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Personal Data Processing Policy1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”), and defines the procedure for processing personal data and the measures taken by Nurr Health LLC (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality, to be its most important objective and a condition for conducting its activities.
1.2. 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 website http://nurrhealth.am/en.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at http://nurrhealth.am/en.
2.4. Personal Data Information System — a collection of personal data contained in databases, together with information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, whether or not using automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website http://nurrhealth.am/en.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted for dissemination, in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User — any visitor to the website http://nurrhealth.am/en.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.
2.13. 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.
2.14. Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed, making it impossible to restore its content in the personal data information system, and/or physical media containing personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
4.1. Personal data subjects have the right to:
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected is not permitted.
5.3. It is not permitted to combine databases containing personal data if such data is processed for purposes that are incompatible with one another.
5.4. Only personal data that meets the purposes of its processing shall be subject to processing.
5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, its accuracy and sufficiency shall be ensured and, where necessary, its relevance in relation to the purposes of processing. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the personal data subject to be identified, for no longer than is required by the purposes of processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or when the need to achieve such purposes is no longer applicable, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing7. Conditions for Personal Data Processing
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, and to perform the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice and the execution of a judicial act, an act of another authority or an official, which is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed where access to such data by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law agreement.
8.3. If inaccuracies in personal data are identified, the User may update the data independently by sending a notification to the Operator’s email address at info@nurrhealth.am, marked “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator’s email address at info@nurrhealth.am, marked “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or with the above-mentioned documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, shall not apply in cases where personal data is processed in state, public or other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified, for no longer than is required by the purposes of processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or receipt of a request to terminate processing, as well as upon detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with the receipt and/or transmission of the information obtained via information and telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body responsible for protecting the rights of personal data subjects of its intention to carry out such cross-border transfers. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is intended.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose such data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator via email at info@nurrhealth.am.
12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: http://nurrhealth.am/policy/en
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”), and defines the procedure for processing personal data and the measures taken by Nurr Health LLC (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality, to be its most important objective and a condition for conducting its activities.
1.2. 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 website http://nurrhealth.am/en.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at http://nurrhealth.am/en.
2.4. Personal Data Information System — a collection of personal data contained in databases, together with information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, whether or not using automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website http://nurrhealth.am/en.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted for dissemination, in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User — any visitor to the website http://nurrhealth.am/en.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.
2.13. 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.
2.14. Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed, making it impossible to restore its content in the personal data information system, and/or physical media containing personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive reliable information and/or documents containing personal data from the personal data subject;
- if the personal data subject withdraws consent to the processing of personal data or submits a request demanding the termination of personal data processing, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
- provide the personal data subject, upon request, with information concerning the processing of their personal data;
- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized body responsible for protecting the rights of personal data subjects, at its request, with the necessary information within 10 days from the date of receipt of such request;
- publish this Personal Data Processing Policy or otherwise ensure unrestricted access to it;
- take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision or dissemination, as well as against other unlawful actions involving personal data;
- cease the transfer (dissemination, provision, access) of personal data, terminate its processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- perform other obligations stipulated by the Personal Data Law.
4.1. Personal data subjects have the right to:
- receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator shall provide information to the personal data subject in an accessible form, and such information must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- require the Operator to clarify, block or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and also take measures provided for by law to protect their rights;
- impose a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
- withdraw consent to the processing of personal data and submit a request demanding the termination of personal data processing;
- appeal unlawful actions or omissions of the Operator in the processing of their personal data to the authorized body responsible for protecting the rights of personal data subjects or through judicial proceedings;
- exercise other rights provided for by the legislation of the Russian Federation.
- provide the Operator with accurate information about themselves;
- notify the Operator of any clarification (updating or modification) of their personal data.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected is not permitted.
5.3. It is not permitted to combine databases containing personal data if such data is processed for purposes that are incompatible with one another.
5.4. Only personal data that meets the purposes of its processing shall be subject to processing.
5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, its accuracy and sufficiency shall be ensured and, where necessary, its relevance in relation to the purposes of processing. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the personal data subject to be identified, for no longer than is required by the purposes of processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or when the need to achieve such purposes is no longer applicable, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing7. Conditions for Personal Data Processing
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, and to perform the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice and the execution of a judicial act, an act of another authority or an official, which is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed where access to such data by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law agreement.
8.3. If inaccuracies in personal data are identified, the User may update the data independently by sending a notification to the Operator’s email address at info@nurrhealth.am, marked “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator’s email address at info@nurrhealth.am, marked “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or with the above-mentioned documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, shall not apply in cases where personal data is processed in state, public or other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified, for no longer than is required by the purposes of processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or receipt of a request to terminate processing, as well as upon detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with the receipt and/or transmission of the information obtained via information and telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body responsible for protecting the rights of personal data subjects of its intention to carry out such cross-border transfers. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is intended.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose such data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator via email at info@nurrhealth.am.
12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: http://nurrhealth.am/policy/en
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