This Personal Data Processing Policy (hereinafter referred to as the "Policy") is applicable to the information in relation to the User, which is located at https://www2.colliers.com/ and can be obtained by Colliers International Limited Liability Company (hereinafter referred to as the "Operator") when using the Colliers International website. The Personal Data Processing Policy is made in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.
1. Main definitions used in the Policy:
"Personal Data" means any information related to an individual, which can be directly or indirectly identified or identifiable (a Personal Data Subject).
“Personal Data for which the Personal Data Subject authorized distribution” means personal data in respect of which the Personal Data Subject authorized access by an unlimited number of persons by consenting to the processing of personal data which the personal data subject allowed to distribute in accordance with the procedure established by this Federal Law.;
"Personal Data Provision" means the actions aimed at disclosure of the Personal Data to a certain person or a certain circle of persons.
“Automated Data Processing” means the processing of personal data by means of computer equipment. "Data Processing" means any action (operation) or a set of actions (operations) performed with or without the use of automation equipment in relation to Personal Data, including collection, recording, systematization, accumulation, storage, rectification (update, change), extraction, using, transfer, including cross-border transfer (distribution, provision, access), subject to the personal data subject’s consent, depersonalization, blocking, deletion, destruction of Personal Data;
Personal Data for which the Personal Data Subject authorized distribution shall be processed in compliance with the restrictions and conditions provided for by Article 10.1 of Law No. 152-FZ dated July 27, 2006.
"Personal Data Confidentiality" means a mandatory requirement for the Operator or other person, who has access to Personal Data, not to allow distribution thereof without a consent of the Personal Data Subject or another legal basis. "Blocking of Personal Data" means a temporary termination of Personal Data Processing (except for cases when the processing is required to rectify the Personal Data).
"Depersonalization of Personal Data" means the actions that make it impossible to determine the belonging of the Personal Data to a specific User or other Personal Data Subject without using additional information.
"Distribution of Personal Data" means any actions aimed at disclosure of the Personal Data to an indefinite circle of persons (Transfer of Personal Data) or at familiarization with the Personal Data of an unlimited circle of persons, including disclosure of Personal Data in the mass media, placement in the information and telecommunication networks, or provision of the access to Personal Data in any other way.
"Cross-Border Transfer of Personal Data" is the Transfer of Personal Data to the territory of a foreign state, to the authority of a foreign state, a foreign individual or a foreign legal entity.
"Destruction of Personal Data" means any actions resulted in the permanent destruction of the Personal Data with the impossibility of further recovery of the Personal Data in the Personal Data Information System and/or in the destruction of the physical media bearing the Personal Data. "Personal Data Information System" is a set of Personal Data contained in the databases, and information technologies and technical means ensuring the processing thereof. "Colliers International Website User" (hereinafter, the "User") is a person having access to the Website via Internet and using the Colliers International Website.
"Cookies" is a small piece of data sent by a web server, stored on the User’s computer and forwarded by a web client or a web browser to the web server in the HTTP request while attempting to open a page of the respective website.
"IP address" is a unique network address of a node in a computer network arranged on the basis of IP protocol.
"Website" is all the information (textual and graphic) and functions located on the Internet at https://www2.colliers.com/, including all internal pages of this address.
"Website Administration" is the Operator’s authorized employees, which act on its behalf and organize the processing or process the Personal Data, as well as determine the purposes of Personal Data Processing, scope of Personal Data to be processed, actions (operations) performed with the Personal Data.
2. General Provisions
2.1. This Policy defines the procedure for processing and protection of User Information, which can be obtained by the Operator when the User fills out a registration form on the website https://www2.colliers.com/, by the Website Administration (Operator), as well as the procedure of and the User’s consent to the receiving of the newsletters when filling out the registration form on the website https://www2.colliers.com/.
2.2. The purpose of this Policy is to ensure the proper protection of User Information, including their Personal Data, from unauthorized access and disclosure, and the compliance with the statutory regulations on advertising, including when the User receives promotional information.
2.3. Relations connected to the collection, storage, distribution and protection of the information provided by the User are regulated by this Policy and the applicable laws of the Russian Federation.
2.4. By using the Colliers International Website, the User consents to Personal Data Processing by the Operator and to the receipt of advertising information from the Operator in accordance with this Policy and the terms and conditions for processing the User's Personal Data by filling out the registration forms.
2.5. If the User does not agree to the terms of the Policy, the User must stop using the Website.
2.6. This Policy is applicable only to the Colliers International Website. The Website Administration does not control and is not responsible for third-party websites to which the User can go by following the links available on the Website.
2.7. Personal Data allowed to be processed under this Policy shall be provided by the User by filling out the registration form and includes the following information:
- full name of the User;
- contact telephone number of the User;
- email address.
2.8. By filling out the registration form, the User express their agreement with the terms of this Policy. This consent is given to perform actions with the specified Personal Data necessary to achieve the purposes specified in Section 3 hereof, including, without limitation, to collect, systematize, accumulate, store, rectify (update, amend), use, transfer to third parties (including cross-border transfer (distribute – subject to the obtainment of a separate consent from the Personal Data Subject -, provide, access)), depersonalize, block, delete, destroy personal data, and perform any other actions provided by the applicable laws of the Russian Federation.
2.9. By pressing "Send", the User consents to all the above actions with the Personal Data provided when filling out the registration forms, and to the receipt of promotional newsletters from the Operator. Period of validity of this consent (if given): until six months expire after the User revokes the consent to receive the relevant information.
3. Purposes of Personal Data Processing
3.1. The purposes of User’s Personal Data Processing are:
- entry into, execution and termination of civil law contracts;
- providing the User with access to the services, information and/or materials contained on the website https://www2.colliers.com/;
- promoting the Operator's services with the subsequent sending of mail, email, messages on WhatsApp, Viber, Contact, as well as phone calls and SMS of promotional content, information and newsletters, invitations to the Operator's events, notifications about offers, events, discounts and other promotional information or news.
3.2. The User may always refuse to receive promotional messages by sending an email to the Operator marked as “Refuse to receive notifications about new services and special offers”.
4. Legal Basis of Personal Data Processing
4.1. The Website Administration processes the User’s Personal Data only if they are entered into and/or sent by the User independently via the special form located at website https://www2.colliers.com/. By filling out the appropriate form and/or sending their Personal Data to the Operator, the User agrees to this Policy.
5. Procedure for Personal Data Collection, Storage, Transfer and Other Types of Personal Data Processing
5.1. The security of Personal Data processed by the Website Administration is ensured by implementing legal, organizational and technical measures required for full compliance with the requirements of applicable legislation in the field of Personal Data Protection.
5.2. The Website Administration (Operator) ensures the safety of Personal Data and takes all possible measures to prevent unauthorized access to the Personal Data.
5.3. If inaccuracies in Personal Data are detected, the User may update them independently by sending a notification marked as “Personal Data Update” to the Operator’s e-mail address.
5.4. The term for Personal Data Processing starts as of its effective date and ends on the date of the relevant request. The User may at any time withdraw their consent to the Personal Data Processing by sending notification to the Website Administration marked as “Withdrawal of Consent to the Personal Data Processing”, “Withdrawal of Consent to the Processing of Personal Data for which the Personal Data Subject Authorized Distribution” to the Operator’s e-mail address, or a written notification to the location address.
5.5. The User agrees that the Website Administration (Operator) has the right to transfer the Personal Data to third parties solely for the purposes specified in Section 3 of this Personal Data Processing Policy and except for cases related to the applicable legislation.
5.6. The User’s Personal Data may be transferred to the authorized state bodies of the Russian Federation only on the grounds and in accordance with the procedure established by the legislation of the Russian Federation.
5.7. If the Personal Data are lost or disclosed, the Website Administration shall inform the User about the loss or disclosure of the Personal Data.
5.8. The Website Administration shall take all organizational and technical measures required to protect the User’s Personal Information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
5.9. The Website Administration together with the User shall take all measures required to prevent losses or other negative consequences caused by the loss or disclosure of the User’s Personal Data.
6. Cross-Border Transfer of Personal Data
6.1. The Operator must ensure that a foreign state, to which the Personal Data is intended to be transferred, ensures the reliable protection of the Personal Data Subjects’ rights before the start of Cross-Border Transfer of the Personal Data.
6.2. The Cross-Border Transfer of Personal Data on the territory of the foreign states, which do not meet the above requirements, may only be carried out if the Personal Data Subject agrees in writing to such cross-border transfer of their Personal Data and/or in case of execution of a contract, to which the Personal Data Subject is a party.
7. Obligations of the Parties
7.1. The Website Administration shall:
7.1.1. Use the received information only for the purposes specified in Clause 3 of this Policy.
7.1.2. Ensure that the confidential information is kept confidential, not to disclose such information without a User’s prior written consent, as well as not to sell, not to exchange, not to post, or not to disclose in any other ways the User’s Personal Data, which were transferred, except for Clauses 5.5., 5.6 of this Policy.
7.1.3. Take preventive measures to protect the confidentiality of the User’s Personal Data in accordance with the procedure usually used to protect such information in the existing business practice.
7.2. The User shall:
7.2.1. Provide information about the Personal Data required for using the Website.
7.2.2. Update or amend the provided information about the Personal Data in case of changes to this information.
8.1. In case of failure to perform obligations, the Operator shall be responsible for losses, incurred by the User in connection with the illegal use of Personal Data, in accordance with the legislation of the Russian Federation, except for the cases provided for in Clause 5.2. and Clause 7.2. of this Policy.
8.2. If the confidential information is lost or disclosed, the Operator shall be not responsible if such confidential information:
8.2.1. Came into public domain before it was lost or disclosed.
8.2.2. Was received from a third party before it was received by the Operator.
8.2.3. Was disclosed with the User’s consent.
8.2.4. Was disclosed by third-party websites and services, links to which are available on the Website, in case of following such links and using such services by the User.
8.3. The User is solely responsible for the possible consequences of submitting inaccurate and/or incomplete Personal Data.
9. Final Provisions
9.1. The User may obtain any clarifications on issues of interest related to the processing of their Personal Data by contacting the Website Administration.
9.2. This document will reflect any changes to the Operator’s Personal Data Processing Policy. The Policy is valid indefinitely until it is replaced with a new version.
9.3. The current version of Personal Data Processing Policy is available at the following link: https://www2.colliers.com/
If you have any questions about this Personal Data Processing Policy, please contact us:
10 Presnenskaya Embankment
BC Naberezhnaya Tower, Block C
Moscow, 123112, Russia
Phone +7 495 258 5151