Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of European Union Regulation No. 679 of 25 May 2018, the General Data Protection Regulation (hereinafter referred to as the “Personal Data Law”), and defines the procedure for processing personal data and the measures adopted by BWS LEGAL LIMITED (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers compliance with the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy and personal and family confidentiality, to be its most important goal and a prerequisite for carrying out its activities.
1.2. This Policy of the Operator 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: http://bws-limited.com/
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer equipment.
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 set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address: http://bws-limited.com/
2.4. Personal data information system means a set of personal data contained in databases, and the information technologies and technical means used for their processing.
2.5. Anonymization of personal data means actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation tools in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, amendment), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator means a public authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, and determines the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website http://bws-limited.com/
2.9. Personal data permitted by the personal data subject for dissemination means personal data to which an unlimited number of persons has been granted access by the personal data subject through consent to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User means any visitor to the website http://bws-limited.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 indefinite number of persons (transfer of personal data) or making personal data accessible to an unlimited number of persons, including publication in the media, placement in information and telecommunication networks, or provision of access to personal data 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 an authority of a foreign state, or to a foreign individual or legal entity.
2.14. Destruction of personal data means 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.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
receive accurate information and/or documents containing personal data from the personal data subject;
continue processing personal data without the consent of the personal data subject in the event that such consent is withdrawn, provided there are grounds specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law and applicable regulations adopted pursuant thereto, 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 relating to the processing of his or her personal data;
organize the processing of personal data in accordance with the applicable legislation of the European Union;
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 for the protection of the rights of personal data subjects with the necessary information within 30 days from the date of receipt of such request;
publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
adopt legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions;
stop the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the cases and in the manner provided by the Personal Data Law;
perform other obligations предусмотренные by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
receive information regarding the processing of their personal data, except in cases provided for by law. Such information shall be provided in an accessible form and must not include personal data relating to other subjects unless there are lawful grounds for such disclosure. 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 not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
impose a condition of prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;
withdraw consent to the processing of personal data;
appeal unlawful actions or inaction of the Operator in relation to the processing of personal data to the authorized body for the protection of the rights of personal data subjects or in court;
exercise other rights provided by European Union legislation.
4.2. Personal data subjects are obliged to:
provide the Operator with accurate personal data about themselves;
notify the Operator of any clarification (update, amendment) of their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without the consent of such subject shall bear liability in accordance with EU legislation.
5. Personal Data That May Be Processed by the Operator
5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Telephone numbers.
5.4. The website also collects and processes anonymized data about visitors (including “cookie” files) using Internet statistics services (Google Analytics and others).
5.5. The above-mentioned data are collectively referred to in this Policy as Personal Data.
5.6. The Operator does not process special categories of personal data relating to race, nationality, political opinions, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data permitted for dissemination from among the special categories of personal data specified in the Personal Data Law is permitted provided that the prohibitions and conditions established by the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for dissemination shall be оформляется separately from other consents to the processing of his or her personal data. At the same time, the conditions provided for, in particular, by the Personal Data Law shall be observed. The requirements for the content of such consent shall be established by the authorized body for the protection of the rights of personal data subjects.
5.8.1. The User provides consent to the processing of personal data permitted for dissemination directly to the Operator.
5.8.2. No later than three business days from receipt of such consent, the Operator shall publish information on the conditions of processing and on the existence of prohibitions and conditions on the processing by an unlimited number of persons of personal data permitted for dissemination.
5.8.3. The transfer (dissemination, provision, access) of personal data permitted by the personal data subject for dissemination shall be terminated at any time upon request of the personal data subject. Such request must include the surname, first name, patronymic (if any), contact information (telephone number, email address, or postal address) of the personal data subject, as well as the list of personal data whose processing is to be terminated. The personal data specified in such request may only be processed by the Operator to whom the request was sent.
5.8.4. Consent to the processing of personal data permitted for dissemination shall terminate from the moment the Operator receives the request specified in Clause 5.8.3 of this Policy.
6. Principles of Personal Data Processing
6.1. Personal data shall be processed on a lawful and fair basis.
6.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing incompatible with the purposes of data collection is not permitted.
6.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
6.4. Only personal data that meets the purposes of processing shall be processed.
6.5. The content and scope of processed personal data shall correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes is not permitted.
6.6. When processing personal data, the Operator shall ensure its accuracy, sufficiency, and, where necessary, relevance to the purposes of processing. The Operator shall take necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form allowing the identification of the personal data subject no longer than is required for the purposes of processing, unless a storage period is established by federal law or by a contract to which the subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or when the need to achieve such purposes no longer exists, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purposes of processing the User’s personal data are:
informing the User by means of email communications;
conclusion, performance, and termination of civil law contracts;
providing the User with access to services, information, and/or materials available on the website http://bws-limited.com/
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may always opt out of receiving informational messages by sending an email to support@bws-limited.com
with the subject line: “Opt-out from notifications about new products, services, and special offers.”
7.3. Anonymized User data collected through Internet statistics services is used to gather information about User actions on the website and to improve the quality of the website and its content.
8. Legal Grounds for Processing Personal Data
8.1. The legal grounds for processing personal data by the Operator are:
contracts concluded between the Operator and the personal data subject;
in accordance with international law of the European Union;
laws and other regulatory legal acts in the field of personal data protection;
User consents to the processing of their personal data and to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User’s personal data only if it is filled in and/or submitted by the User independently through special forms located on the website http://bws-limited.com/
or sent to the Operator via email. By completing the relevant forms and/or sending personal data to the Operator, the User expresses consent to this Policy.
8.3. The Operator processes anonymized User data if this is allowed in the User’s browser settings (cookie storage and JavaScript technology enabled).
8.4. The personal data subject independently decides to provide his or her personal data and gives consent freely, of his or her own will, and in his or her own interest.
9. Conditions for Processing Personal Data
9.1. Personal data shall be processed with the consent of the personal data subject.
9.2. Processing of personal data is necessary to achieve purposes provided by an international treaty of the European Union or by law, and to perform functions, powers, and duties imposed on the Operator by European Union legislation.
9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to execution in accordance with European Union legislation on enforcement proceedings.
9.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or of a contract under which the subject will be a beneficiary or guarantor.
9.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Processing is carried out in respect of personal data to which access has been granted to an unlimited number of persons by the personal data subject or at his or her request (hereinafter referred to as “publicly available personal data”).
9.7. Processing is carried out in respect of personal data that is subject to publication or mandatory disclosure in accordance with federal law.
10. Procedure for Collection, Storage, Transfer, and Other Types of 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 applicable legislation in the field of personal data protection.
10.1. The Operator ensures the security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. Under no circumstances will the User’s personal data be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has consented to the transfer of data to a third party for the performance of obligations under a civil law contract.
10.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notice to the Operator at support@bws-limited.com
with the subject line: “Personal Data Update.”
10.4. 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 by contract or applicable law.
The User may at any time withdraw consent to the processing of personal data by sending a notice via email to support@bws-limited.com
with the subject line: “Withdrawal of Consent to Personal Data Processing.”
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must independently and promptly review such documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
10.6. Restrictions established by the personal data subject on the transfer (except for access), processing, or conditions of processing (except for access) of personal data permitted for dissemination shall not apply in cases where personal data is processed in state, public, or other public interests determined by EU legislation.
10.7. The Operator shall ensure the confidentiality of personal data during processing.
10.8. The Operator stores personal data in a form allowing the identification of the personal data subject no longer than is required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. Grounds for termination of personal data processing may include achievement of the purposes of processing, expiry of the consent period, withdrawal of consent by the personal data subject, or identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, amendment), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with receipt and/or transfer of information via information and telecommunication networks, or without such transfer.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator shall ensure that the foreign state to whose territory personal data is to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements may be carried out only if the personal data subject has provided written consent to such transfer and/or where the transfer is necessary for the performance of a contract to which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data shall not disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by law.
14. Final Provisions
14.1. The User may obtain any clarifications regarding issues related to the processing of personal data by contacting the Operator via email at support@bws-limited.com
14.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy shall remain in force indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at: http://bws-limited.com/