Personal Data Processing Policy
1. General provisions
This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the Personal Data Law). It sets out the procedures for processing personal data and the measures taken to protect it by Valeria Sergeevna Gruzdeva (the Operator).
1.1. Respect for human and civil rights and freedoms when processing personal data, including the rights to privacy and personal and family confidentiality, is a key objective and condition of the Operator's activities.
1.2. This Policy applies to all information the Operator may obtain about visitors to https://web-gruzdeva.ru/.
2. Definitions used in this Policy
2.1. Automated processing of personal data means processing personal data using computer technology.
2.2. Blocking personal data means temporarily suspending its processing, except where processing is necessary to clarify the data.
2.3. Website means the collection of graphic and information materials, software and databases made available online at https://web-gruzdeva.ru/.
2.4. Personal data information system means the personal data contained in databases together with the information technologies and technical resources used to process it.
2.5. Depersonalisation means actions that make it impossible to determine, without additional information, which User or other data subject particular personal data relates to.
2.6. Processing personal data means any action or set of actions performed on personal data, with or without automated means, including collection, recording, organisation, accumulation, storage, clarification (updating or amendment), retrieval, use, transfer (distribution, provision or access), depersonalisation, blocking, deletion and destruction.
2.7. Operator means a public authority, municipal authority, legal entity or individual that, alone or jointly with others, organises and/or processes personal data and determines the purposes of processing, the data to be processed and the actions performed on it.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://web-gruzdeva.ru/.
2.9. Personal data authorised for distribution means personal data to which a data subject has granted access to an unlimited number of people by consenting to its processing for distribution in accordance with the Personal Data Law.
2.10. User means any visitor to https://web-gruzdeva.ru/.
2.11. Provision of personal data means actions intended to disclose it to a specific person or group of people.
2.12. Distribution of personal data means actions intended to disclose it to an indefinite number of people or make it accessible to an unlimited number of people, including publication in the media, placement on information and telecommunications networks or any other means of access.
2.13. Cross-border transfer means transferring personal data to a foreign state, its authorities, a foreign individual or a foreign legal entity.
2.14. Destruction means actions that irreversibly destroy personal data so that its content cannot be restored in a personal data information system, and/or destroy the physical media containing it.
3. Principal rights and obligations of the Operator
3.1. The Operator may:
— obtain accurate information and/or documents containing personal data from the data subject;
— continue processing without consent, on the grounds specified in the Personal Data Law, if the data subject withdraws consent or requests that processing cease;
— independently determine the measures necessary and sufficient to fulfil the obligations under the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by that Law or other federal laws.
3.2. The Operator must:
— provide a data subject, on request, with information about the processing of their personal data;
— organise processing in accordance with applicable Russian legislation;
— respond to enquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law;
— provide the authorised personal data protection authority with requested information within 10 days of receiving its request;
— publish this Policy or otherwise provide unrestricted access to it;
— take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, amendment, blocking, copying, provision, distribution and other unlawful actions;
— cease transfer (distribution, provision or access), cease processing and destroy personal data in the cases and manner prescribed by the Personal Data Law;
— fulfil other obligations prescribed by the Personal Data Law.
4. Principal rights and obligations of data subjects
4.1. Data subjects may:
— obtain information about the processing of their personal data, except in cases provided for by federal law. The Operator provides this information in an accessible form. It must not contain personal data relating to other data subjects unless lawful grounds permit disclosure. The Personal Data Law defines the information to be provided and the procedure for providing it;
— require the Operator to clarify, block or destroy personal data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose, and take other legally available measures to protect their rights;
— require prior consent for processing personal data to promote goods, works or services;
— withdraw consent to processing and request that processing cease;
— challenge the Operator's unlawful actions or omissions before the authorised personal data protection authority or a court;
— exercise other rights under Russian legislation.
4.2. Data subjects must:
— provide the Operator with accurate information about themselves;
— inform the Operator of updates or changes to their personal data.
4.3. Persons providing false information about themselves or another data subject's information without that person's consent are liable under Russian legislation.
5. Principles of personal data processing
5.1. Personal data is processed lawfully and fairly.
5.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes of collection is prohibited.
5.3. Databases containing personal data processed for incompatible purposes must not be combined.
5.4. Only personal data relevant to the processing purposes may be processed.
5.5. The content and volume of personal data must correspond to the stated processing purposes. Excessive data processing is prohibited.
5.6. Personal data must be accurate, sufficient and, where necessary, up to date for the processing purposes. The Operator takes or ensures the necessary steps to delete or clarify incomplete or inaccurate data.
5.7. Personal data is retained in an identifiable form for no longer than necessary for its processing purposes, unless a federal law or a contract to which the data subject is a party, beneficiary or guarantor specifies a retention period. It is destroyed or depersonalised when the purposes are achieved or no longer necessary, unless federal law provides otherwise.
6. Purposes of personal data processing
Purpose: informing the User by email.
Personal data:
— surname, first name and patronymic;
— telephone numbers.
Legal basis:
— Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”.
Types of processing:
— transfer of personal data.
7. Conditions of personal data processing
7.1. Processing is carried out with the data subject's consent.
7.2. Processing is necessary to achieve purposes established by an international treaty of the Russian Federation or by law, or to fulfil the functions, powers and obligations imposed on the Operator by Russian legislation.
7.3. Processing is necessary for the administration of justice or enforcement of a court decision or an act of another authority or official enforceable under Russian enforcement legislation.
7.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, to conclude a contract at the data subject's initiative, or to conclude a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the data subject's rights and freedoms are not infringed.
7.6. Processing concerns personal data made accessible to an unlimited number of people by the data subject or at their request (publicly available personal data).
7.7. Processing concerns personal data subject to publication or mandatory disclosure under federal law.
8. Collection, storage, transfer and other processing procedures
The security of personal data processed by the Operator is ensured through the legal, organisational and technical measures required to comply fully with applicable personal data protection legislation.
8.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorised access.
8.2. The User's personal data will not be transferred to third parties except where required by applicable law or where the data subject has consented to transfer to a third party for performance of obligations under a civil-law contract.
8.3. If inaccuracies are found, the User may update their personal data by emailing the Operator at abramovavs75@mail.ru with the subject “Personal data update”.
8.4. The processing period is determined by the purposes for which data was collected, unless a contract or applicable legislation provides otherwise.
The User may withdraw consent at any time by emailing abramovavs75@mail.ru with the subject “Withdrawal of consent to personal data processing”.
8.5. Information collected by third-party services, including payment systems, communications services and other providers, is stored and processed by those parties (operators) in accordance with their user agreements and privacy policies. The Operator is not responsible for third-party actions, including those of the service providers referred to in this clause.
8.6. Restrictions imposed by a data subject on transfer (other than granting access), processing or processing conditions (other than obtaining access) of data authorised for distribution do not apply where processing serves state, social or other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. Personal data is retained in an identifiable form for no longer than required by its processing purposes, unless a federal law or a contract to which the data subject is a party, beneficiary or guarantor specifies a retention period.
8.9. Processing may cease when its purposes are achieved, consent expires or is withdrawn, the data subject requests cessation, or unlawful processing is identified.
9. Actions performed by the Operator
9.1. The Operator collects, records, organises, accumulates, stores, clarifies (updates or amends), retrieves, uses, transfers (distributes, provides or grants access to), depersonalises, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing with or without receipt and/or transmission of information over information and telecommunications networks.
10. Cross-border transfer
10.1. Before undertaking cross-border transfer, the Operator must notify the authorised personal data protection authority of the intention to do so. This notification is separate from the notification of the intention to process personal data.
10.2. Before submitting that notification, the Operator must obtain the relevant information from the foreign authorities, individuals or legal entities to which the data is to be transferred.
11. Confidentiality
The Operator and other persons who obtain access to personal data must not disclose it to third parties or distribute it without the data subject's consent, unless federal law provides otherwise.
12. Final provisions
12.1. The User may request clarification about the processing of their personal data by emailing the Operator at abramovavs75@mail.ru.
12.2. Changes to the Operator's personal data processing policy will be reflected in this document. The Policy remains valid indefinitely until replaced by a new version.
12.3. The current version of this Policy is publicly available at https://web-gruzdeva.ru/en/privacy.
This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the Personal Data Law). It sets out the procedures for processing personal data and the measures taken to protect it by Valeria Sergeevna Gruzdeva (the Operator).
1.1. Respect for human and civil rights and freedoms when processing personal data, including the rights to privacy and personal and family confidentiality, is a key objective and condition of the Operator's activities.
1.2. This Policy applies to all information the Operator may obtain about visitors to https://web-gruzdeva.ru/.
2. Definitions used in this Policy
2.1. Automated processing of personal data means processing personal data using computer technology.
2.2. Blocking personal data means temporarily suspending its processing, except where processing is necessary to clarify the data.
2.3. Website means the collection of graphic and information materials, software and databases made available online at https://web-gruzdeva.ru/.
2.4. Personal data information system means the personal data contained in databases together with the information technologies and technical resources used to process it.
2.5. Depersonalisation means actions that make it impossible to determine, without additional information, which User or other data subject particular personal data relates to.
2.6. Processing personal data means any action or set of actions performed on personal data, with or without automated means, including collection, recording, organisation, accumulation, storage, clarification (updating or amendment), retrieval, use, transfer (distribution, provision or access), depersonalisation, blocking, deletion and destruction.
2.7. Operator means a public authority, municipal authority, legal entity or individual that, alone or jointly with others, organises and/or processes personal data and determines the purposes of processing, the data to be processed and the actions performed on it.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://web-gruzdeva.ru/.
2.9. Personal data authorised for distribution means personal data to which a data subject has granted access to an unlimited number of people by consenting to its processing for distribution in accordance with the Personal Data Law.
2.10. User means any visitor to https://web-gruzdeva.ru/.
2.11. Provision of personal data means actions intended to disclose it to a specific person or group of people.
2.12. Distribution of personal data means actions intended to disclose it to an indefinite number of people or make it accessible to an unlimited number of people, including publication in the media, placement on information and telecommunications networks or any other means of access.
2.13. Cross-border transfer means transferring personal data to a foreign state, its authorities, a foreign individual or a foreign legal entity.
2.14. Destruction means actions that irreversibly destroy personal data so that its content cannot be restored in a personal data information system, and/or destroy the physical media containing it.
3. Principal rights and obligations of the Operator
3.1. The Operator may:
— obtain accurate information and/or documents containing personal data from the data subject;
— continue processing without consent, on the grounds specified in the Personal Data Law, if the data subject withdraws consent or requests that processing cease;
— independently determine the measures necessary and sufficient to fulfil the obligations under the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by that Law or other federal laws.
3.2. The Operator must:
— provide a data subject, on request, with information about the processing of their personal data;
— organise processing in accordance with applicable Russian legislation;
— respond to enquiries and requests from data subjects and their legal representatives in accordance with the Personal Data Law;
— provide the authorised personal data protection authority with requested information within 10 days of receiving its request;
— publish this Policy or otherwise provide unrestricted access to it;
— take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, amendment, blocking, copying, provision, distribution and other unlawful actions;
— cease transfer (distribution, provision or access), cease processing and destroy personal data in the cases and manner prescribed by the Personal Data Law;
— fulfil other obligations prescribed by the Personal Data Law.
4. Principal rights and obligations of data subjects
4.1. Data subjects may:
— obtain information about the processing of their personal data, except in cases provided for by federal law. The Operator provides this information in an accessible form. It must not contain personal data relating to other data subjects unless lawful grounds permit disclosure. The Personal Data Law defines the information to be provided and the procedure for providing it;
— require the Operator to clarify, block or destroy personal data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose, and take other legally available measures to protect their rights;
— require prior consent for processing personal data to promote goods, works or services;
— withdraw consent to processing and request that processing cease;
— challenge the Operator's unlawful actions or omissions before the authorised personal data protection authority or a court;
— exercise other rights under Russian legislation.
4.2. Data subjects must:
— provide the Operator with accurate information about themselves;
— inform the Operator of updates or changes to their personal data.
4.3. Persons providing false information about themselves or another data subject's information without that person's consent are liable under Russian legislation.
5. Principles of personal data processing
5.1. Personal data is processed lawfully and fairly.
5.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes of collection is prohibited.
5.3. Databases containing personal data processed for incompatible purposes must not be combined.
5.4. Only personal data relevant to the processing purposes may be processed.
5.5. The content and volume of personal data must correspond to the stated processing purposes. Excessive data processing is prohibited.
5.6. Personal data must be accurate, sufficient and, where necessary, up to date for the processing purposes. The Operator takes or ensures the necessary steps to delete or clarify incomplete or inaccurate data.
5.7. Personal data is retained in an identifiable form for no longer than necessary for its processing purposes, unless a federal law or a contract to which the data subject is a party, beneficiary or guarantor specifies a retention period. It is destroyed or depersonalised when the purposes are achieved or no longer necessary, unless federal law provides otherwise.
6. Purposes of personal data processing
Purpose: informing the User by email.
Personal data:
— surname, first name and patronymic;
— telephone numbers.
Legal basis:
— Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”.
Types of processing:
— transfer of personal data.
7. Conditions of personal data processing
7.1. Processing is carried out with the data subject's consent.
7.2. Processing is necessary to achieve purposes established by an international treaty of the Russian Federation or by law, or to fulfil the functions, powers and obligations imposed on the Operator by Russian legislation.
7.3. Processing is necessary for the administration of justice or enforcement of a court decision or an act of another authority or official enforceable under Russian enforcement legislation.
7.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, to conclude a contract at the data subject's initiative, or to conclude a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the data subject's rights and freedoms are not infringed.
7.6. Processing concerns personal data made accessible to an unlimited number of people by the data subject or at their request (publicly available personal data).
7.7. Processing concerns personal data subject to publication or mandatory disclosure under federal law.
8. Collection, storage, transfer and other processing procedures
The security of personal data processed by the Operator is ensured through the legal, organisational and technical measures required to comply fully with applicable personal data protection legislation.
8.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorised access.
8.2. The User's personal data will not be transferred to third parties except where required by applicable law or where the data subject has consented to transfer to a third party for performance of obligations under a civil-law contract.
8.3. If inaccuracies are found, the User may update their personal data by emailing the Operator at abramovavs75@mail.ru with the subject “Personal data update”.
8.4. The processing period is determined by the purposes for which data was collected, unless a contract or applicable legislation provides otherwise.
The User may withdraw consent at any time by emailing abramovavs75@mail.ru with the subject “Withdrawal of consent to personal data processing”.
8.5. Information collected by third-party services, including payment systems, communications services and other providers, is stored and processed by those parties (operators) in accordance with their user agreements and privacy policies. The Operator is not responsible for third-party actions, including those of the service providers referred to in this clause.
8.6. Restrictions imposed by a data subject on transfer (other than granting access), processing or processing conditions (other than obtaining access) of data authorised for distribution do not apply where processing serves state, social or other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. Personal data is retained in an identifiable form for no longer than required by its processing purposes, unless a federal law or a contract to which the data subject is a party, beneficiary or guarantor specifies a retention period.
8.9. Processing may cease when its purposes are achieved, consent expires or is withdrawn, the data subject requests cessation, or unlawful processing is identified.
9. Actions performed by the Operator
9.1. The Operator collects, records, organises, accumulates, stores, clarifies (updates or amends), retrieves, uses, transfers (distributes, provides or grants access to), depersonalises, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing with or without receipt and/or transmission of information over information and telecommunications networks.
10. Cross-border transfer
10.1. Before undertaking cross-border transfer, the Operator must notify the authorised personal data protection authority of the intention to do so. This notification is separate from the notification of the intention to process personal data.
10.2. Before submitting that notification, the Operator must obtain the relevant information from the foreign authorities, individuals or legal entities to which the data is to be transferred.
11. Confidentiality
The Operator and other persons who obtain access to personal data must not disclose it to third parties or distribute it without the data subject's consent, unless federal law provides otherwise.
12. Final provisions
12.1. The User may request clarification about the processing of their personal data by emailing the Operator at abramovavs75@mail.ru.
12.2. Changes to the Operator's personal data processing policy will be reflected in this document. The Policy remains valid indefinitely until replaced by a new version.
12.3. The current version of this Policy is publicly available at https://web-gruzdeva.ru/en/privacy.
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