Privacy Policy

When processing personal data, LLC » Aesthetic Dentistry Clinic » is guided by the Policy of LLC «Clinic of Aesthetic Dentistry» regarding the processing of personal data.

I. General provisions

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in LLC » Aesthetic Dentistry Clinic» in order to protect the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
The personal data processing policy at the LLC “Aesthetic Dentistry Clinic” has been developed in accordance with Federal Law No. 152-FL of 27.07.2006 «On Personal Data».
The following terms and definitions are used in this Policy:

operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;

personal data — any information relating directly or indirectly to a specific or identifiable individual (subject of personal data);

personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

automated processing of personal data — processing of personal data using computer technology;

dissemination of personal data — actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited circle of persons, including the publication of personal data in the media, placement in information and telecommunications networks or providing access to personal data in any other way;

provision of personal data — actions aimed at disclosure of personal data to a certain person or a certain circle of persons;

blocking of personal data — temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data);

destruction of personal data — actions as a result of which it is 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;

depersonalization of personal data — actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific personal data subject;

personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing;

cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

1. The Policy applies to all personal data of subjects processed in LLC “Aesthetic Dentistry Clinic” with the use of automation tools and without the use of such tools.
2. Any subject of personal data must have access to this Policy.

II. Principle and conditions of personal data processing

Processing of personal data in LLC “Aesthetic Dentistry Clinic” is carried out on the basis of the following principles:

legality and fair basis;
restrictions on the processing of personal data to achieve specific, predetermined and legitimate goals;
preventing the processing of personal data incompatible with the purposes of personal data collection;
preventing the consolidation of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
processing only those personal data that meet the purposes of their processing;
compliance of the content and volume of the processed personal data with the stated purposes of processing;
preventing the processing of excessive personal data in relation to the stated purposes of their processing;
ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of the need to achieve these goals if it is impossible for the Company to eliminate the violations of personal data unless otherwise provided by federal law.

LLC “Aesthetic Dentistry Clinic” processes personal data only if there is at least one of the following conditions:

the processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
the processing of personal data is necessary to achieve the goals stipulated by law, to carry out and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
the processing of personal data is necessary for the execution of a contract to which either the beneficiary or the guarantor is the subject of personal data, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor;
processing of personal data is necessary to exercise the rights and legitimate interests of the Company or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;
processing of personal data is carried out, access of an unlimited number of persons to which is provided by the subject of personal data or at his request;
personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

LLC “Aesthetic Dentistry Clinic” and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
In order to provide information, the Company may create publicly available sources of personal data of employees, including directories and address books. The publicly available sources of personal data, with the consent of the employee may include his surname, first name, patronymic, date and place of birth, position, contact phone numbers, e-mail address.
Information about an employee must be excluded from publicly available sources of personal data at any time at the request of the employee or by a court decision or other authorized state bodies.

LLC “Aesthetic Dentistry Clinic” has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of a contract concluded with this person. The person processing personal data on behalf of the Company is obliged to comply with the principles and rules of personal data processing provided for by FL-152.

Processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, health status, intimate life by LLC “Aesthetic Dentistry Clinic” is allowed in cases where:

the subject of personal data has given written consent to the processing of his personal data;
personal data is made publicly available by the subject of personal data;
the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the legislation of the Russian Federation on pensions for state pension provision, on labor pensions;
the processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;
processing of personal data is carried out in accordance with the legislation of the Russian Federation on countering terrorism, on combating corruption, on enforcement proceedings, and the penal enforcement legislation of the Russian Federation;
processing of personal data is carried out in accordance with the legislation on mandatory types of insurance, with insurance legislation.

The processing of special categories of personal data must be immediately terminated if the reasons for their processing have been eliminated, unless otherwise established by federal law.

The processing of personal data on criminal record may be carried out by the Company only in cases and in accordance with the procedure determined in accordance with federal laws.
Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity — biometric personal data — can be processed by the Company only with the written consent of the employee.
Cross-border transfer of personal data on the territory of foreign states can be carried out by LLC “Aesthetic Dentistry Clinic” only with the consent of the subject of personal data on the cross-border transfer of his personal data.
Prior to the start of the cross-border transfer of personal data, the Company is obliged to make sure that the foreign state to whose territory the transfer of personal data is carried out ensures adequate protection of the rights of personal data subjects.

III. Rights of the personal data subject

The subject of personal data makes a decision on the provision of his personal data and consents to their processing freely, of his own free will and in his own interest. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form that allows to confirm the fact of its receipt unless otherwise established by federal law.

The obligation to provide proof of obtaining the consent of the personal data subject to the processing of his personal data or proof of the existence of the grounds specified in FL-152 is assigned to the Company.

The subject of personal data has the right to receive information concerning the processing of his personal data, unless such right is restricted in accordance with federal laws. The subject of personal data has the right to demand from LLC “Aesthetic Dentistry Clinic” clarification of his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing as well as to take measures provided by law to protect their rights.
Processing of personal data for the purpose of promoting goods, works, services on the market by making direct contacts with a potential consumer using means of communication, as well as for the purposes of political agitation is allowed only with the prior consent of the subject of personal data. The specified processing of personal data is considered to be carried out without the prior consent of the personal data subject, unless the Company proves that such consent has been obtained.

LLC “Aesthetic Dentistry Clinic” immediately terminate, at the request of the subject of personal data, the processing of his personal data for the above purposes.

It is prohibited to make decisions based solely on automated processing of personal data that generate legal consequences with respect to the subject of personal data or otherwise affect his rights and legitimate interests, except in cases provided for by federal laws or with the written consent of the subject of personal data.
If the subject of personal data believes that LLC “Aesthetic Dentistry Clinic” processes his personal data in violation of the requirements of FL-152 or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal the actions or inaction of LLC “Aesthetic Dentistry Clinic” to the Authorized Body for the Protection of the rights of personal data subjects or to judicial procedure.

The subject of personal data has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.

IV. Ensuring the security of personal data

The security of personal data processed by LLC “Aesthetic Dentistry Clinic” is ensured by the implementation of legal, organizational, technical and programmatic measures necessary and sufficient to meet the requirements of federal legislation in the field of personal data protection.
In order to purposefully create unfavorable conditions and insurmountable obstacles in the Company for violators trying to carry out unauthorized access to personal data in order to acquire them, modify them, destroy them, infect them with a malicious computer program, substitute and commit other unauthorized actions, the Company applies the following organizational and technical measures:

appointment of officials responsible for organizing the processing and protection of personal data;
restriction and regulation of the composition of employees with access to personal data;
familiarization of employees with the requirements of federal legislation and the Company’s regulatory documents on the processing and protection of personal data;
ensuring accounting and storage of material media and their circulation, excluding theft, substitution, unauthorized copying and destruction;
identification of threats to the security of personal data during their processing, the formation of threat models based on them;
development based on the threat model of a personal data protection system for the corresponding class of information systems;
checking the readiness and effectiveness of the use of information security tools;
implementation of a permissive system for user access to information resources, software and hardware for processing and protecting information;
registration and accounting of actions of users of personal data information systems;
password protection of user access to the personal data information system;
the use of access control tools to communication ports, input-output devices, removable storage media and external storage media;
the use, where necessary, of means of cryptographic protection of information to ensure the security of personal data during transmission through open communication channels and storage on machine storage media;
implementation of anti-virus control, prevention of the introduction of malicious programs (virus programs) and software bookmarks into the corporate network;
use of firewalls;
detection of intrusions into the Company’s corporate network that violate or create preconditions for violation of established requirements for ensuring the security of personal data;
centralized management of the personal data protection system.
information backup;
ensuring the recovery of personal data modified or destroyed due to unauthorized access to them;
training of employees using information security tools used in personal data information systems, the rules for working with them;
taking into account the means of information protection used, operational and technical documentation for them;
the use of information security tools that have passed the conformity assessment procedure in the prescribed manner;
monitoring user actions, conducting proceedings on violations of personal data security requirements;
placement of technical means for processing personal data within a protected area;
organization of access control to the territory of the Company;
maintenance of technical means of protection, signaling of premises in a state of constant readiness.

V. Final provisions

Other rights and obligations of Clinic of Aesthetic Dentistry LLC, as a personal data operator, are determined by the legislation of the Russian Federation in the field of personal data.

Company officials guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.