PERSONAL DATA PROCESSING POLICY
1. General Provisions
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" and defines the procedure for processing personal data and the measures taken by the Individual Entrepreneur Golubeva Marusya Vyacheslavovna (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's Policy 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://marusyagolubevaretoucher.com.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of the processing of personal data (except when processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address
http://marusyagolubevaretoucher.com.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility of determining the identity of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data
2.7. Operator – a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the website
http://marusyagolubevaretoucher.com.
2.9. Personal data permitted by the personal data subject for dissemination – personal data to which an unlimited number of persons may have access, granted by the personal data subject through the provision of consent for the processing of personal data permitted by the personal data subject for dissemination, in the manner prescribed by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User – any visitor to the website
http://marusyagolubevaretoucher.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including the publication of personal data in the media, posting in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign authority, foreign natural or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irrevocable destruction of personal data with the impossibility of further recovery of the content of personal data in the personal data information system and (or) destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— eceive from the personal data subject accurate information and/or documents containing personal data;
— in the event of the withdrawal by the personal data subject of their consent to the processing of personal data, as well as in the event of a request to cease the processing of personal data, the Operator has the right to continue processing the personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, 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 their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— 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, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations stipulated 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 concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided by the Operator to the personal data subject in an accessible form and must not contain personal data relating to other personal data subjects, unless there are legal grounds for the disclosure of such personal data. The list of such information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the Operator clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing, as well as to take measures provided for by law to protect their rights;
— make it a condition to obtain prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as to submit a request to cease the processing of personal data;
— оappeal to the authorized body for the protection of the rights of personal data subjects or to the court against unlawful actions or omissions of the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator about clarifying (updating, modifying) their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent shall bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data must correspond to the declared purposes of processing. The processed personal data must not be excessive in relation to the declared purposes of their processing.
5.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data shall be carried out in a form that allows identification of the personal data subject for no longer than is required for the purposes of personal data processing, unless a different storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in case of loss of the necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
The purpose of processing is to provide the User with access to the services, information, and/or materials contained on the website
Personal data:
Last name, first name, patronymic
Email address
Phone numbers
Photographs
Legal basis:
Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and Information Protection”
Types of personal data processing:
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and for the performance of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, a beneficiary, or a guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data, access to which is granted by the personal data subject to an unlimited number of persons or at the subject’s request (hereinafter referred to as publicly available personal data), is processed.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protectio.
8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of legal requirements or if the personal data subject has given consent to the Operator to transfer the data to a third party for the purpose of fulfilling obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address at ms.golubevama@gmail.com with the subject line “Updating personal data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by contract or applicable law.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at ms.golubevama@gmail.com with the subject line “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for familiarizing themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6.Restrictions established by the personal data subject regarding transfer (except for access provision), as well as processing or conditions of processing (except for access provision) of personal data permitted for dissemination, shall not apply in cases of processing personal data in the interests of the state, society, or other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than is necessary for the purposes of personal data processing, unless a longer storage period is established by federal law or by a contract to which the personal data subject is a party, a beneficiary, or a guarantor.
8.9. Grounds for termination of personal data processing may include the achievement of the purposes of processing, expiration of the consent validity period, withdrawal of consent by the personal data subject, a request to cease processing, or the discovery of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Collected Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, either with the receipt and/or transmission of the processed data via information and telecommunication networks, or without such receipt and/or transmission.
10. Cross-Border Transfer of Personal Data
10.1. Prior to initiating any cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the foreign government bodies, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law..
12. Final Provisions
12.1. The User may receive any clarification regarding the processing of their personal data by contacting the Operator via email at ms.golubevama@gmail.com.
12.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at
https://marusyagolubevaretoucher.com/#rec879000304.