This personal data processing policy has been formulated in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and establishes the procedures for personal data processing and the measures to ensure the security of personal data undertaken by PT CANGGU PRIMA PROPERTI (hereinafter referred to as the "Operator").
1.1. The Operator's primary goal and condition is to uphold the rights and freedoms of individuals and citizens in the processing of their personal data. This includes safeguarding the rights to privacy and confidentiality of personal and family life.
1.2. This Privacy Policy (hereinafter referred to as the "Policy") governs all information that PT CANGGU PRIMA PROPERTI (the "Operator") may collect about visitors to its website https://primaresidence.pro/
2.1. Automated Processing of Personal Data - the processing of personal data using computer technology.
2.2. Blocking of Personal Data - the temporary suspension of personal data processing, except in cases where processing is necessary for the clarification of personal data.
2.3. Website - a collection of graphical and informational materials, as well as computer programs and databases that make them available on the Internet at the network address https://primaresidence.pro/
2.4. Personal Data Information System - a system comprising databases containing personal data and the information technologies and technical means used for processing such data.
2.5. Anonymization of Personal Data - actions that make it impossible to identify the ownership of personal data to a specific User or other personal data subject without additional information.
2.6. Processing of Personal Data - any action (operation) or a series of actions (operations) performed on personal data, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
2.7. Operator - any government agency, municipal body, legal entity, or individual that independently or in conjunction with others organizes and/or processes personal data. It also refers to those who determine the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed on the personal data.
2.8. Personal Data - encompasses all information directly or indirectly associated with a specific or identifiable user of the website https://primaresidence.pro/
2.9. Personal Data Authorized for Distribution - personal data for which the data subject has provided consent for processing and unrestricted access by any person, in accordance with the procedures outlined in the Personal Data Law (hereinafter referred to as "authorized personal data").
2.10. User - any individual accessing the https://primaresidence.pro/ website.
2.11 Provision of Personal Data - actions aimed at making personal data available to a specified individual or group.
2.12. Dissemination of Personal Data - any activities aimed at making personal data available to an undefined audience, including the transfer of personal data, making it accessible to the public, publishing in mass media, posting on information and telecommunication networks, or otherwise providing access to personal data.
2.13. Cross-Border Personal Data Transfer - the process of transferring personal data to a foreign country, to the authorities of a foreign state, foreign individuals, or foreign legal entities.
2.14. Destruction of Personal Data - any actions resulting in personal data being permanently destroyed, making its content unrecoverable in the personal data information system and/or leading to the physical destruction of the data carriers.
3.1. The Operator is entitled to:
3.2. The Operator is obliged to:
3.3. The Operator has the right to send the User notifications about new products and services, special offers and various events. The User can always opt out of receiving informational messages by sending the Operator a letter to the e-mail address sales@primaresidence.pro with the note "Opt-out of notifications about new products and services and special offers".
4.1 Rights of Personal Data Subjects
Subjects of personal data are entitled to:
4.2. Obligations of Personal Data Subjects:
4.3. Individuals who submit false information to the Operator about themselves or about another personal data subject without their consent are subject to liability under the laws of the Russian Federation.
5.1. Personal data must be processed lawfully and fairly.
5.2. The processing of personal data is confined to achieving explicit, predefined, and legitimate objectives. Processing personal data for purposes incompatible with the initial reasons for collection is prohibited.
5.3. Merging databases containing personal data processed for mutually incompatible purposes is not permitted.
5.4. Only personal data relevant to the purposes of its processing is subject to processing.
5.5. The content and volume of personal data processed must match the declared processing objectives. Excess processing of personal data beyond what is necessary for its declared purposes is prohibited.
5.6. Accuracy, sufficiency, and, where applicable, timeliness of personal data must be maintained throughout processing. The Operator is responsible for taking or ensuring necessary actions to correct or delete any incomplete or inaccurate data.
5.7. Personal data must be stored in a manner that allows for the identification of the data subject only as long as is necessary for the purposes of data processing. If not specified by federal law or outlined in a contract where the data subject is a party, beneficiary, or guarantor, the storage period should not exceed the duration needed to achieve the processing objectives. Once these objectives are met or no longer required, the processed personal data must be either destroyed or anonymized, unless federal law stipulates otherwise.
The primary objective of processing is to grant Users access to services, information, and/or materials available on the website.
Personal data processed includes:
Legal Basis:
Types of Personal Data Processing:
7.1. Personal data processing is conducted with the explicit consent of the data subject for the processing of their personal data.
7.2. Personal data processing is required to fulfill objectives stipulated by international treaties of the Russian Federation or laws, and to carry out the functions, powers, and responsibilities assigned to the operator by Russian Federation legislation.
7.3. Personal data processing is essential for the administration of justice, enforcement of judicial decisions, or actions of other bodies or officials, which must be executed in accordance with Russian Federation laws on enforcement proceedings.
7.4. Personal data processing is required for the execution of a contract where the data subject is a party, beneficiary, or guarantor. This also applies to contracts initiated by the data subject or contracts where the data subject will be the beneficiary or guarantor.
7.5. Personal data processing is essential for exercising the rights and legitimate interests of the operator or third parties, or for achieving publicly significant objectives, ensuring it does not infringe upon the rights and freedoms of the data subject.
7.6. Processing includes personal data for which the data subject has provided access to an unlimited number of persons or has requested to be made publicly available (hereinafter referred to as "publicly available personal data").
7.7. Processing involves personal data that must be published or disclosed as required by federal law.
The Operator ensures the security of processed personal data by implementing legal, organizational, and technical measures required to fully comply with current personal data protection legislation.
8.1. The Operator guarantees the protection of personal data and implements all feasible measures to prevent access by unauthorized persons.
8.2. User personal data shall not be transferred to third parties under any circumstances, except when required by law or when the personal data subject has explicitly consented to the transfer of their data to a third party for the fulfillment of obligations stipulated by a civil contract.
8.3. If inaccuracies in personal data are discovered, Users can correct them by sending a notification to the Operator's email address at sales@primaresidence.pro, marked "Personal Data Update."
8.4. The processing period of personal data is defined by the achievement of the objectives for which the personal data were collected unless otherwise specified by a contract or applicable legislation. Users may revoke their consent to process personal data at any time by sending an email to the Operator at sales@primaresidence.pro with the subject "Withdrawal of Consent for Personal Data Processing."
8.5. Information collected by third-party services, including payment systems and communication providers, is managed and processed by these entities according to their User Agreements and Privacy Policies. The Operator is not responsible for third-party actions, including those service providers mentioned herein.
8.6. Restrictions set by the personal data subject on data transfer (excluding access provision), as well as on processing or conditions of processing (excluding access acquisition) of publicly available personal data, do not apply in instances of data processing for state, public, or other public interests as defined by Russian law.
8.7. The Operator guarantees the confidentiality of personal data during its processing.
8.8. Personal data is stored in a manner that allows for the identification of the data subject only as long as is necessary for the processing purposes, unless a longer retention period is required by federal law or a contract involving the personal data subject as a party, beneficiary, or guarantor.
8.9. Processing of personal data may cease upon achieving the processing objectives, expiration or withdrawal of the data subject's consent, a request to halt data processing, or if unlawful data processing is identified.
9.1. The Operator engages in collecting, recording, organizing, accumulating, storing, refining (updating, modifying), retrieving, utilizing, transferring (distributing, making available, granting access), anonymizing, blocking, deleting, and destroying personal data.
9.2. The Operator conducts automated processing of personal data, involving the receipt and/or dissemination of information through information and telecommunication networks, or without such networks.
10.1. Prior to initiating cross-border personal data transfers, the Operator is required to inform the authorized data protection authority of its intention, sending this notification separately from any notice regarding personal data processing activities.
10.2. Additionally, before issuing the said notification, the Operator must secure relevant confirmations from the governmental bodies, foreign individuals, and legal entities in the recipient country intended for the trans-border personal data transfer.
The operator and other persons who have access to personal data must not disclose to third parties and not disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12.1. Users may seek clarifications on any queries related to the processing of their personal data by reaching out to the Operator via email at sales@primaresidence.pro.
12.2. Any changes to the Operator's personal data processing policy will be documented in this Policy, which remains in effect indefinitely until superseded by a newer version.
