Privacy Policy on Personal Data Processing1. General ProvisionsThis Privacy Policy on personal data processing (hereinafter referred to as the “Policy”) has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter — the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by PT Our Place Invest (hereinafter — the “Operator”).
1.1. The Operator sets compliance with the rights and freedoms of individuals in processing their personal data as its most important objective and condition, including the protection of the rights to privacy, personal and family confidentiality.
1.2. This Policy of the Operator applies to all information the Operator may obtain about visitors of the website
https://svcbali.com.
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2. Key Terms Used in the Policy(Definitions translated exactly as in your Russian version)
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Automated processing of personal data — processing using computing technology.
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Blocking of personal data — temporary suspension of processing (except when processing is necessary to clarify data).
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Website — a collection of graphic and information materials, software, and databases accessible at
https://svcbali.com.
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Information system of personal data — a set of databases and IT solutions ensuring their processing.
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Depersonalization of personal data — actions making it impossible to identify a data subject without additional information.
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Processing of personal data — any action or set of actions performed with or without automation, including collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
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Operator — a state, municipal, legal, or natural person that organizes and/or carries out processing of personal data and determines its purposes and content.
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Personal data — any information relating directly or indirectly to an identified or identifiable User of the website
https://svcbali.com.
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Personal data allowed for distribution — data provided by the subject for unrestricted access by giving consent in accordance with the Personal Data Law.
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User — any visitor of the website
https://svcbali.com.
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Provision of personal data — actions aimed at disclosure to a specific person(s).
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Distribution of personal data — actions aimed at disclosure to an unlimited number of persons.
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Cross-border transfer of personal data — transfer to the territory of a foreign state, its authorities, foreign persons or entities.
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Destruction of personal data — irreversible deletion of data, making recovery impossible.
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3. Rights and Obligations of the OperatorThe Operator has the right to:
• receive accurate information/documents from the subject;
• continue processing without consent if provided for by law;
• determine necessary and sufficient measures for compliance with the Personal Data Law.
The Operator is obliged to:
• provide data subjects with information on processing upon request;
• process data in accordance with Russian law;
• respond to requests of subjects and authorities;
• publish this Policy in public access;
• ensure legal, organizational, and technical protection of personal data;
• stop and destroy data when required by law.
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4. Rights and Obligations of Data SubjectsData subjects have the right to:
• obtain information about their data processing;
• demand correction, blocking, or deletion of incomplete, outdated, inaccurate, or unlawfully obtained data;
• condition consent for processing for marketing purposes;
• withdraw consent to processing;
• lodge complaints with authorities or courts;
• exercise other rights under Russian law.
Data subjects are obliged to:
• provide accurate information;
• notify the Operator of updates/changes.
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5. Principles of Personal Data Processing • Processing is lawful and fair.
• Limited to legitimate, predefined purposes.
• Combining databases with incompatible purposes is not allowed.
• Only relevant and necessary data may be processed.
• Accuracy and timeliness of data must be ensured.
• Data is stored no longer than required for processing purposes.
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6. Purpose of Processing •
Purpose: Providing Users with access to services, information, and/or materials on the website.
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Data processed: full name, email address, phone numbers.
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Legal grounds: Operator’s charter documents, contracts with data subjects.
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Types of processing: collection, recording, storage, deletion, depersonalization, emailing information, consulting clients on real estate, processing purchase requests, organizing property viewings.
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7. Conditions of ProcessingProcessing is carried out:
• with the subject’s consent;
• when required by law, for judicial or governmental obligations;
• to execute or conclude contracts with the subject;
• to achieve legitimate interests without infringing rights;
• for publicly available or legally required data.
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8. Collection, Storage, Transfer, and Security • The Operator ensures security of personal data with legal, organizational, and technical measures.
• Data is not transferred to third parties except when required by law or contract with consent.
• Users can update data by emailing
bbd.investgroup@gmail.com with the note “Personal Data Update.”
• Consent can be withdrawn via email with the note “Withdrawal of Consent.”
• Third-party services (payment systems, communication tools, providers) process data according to their own agreements and policies.
• Confidentiality is guaranteed during processing.
• Data storage lasts no longer than necessary to fulfill purposes.
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9. Actions Performed with DataThe Operator collects, records, systematizes, stores, updates, extracts, uses, transfers, depersonalizes, blocks, deletes, and destroys personal data. Automated processing is also performed with or without telecom networks.
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10. Cross-Border TransferBefore cross-border transfer, the Operator must notify the authorized Russian data protection authority and ensure necessary information is obtained from foreign recipients.
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11. ConfidentialityThe Operator and other persons with access to data must not disclose it to third parties without consent, unless required by law.
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12. Final Provisions • Users may request clarifications via email:
bbd.investgroup@gmail.com.
• Any changes to this Policy will be reflected in this document. The Policy is valid indefinitely until replaced.
• The current version is publicly available online at:
https://svcbali.com/privacy/ 