composition and parameters of technical protection means are determined by the Operator's internal documents (threat model, personal data protection regulation, orders) and are not subject to public disclosure for security purposes.
For the on-premise version the parameters of technical protection means are determined by the customer in accordance with clause 6.4 of this Policy.
6.3.Organizational measures for the protection of personal data:
- A person responsible for organizing the processing of personal data has been appointed (appointed by an order of the Operator). Appeals to the responsible person and requests from personal data Subjects are sent to the email address: contact@videograce.ru. Control over compliance with this Policy and the deadlines for handling appeals is exercised by the specified person.
- This document — the Personal Data Processing Policy — has been developed and approved.
- Local acts on the protection of personal data have been developed and approved.
- Employees are familiarized with the requirements of personal data legislation.
- A log of personal data Subjects' appeals is maintained.
- Operator employees' access to personal data is carried out remotely within the scope of their job duties and in accordance with established access rights
- Осуществляется ведение журналов учёта инцидентов
- Назначено ответственное лицо для взаимодействия с Roskomnadzor по инцидентам.
6.4.Specifics of protection of personal data in the on-premise version:
- The Operator is the software developer and does not deploy, maintain or control information protection measures on the customer's servers.
- Protection of personal data in the on-premise version is ensured by the customer independently in accordance with the requirements of the legislation of the Russian Federation.
- The Operator provides the customer with recommendations for configuring information protection measures, but is not responsible for their implementation and operation.
- The composition and transfer of diagnostic data in the on-premise version are determined by the settings and the contract with the customer.
6.5.Server placement:
- The on-premise version is hosted on the customer's server or on infrastructure chosen by them.
The initial collection, recording and storage of personal data of citizens of the Russian Federation are carried out using databases located on the territory of the Russian Federation. The customer undertakes to comply with this requirement.
7. UPDATE, CORRECTION, DELETION AND DESTRUCTION OF PERSONAL DATA, RESPONSES TO SUBJECTS' REQUESTS FOR ACCESS TO PERSONAL DATA
7.1.Confirmation of the fact of the processing of personal data by the Operator, the legal grounds and purposes of the processing of personal data, as well as other information specified in part 7 of Article 14 of the Law on Personal Data, are provided by the Operator to the personal data Subject or his representative upon appeal or upon receipt of a request from the personal data Subject or his representative. The information provided does not include personal data relating to other personal data Subjects, except in cases where there are lawful grounds for disclosing such personal data.
The request must contain:
- the number of the primary identity document of the personal data Subject or his representative, information on the date of issue of the specified document and the issuing authority;
- information confirming the personal data Subject's involvement in relations with the Operator (contract number, contract date, conventional verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by the Operator;
- the signature of the personal data Subject or his representative.
The request may be submitted in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
The appeal (request) is sent by the personal data Subject by sending an email to contact@videograce.ru or via the support request form on the Website videograce.ru.
If the appeal (request) of the personal data Subject does not contain, in accordance with the requirements of the Law on Personal Data, all the necessary information, or if the subject does not have rights of access to the requested information, a reasoned refusal is sent to him.
The right of the personal data Subject to access his personal data may be limited in accordance with part 8 of Article 14 of the Law on Personal Data, including if the Subject's access to his personal data infringes the rights and lawful interests of third parties.
7.2.In the event of detection of inaccurate personal data during an appeal by the personal data Subject or his representative, or at their request, or at the request of Roskomnadzor, the Operator carries out the blocking of the personal data relating to that personal data Subject from the moment of such appeal or receipt of the specified request for the period of verification, provided that the blocking of personal data does not violate the rights and lawful interests of the personal data Subject or third parties.
If the inaccuracy of personal data is confirmed, the Operator, on the basis of information provided by the personal data Subject or his representative, or by Roskomnadzor, or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes the blocking of the personal data.
7.3.In the event of unlawful processing of personal data being revealed during an appeal (request) of the personal data Subject or his representative or Roskomnadzor, the Operator carries out the blocking of the unlawfully processed personal data relating to that personal data Subject from the moment of such appeal or receipt of the request.
7.4.Upon achievement of the purposes of processing personal data, as well as in the event of the personal data Subject withdrawing consent to their processing, personal data are subject to destruction if:
- otherwise not provided by a contract to which the personal data Subject is a party;
- the operator is not entitled to carry out processing without the consent of the personal data Subject on the grounds provided for by the Law on Personal Data or other federal laws;
- otherwise not provided by another agreement between the Operator and the personal data Subject.
In the event of withdrawal of consent to the processing of personal data, the Operator is obliged to cease their processing and destroy the personal data within a period not exceeding thirty days from the date of receipt of said withdrawal, unless otherwise provided by a contract or other agreement between the Operator and the personal data Subject.
7.5.The personal data Subject has the right to demand from the Operator:
- correction of his personal data;
- blocking or destruction of personal data if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing;
- cessation of processing of personal data and their deletion (the right to be forgotten);
- transfer of personal data to another operator, if technically possible;
- objection to the processing of personal data, including for marketing purposes.
These requests are sent by the personal data Subject by sending an email to contact@videograce.ru or via the support request form on the Website videograce.ru. The appeal is considered and a reasoned response is given within 10 working days from the date of receipt.
7.6.In the event of processing personal data in the on-premise version of the software, subjects' requests for access, correction, blocking, deletion or destruction of personal data are sent to the customer — an independent personal data operator. The Operator does not have the technical capability to fulfill such requests in relation to data processed in the on-premise version on the customer's servers.
8. FINAL PROVISIONS
8.1.The Operator has the right to send the Personal Data Subject advertising and informational messages by e-mail only on the condition of prior consent to receive advertising in accordance with part 1 of Article 18 of the Federal Law of 13.03.2006 No. 38-ФЗ "On Advertising". Consent to receive advertising messages from the Operator by e-mail is given in electronic form by placing a mark (checkbox) in the corresponding field on the Site.
The Personal Data Subject has the right to opt out of receiving advertising messages by following the corresponding link in the e-mails received from the Operator, or by sending a notice of refusal to receive advertising messages to the support service by e-mail contact@videograce.ru or via the contact form on the Site videograce.ru.
8.2.In fulfillment of the requirements of part 2 of Article 18.1 of the Law on Personal Data, this Policy is posted at the Operator's address of location, and is also published in open access on the information and telecommunication network "Internet" on the Site at https://videograce.ru/.
8.3.The following appendices are an integral part of this Policy:
Appendix №1 CONSENT TO THE PROCESSING OF PERSONAL DATA
Appendix №2 CONSENT TO RECEIVE NEWS AND ADVERTISING MAILINGS AND TO THE RELATED PROCESSING OF PERSONAL DATA
Operator:
Limited Liability Company «ТАС»
Taxpayer Identification Number (INN) 7814784685
Primary State Registration Number (OGRN) 1207800176561
197375, Saint Petersburg, Verbnaia Street, 27, lit. A, room 4N, office 103
contact@videograce.ru
+7 911 949 3000