Goals of PD processing and their types

All of the following PDs are general, meaning they do not fall under the category of special or biometric personal data.

Purpose of PD processing	Types of PD	Category of users whose data is being processed	Processing time	Processing base
consideration of the User’s online request sent by filling out the contact form	last name, first name, patronymic, organization (place of work), email address	users who send a request via the contact form	during the request processing period	Your consent, expressed by checking the box and clicking the «Submit» button
preparation, conclusion, and execution of a civil law contract	last name, first name, patronymic, organization (place of work), phone number, email address	users who submit an application or request for a commercial offer and intend to enter into a contract on their own behalf or on behalf of an organization, including contractors, representatives of contractors and clients, clients, and beneficiaries under contracts	during the period of request processing and (or) contract execution	Your consent, expressed by checking the box and clicking the «Submit» button
a response to a User’s call using the number provided on the Website, or a response to an email received at the email address provided on the Website	last name, first name, patronymic, organization (place of work), phone number, email address	users who have made a call to a number listed on the Website or sent an email to an email address listed on the Website	until the goal is achieved or the consent to process PD is revoked	Our legitimate interest in improving the quality of our services, and your consent, expressed by providing your data by phone or email
ensuring and improving the Website’s operation through anonymized statistical recording	IP address, location data, and cookies	all users (except those who have disabled cookies in their browser)	until the goal is achieved or the consent to process PD is revoked	Your consent expressed in the form of continuing to use the Site and (or) by clicking » ok » in the banner that pops up when entering the site

Site User Rights

The Website User has the following rights:

· Right of access	You have the right to request a copy of the personal data we have
* Right to clarify	You can ask us to correct inaccurate or incomplete personal data
* Right of withdrawal	You can withdraw your consent to the processing of your personal data at any time.
* The right to be forgotten	You can request the deletion of the data we have about you, except in cases where we are required to keep this data by law.

The User has the right to withdraw their consent to the processing of personal data at any time by sending a written notification to the email address surgimed@ya.ru (hereinafter referred to as the «Operator’s email address») with the subject «Withdrawal of Consent to the Processing of Personal Data.»

The right of access is implemented by::

• send a request to the email address surgimed@ya.ru. In this case, the request must be signed with an electronic signature in accordance with the legislation of the Russian Federation;
• send your request to our postal address: 142450, Moscow Region, Noginsky District, Staraya Kupavna, Dorozhnaya Street, 1, Building 2 (hereinafter referred to as the «Operator’s postal address»).

Other rights can be exercised by sending a written notification to the Operator’s postal or electronic address, and in the case of an electronic letter, by marking the subject line accordingly.

The request must include your passport details, your full name, and information about our relationship with you, during which we obtained your personal data.

If you have any complaints and / or questions, you can always contact us or appeal against our actions (omissions), including decisions made based solely on automated processing of their personal data, to the territorial authority of Roskomnadzor in your region.

Methods for granting consent to the processing of personal data

You can give us your consent to process your personal data in the following ways:

• after filling in the fields that imply entering the PD, set a «check mark» in the corresponding field on the Site and (or) perform further suggested actions (for example, click «Submit», «Register», etc.);
• with respect to cookies — by continuing to use the Site and / or by clicking the «ok» button in the banner that pops up when entering the Site.

Transfer of PD to third parties

We do not transfer your Personal Data to third parties without your consent, except in cases where we are required to do so by law or when such transfer is necessary for the conclusion and / or performance of a contract concluded with the User.

When you provide us with your personal data for the purpose of preparing, concluding, and executing a civil law contract, or when you submit an online request and receive a response from us by phone or email, your name, phone number, and email address are shared with a third party, Surgimed LLC , which processes the personal data received through the Website on behalf of the Operator. By giving your consent to the processing of your personal data for the purpose of processing your online application or preparing, concluding, and executing a contract, you are consenting to the transfer of your personal data to Surgimed LLC for the above purpose.

Termination of PD processing

We stop processing personal data under the following conditions:

• achieving the goals of processing personal data and (or) the maximum storage period for personal data within 30 days;
• identification of unlawful processing of personal data, including the fact of illegal receipt of personal data or the absence of a need for personal data for the stated purpose of processing personal data — within a period of no more than 3 business days from the date of identification (during the period of verification of the legality of processing personal data, they are subject to immediate blocking);
• You can withdraw your consent to the processing of your personal data if the processing of your personal data is no longer necessary for the purposes of processing your personal data within 30 days.
• Your request to us to stop processing your personal data, except in cases specified by law, must be fulfilled within 10 days.

When the purposes of PD processing are achieved, or in any other case of PD processing termination provided for by the Policy, we destroy the PD if:

• unless otherwise provided by the contract to which you are a party, beneficiary, or guarantor;
• we do not have the right to process personal data without the subject’s consent, except as provided for by the Federal Law on Personal Data or other federal laws;
• otherwise provided for by another agreement between the Operator and You.

We destroy PD in a way that makes it impossible to recover the PD. If it is impossible to destroy the PD without damaging the material medium in a way that prevents it from being used for its intended purpose, then both the PD and the material medium must be destroyed.

Destruction of PD in PD processing information systems and PD alienable machine media is carried out using standard means or specialized software, hardware, or software-hardware means that include information destruction (data erasure) or physical destruction of disk chips.

Storage, protection and security of PD

The PDs that we collect and store are considered confidential information (except in cases where the PDs are processed by an unlimited number of people, or at the request of the User). They are protected from loss, modification, or unauthorized access, as required by law.

In particular, we take measures provided for in Articles 18.1 and 19 of the Federal Law on Personal Data.

We have complied with the requirements for data localization, which means that we store personal data in the Russian Federation.

We carry out internal control of the compliance of PD processing with the Federal Law «On Personal Data Protection» and the regulatory legal acts adopted in accordance with it, the requirements for PD protection, the Operator’s policy regarding PD processing, and the Operator’s local acts.

We periodically inform the Operator’s employees who process personal data about the provisions of the Russian Federation’s legislation on personal data (including the requirements for personal data protection) and local regulations on personal data processing.

Changing the Policy

We reserve the right to modify, add, or remove parts of this Policy at any time and at our sole discretion. If any significant changes are made, we will notify you by posting them on the Website.

The new version of the Policy comes into force on the date of its publication on the Internet.

The current version of the Policy is available at https://surjimed.com/p-p/.

Operator’s details

SurzhiMed Limited Liability Company

TIN 7709886751 PKP 503101001 OGRN 1117746778995 E-mail: surgimed@ya.ru 142450, Moscow Region, Noginsky District, Staraya Kupavna, Dorozhnaya Street, 1, Building 2