This Privacy Policy is prepared in accordance with the requirements of the Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedures for processing personal data and measures for ensuring personal data security taken by The Meltzer Group, LLC (hereinafter referred to as the "Operator"). 1.1. The Operator’s primary goal and condition for conducting its activities is to respect and protect the rights and freedoms of individuals when processing their personal data, including safeguarding privacy, personal, and family secrets. 1.2. This Privacy Policy (hereinafter referred to as the "Policy") applies to all information that the Operator may receive about visitors to the website https://meltzerfirm.com/en/.
Definitions
2.1. Automated Processing of Personal Data — Processing of personal data using computer technology. 2.2. Blocking of Personal Data — Temporary cessation of personal data processing (except where processing is necessary for data verification). 2.3. Website — A collection of graphical and informational materials, as well as software and databases, providing access via the network address https://meltzerfirm.com/en/. 2.4. Information System of Personal Data — A system of personal data databases and information technologies and technical means for their processing. 2.5. Anonymization of Personal Data — Actions that make it impossible to determine without additional information the association of personal data with a specific User or other personal data subject. 2.6. Processing of Personal Data — Any action (operation) or set of actions (operations) performed with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction. 2.7. Operator — A state or municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing, as well as determines the purposes of personal data processing, the composition of data subject to processing, and the actions (operations) performed with personal data. 2.8. Personal Data — Any information related directly or indirectly to a specific or identifiable User of the website https://meltzerfirm.com/en/. 2.9. Personal Data Allowed for Distribution — Personal data to which access has been granted to an unlimited number of individuals by the data subject through consent to processing under the Personal Data Law (hereinafter — personal data allowed for distribution). 2.10. User — Any visitor to the website https://meltzerfirm.com/en/. 2.11. Provision of Personal Data — Actions aimed at disclosing personal data to a specific individual or a defined group of individuals. 2.12. Distribution of Personal Data — Any actions aimed at disclosing personal data to an undefined group of individuals (transmission of personal data) or to an unlimited number of individuals, including publicizing personal data in mass media, placing it in information and telecommunications networks, or providing access to personal data in any other way. 2.13. Cross-Border Transfer of Personal Data — Transfer of personal data to a foreign state authority, foreign individual, or foreign legal entity. 2.14. Destruction of Personal Data — Any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of its content in the personal data information system and/or the destruction of physical media containing personal data.
Operator’s Rights and Obligations
3.1. The Operator has the right to:
Obtain accurate information and/or documents containing personal data from the data subject;
Continue processing personal data without consent if the data subject withdraws consent or requests termination, if there are grounds specified in the Personal Data Law;
Independently determine the necessary and sufficient measures to comply with obligations under the Personal Data Law and related regulations, unless otherwise specified by the Personal Data Law or other federal laws.
3.2. The Operator must:
Provide information related to personal data processing upon request;
Organize personal data processing in accordance with current Russian legislation;
Respond to requests and inquiries from data subjects and their legal representatives as required by the Personal Data Law;
Provide necessary information to the authorized body for personal data protection within 10 days of receiving such a request;
Publish or otherwise make this Policy available to the public;
Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, or other illegal actions;
Cease the transmission (distribution, provision, access) of personal data, stop processing, and destroy personal data as required by the Personal Data Law;
Fulfill other obligations under the Personal Data Law.
Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to:
Receive information about the processing of their personal data, except as specified by federal laws. The information should be provided in an accessible form and should not include personal data of other subjects unless legally permissible. The list of information and the procedure for obtaining it are established by the Personal Data Law;
Request correction, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the processing purpose;
Require consent for processing personal data for marketing purposes;
Withdraw consent for personal data processing and request termination of processing;
Appeal against unlawful actions or inactions of the Operator regarding personal data processing to the authorized body for personal data protection or through the court;
Exercise other rights provided by Russian legislation.
4.2. Data subjects must:
Provide accurate data about themselves to the Operator;
Notify the Operator of any changes (updates, modifications) to their personal data.
4.3. Individuals providing false information about themselves or another personal data subject without consent are responsible under Russian law.
Principles of Personal Data Processing
5.1. Personal data processing is carried out legally and fairly. 5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing that is incompatible with the purposes of data collection is not permitted. 5.3. Databases containing personal data for different purposes cannot be combined. 5.4. Only personal data necessary for the purposes of processing is collected. 5.5. The content and volume of personal data processed should correspond to the stated purposes of processing. Excessive data in relation to the stated purposes is not allowed. 5.6. Accuracy, adequacy, and relevance of personal data for processing purposes are ensured. The Operator takes necessary measures to remove or correct incomplete or inaccurate data. 5.7. Personal data is stored in a form that allows identification of the data subject no longer than required for the processing purposes, unless otherwise stipulated by federal law, contract, or agreement involving the data subject. Personal data is destroyed or anonymized upon achieving processing purposes or loss of necessity, unless otherwise specified by federal law.
Purposes of Personal Data Processing
The purposes of processing personal data include:
Order details clarification
Contact information (email address, phone numbers, name)
Legal Basis: Federal Law "On Information, Information Technologies, and Information Protection" No. 149-FZ of July 27, 2006. Types of Processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
Conditions for Processing Personal Data
7.1. Processing is carried out with the consent of the data subject. 7.2. Processing is necessary to achieve goals stipulated by international agreements or laws, or to fulfill the Operator’s legal functions, powers, and obligations. 7.3. Processing is necessary for judicial proceedings, execution of court orders, or other official acts required by Russian law. 7.4. Processing is required for the execution of a contract where the data subject is a party or for entering into a contract on the data subject’s initiative. 7.5. Processing is necessary to protect the Operator’s or third parties' rights and interests or to achieve public objectives, provided it does not violate the data subject’s rights. 7.6. Processing of personal data made accessible by the data subject or at their request (publicly available data). 7.7. Processing of personal data required by federal law to be published or disclosed. 8. Order of Collection, Storage, Transfer, and Other Processing of Personal Data 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 on personal data protection. 8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data by third parties. 8.2. User personal data will never be transferred to third parties under any circumstances, except for cases related to compliance with current legislation or if the data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil-law contract. 8.3. In case of inaccuracies in personal data, the User can update it independently by sending a notification to the Operator at the email address info@meltzerfirm.com with the subject line "Personal Data Update." 8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is specified in the contract or current legislation. The User may withdraw their consent to process personal data at any time by sending a notification to the Operator via email at info@meltzerfirm.com with the subject line "Withdrawal of Consent for Data Processing." 8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section. 8.6. Restrictions set by the data subject on the transfer (except for granting access) or processing of personal data, or conditions for processing (except for access) of personal data permitted for distribution, do not apply in cases of processing personal data in government, public, or other public interests as determined by Russian law. 8.7. The Operator ensures the confidentiality of personal data during processing. 8.8. The Operator stores personal data in a form that allows the identification of the data subject for no longer than necessary to achieve the purposes of personal data processing, unless the storage period is specified by federal law, a contract, or is required by the data subject’s legal obligations. 8.9. Conditions for the cessation of personal data processing may include the achievement of the processing purposes, expiration of the data subject’s consent, withdrawal of consent by the data subject, or a requirement to stop processing personal data, as well as the identification of unlawful processing. 9. List of Actions Performed by the Operator with Received Personal Data 9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data. 9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of received information through information and telecommunication networks or without such transmission. 10. Cross-Border Transfer of Personal Data 10.1. Before starting cross-border transfer activities, the Operator must notify the authorized body for protecting the rights of personal data subjects of their intention to carry out the cross-border transfer of personal data (this notification is sent separately from the notification about the intention to process personal data). 10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from foreign government authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned. 11. Confidentiality of Personal Data The Operator and other individuals who have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law. 12. Final Provisions 12.1. Users may obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at info@meltzerfirm.com. 12.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is effective indefinitely until replaced by a new version. 12.3. The current version of the Policy is freely available on the Internet at https://meltzerfirm.com/en/privacy.