Privacy Policy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”), and establishes the procedures for processing personal data and the measures taken to ensure the security of personal data by SCORPION Private Security Company LLC (hereinafter referred to as the “Operator”).
1.1. The Operator’s primary objective and condition for conducting its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of privacy and personal and family confidentiality.
1.2. This Policy regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://security-scorpion.com/.
2. Basic Terms Used in This Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where processing is necessary to clarify personal data.
2.3. Website means a collection of graphic and informational materials, computer programs, and databases that ensure their availability on the Internet at https://security-scorpion.com/.
2.4. Personal data information system means a collection of personal data contained in databases, together with information technologies and technical means used to process such data.
2.5. Anonymization of personal data means actions that make it impossible to identify a specific User or other personal data subject without using additional information.
2.6. Processing of personal data means any action or set of actions performed on personal data, with or without the use of automated means, including collection, recording, systematization, accumulation, storage, updating, modification, retrieval, use, transfer, dissemination, provision of access, anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator means a government authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or processes personal data, as well as determines the purposes of processing, the categories of personal data to be processed, and the actions performed on such data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://security-scorpion.com/.
2.9. Personal data authorized for dissemination by the data subject means personal data to which an unlimited number of persons have been granted access by the data subject through consent to the processing of personal data authorized for dissemination, in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for dissemination”).
2.10. User means any visitor to the website https://security-scorpion.com/.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an unlimited number of persons or making personal data available to an unlimited number of persons, including publication in mass media, posting on information and telecommunications networks, or providing access by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore their contents in a personal data information system, and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
- Obtain reliable information and/or documents containing personal data from the personal data subject.
- Continue processing personal data without the data subject’s consent if the data subject withdraws consent to processing or submits a request to terminate processing, provided that the grounds specified in the Personal Data Law exist.
- Independently determine the composition and list of measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and related regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
- 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 applicable laws 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 personal data protection authority with the information it requests within 10 days of receiving such a request.
- Publish this 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, dissemination, and other unlawful actions involving personal data.
- Cease the transfer, dissemination, provision of access to, or processing of personal data, and destroy personal data in accordance with the procedures and circumstances established by the Personal Data Law.
- Fulfill other obligations established by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
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 law. Such information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other data subjects, unless there are lawful grounds for disclosure. The scope of information and the procedure for obtaining it are established by the Personal Data Law.
- Request that the Operator correct, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and take legal measures to protect their rights.
- Require prior consent for the processing of personal data for the purpose of promoting goods, works, or services in the market.
- Withdraw consent to the processing of personal data and submit a request to terminate such processing.
- Appeal unlawful actions or omissions of the Operator in processing their personal data to the authorized personal data protection authority or through the courts.
- Exercise other rights provided for by the laws of the Russian Federation.
4.2. Personal data subjects are obliged to:
- Provide the Operator with accurate information about themselves.
- Notify the Operator of any updates or changes to their personal data.
4.3.
Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent shall be liable in accordance with the laws of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes for which personal data were collected is not permitted.
5.3. Databases containing personal data processed for purposes that are incompatible with one another shall not be combined.
5.4. Only personal data relevant to the purposes of processing shall be processed.
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, their accuracy, sufficiency, and, where necessary, relevance to the purposes of processing shall be ensured. The Operator shall take, or ensure the taking of, necessary measures to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the data subject to be identified for no longer than is necessary to achieve the purposes of processing, unless a retention period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized once the purposes of processing have been achieved or when the need to achieve those purposes no longer exists, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Informing the User by sending email messages.
Personal data:
- Last name, first name, and patronymic;
- Email address;
- Telephone numbers.
Legal grounds: Federal Law No. 149-FZ of July 27, 2006, “On Information, Information Technologies and Information Protection.”
Types of personal data processing: Transfer of personal data.
7. Conditions for Processing Personal Data
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve purposes established by an international treaty of the Russian Federation or by law, and to perform functions, powers, and duties imposed on the Operator by the laws of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the enforcement of a court judgment, or the enforcement of an act issued by another authority or official in accordance with the laws of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data processing is carried out where access to such data has been granted to an unlimited number of persons by the 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 shall be processed.
8. Procedures for the 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 applicable personal data protection legislation.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized persons from accessing such data.
8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except where such transfer is required by 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 contract.
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@security-scorpion.com with the subject line “Personal Data Update.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the data were collected, unless another period is established by a contract 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 by email at info@security-scorpion.com with the subject line “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 those parties (operators) in accordance with their respective Terms of Service and Privacy Policies. The personal data subject should familiarize themselves with these documents. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this section.
8.6. Restrictions imposed by a personal data subject on the transfer of personal data (except for granting access), as well as on the processing or conditions of processing of personal data authorized for dissemination (except for obtaining access), shall not apply where personal data are processed in the public, state, or other public interests established by the laws of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during processing.
8.8. The Operator shall store personal data in a form that allows the data subject to be identified for no longer than is necessary to achieve the purposes of processing, unless a retention period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the data subject’s consent, withdrawal of consent by the data subject, receipt of a request to terminate processing, or identification of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, updates, modifies, retrieves, uses, transfers, disseminates, provides access to, anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data, including the receipt and/or transfer of information through information and telecommunications networks or without the use of such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfers of personal data, the Operator is required to notify the authorized personal data protection authority of its intention to carry out such transfers. This notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the notification referred to above, the Operator shall obtain the relevant information from the foreign government authorities, 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 any other persons who have access to personal data are obliged not to disclose such data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarification regarding the processing of their personal data by contacting the Operator via email at info@security-scorpion.com.
12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. This Policy remains in effect indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: