Policy Regarding the Processing of Personal Data

1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and the measures taken to ensure the security of personal data by Individual Entrepreneur Elvira Vyacheslavovna Naumenko (hereinafter referred to as the Operator).
1.1.
The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets, to be its most important goal and condition for carrying out its activities.
1.2.
This Operator’s personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://elvalegacy.com/.
2. Basic Terms Used in the Policy
2.1.
Automated processing of personal data means the processing of personal data using computer technology.
2.2.
Blocking of personal data means the temporary suspension of the processing of personal data, except in cases where processing is necessary to clarify personal data.
2.3.
Website means a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://elvalegacy.com/.
2.4.
Personal data information system means a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5.
Depersonalization of personal data means actions as a result of which it is impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another personal data subject.
2.6.
Processing of personal data means any action or operation, or a set of actions or operations, performed with or without the use of automation tools in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, extraction, use, transfer, distribution, provision, access, depersonalization, blocking, deletion, and destruction of personal data.
2.7.
Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions or operations performed with personal data.
2.8.
Personal data means any information directly or indirectly related to an identified or identifiable User of the website https://elvalegacy.com/.
2.9.
Personal data permitted by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by providing consent to the processing of personal data permitted by the personal data subject for distribution in accordance with the procedure provided for by the Personal Data Law, hereinafter referred to as personal data permitted for distribution.
2.10.
User means any visitor to the website https://elvalegacy.com/.
2.11.
Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12.
Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons, transferring personal data, or making personal data available to an unlimited group of persons, including the publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data in any other way.
2.13.
Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14.
Destruction of personal data means any actions as a result of which personal data is permanently destroyed without the possibility of further restoring the content of the personal data in the personal data information system and/or as a result of which physical media containing personal data is destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
· receive accurate information and/or documents containing personal data from the personal data subject;
· if the personal data subject withdraws consent to the processing of personal data or submits a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject where grounds specified in the Personal Data Law exist;
· independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided for 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 concerning 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 request of that body, with the necessary information within 10 days from the date of receipt of such request;
· publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
· take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, or distribution, as well as against other unlawful actions involving personal data;
· stop the transfer, distribution, provision, or access to personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
· perform other obligations provided for by the Personal Data Law.
4. Basic 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 to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
· require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
· require prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;
· withdraw consent to the processing of personal data and submit a request to stop the processing of personal data;
· appeal unlawful actions or inaction of the Operator in the processing of personal data to the authorized body for the protection of the rights of personal data subjects or in court;
· 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;
· notify the Operator of any clarification, update, or change to their personal data.
4.3.
Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1.
Personal data shall be processed on a lawful and fair basis.
5.2.
The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes for which the personal data was collected shall not be permitted.
5.3.
The combination of databases containing personal data processed for purposes that are incompatible with one another shall not be permitted.
5.4.
Only personal data that corresponds to the purposes of its processing shall be processed.
5.5.
The content and volume of the personal data processed shall correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of its processing shall not be permitted.
5.6.
When processing personal data, the accuracy and sufficiency of the personal data and, where necessary, its relevance in relation 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.
Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than is required by the purposes of personal data processing, unless the personal data storage period is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.
The personal data processed shall be destroyed or depersonalized upon achievement of the purposes of processing or if the need to achieve those purposes is lost, unless otherwise provided for by federal law.
6. Purposes of Personal Data Processing
Purpose of Processing
Informing the User by sending a message through the Telegram messenger.
Personal Data
· surname, first name, patronymic;
· email address;
· telephone numbers;
· year, month, date, and place of birth;
· actual residential address and registered address at the place of residence and/or place of stay.
Legal Grounds
Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection.”
Types of Personal Data Processing
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
Informing the User by sending a message through the Telegram messenger.
7. Conditions for Personal Data Processing
7.1.
Personal data shall be processed 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 to exercise 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 authority or official subject to enforcement 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 an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5.
The processing of personal data is necessary for exercising the rights and legitimate interests of the Operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6.
Personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request, hereinafter referred to as publicly available personal data, is processed.
7.7.
Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator shall be ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1.
The Operator shall ensure the security of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.
8.2.
The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil law agreement.
8.3.
If inaccuracies in personal data are identified, the User may update the data independently by sending a notification to the Operator’s email address, elvalos@yandex.ru, marked “Personal Data Update.”
8.4.
The period of personal data processing shall be determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by email to elvalos@yandex.ru marked “Withdrawal of Consent to Personal Data Processing.”
8.5.
All information collected by third-party services, including payment systems, communication services, and other service providers, shall be stored and processed by those persons or Operators in accordance with their User Agreement and Privacy Policy.
The personal data subject and/or [shall familiarize themselves] with the specified documents.
The Operator shall not be responsible for the actions of third parties, including the service providers specified in this clause.
8.6.
Restrictions established by the personal data subject on the transfer, except for granting access, as well as on the processing or conditions of processing, except for obtaining access, of personal data permitted for distribution shall not apply in cases where personal data is processed in state, public, or other public interests defined by the legislation of the Russian Federation.
8.7.
When processing personal data, the Operator shall ensure the confidentiality of personal data.
8.8.
The Operator shall store personal data in a form that allows the personal data subject to be identified for no longer than is required by the purposes of personal data processing, unless the personal data storage period is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9.
A condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the personal data subject’s consent, the withdrawal of consent by the personal data subject, a request to stop the processing of personal data, or the identification of unlawful personal data processing.
9. List of Actions Performed by the Operator With the Personal Data Received
9.1.
The Operator performs the collection, recording, systematization, accumulation, storage, clarification, updating, modification, extraction, use, transfer, distribution, provision, access, depersonalization, blocking, deletion, and destruction of personal data.
9.2.
The Operator performs automated processing of personal data with or without the receipt and/or transfer of the information received through information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1.
Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data.
Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2.
Before submitting the above-mentioned notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data shall not disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1.
The User may receive any clarification regarding matters related to the processing of their personal data by contacting the Operator by email at elvalos@yandex.ru.
12.2.
Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document.
The Policy shall remain in effect indefinitely until it is replaced by a new version.
12.3.
The current version of the Policy is freely available on the Internet at:
https://elvalegacy.com/privacy