Personal Data Processing Policy
1. General provisions
This personal data processing policy is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Natalya Sergeevna Zhelonkina (hereinafter - the Operator).
1.1. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's Personal Data Processing Policy (the "Policy") applies to all information that the Operator may obtain about visitors to the website https://nataliajelonkina.ru.
2. Key concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer equipment.
2.2. Blocking of personal data - temporary termination of processing of personal data (unless processing is necessary to clarify personal data).
2.3. Website - a set of graphic and information materials, as well as programs for computers and databases that ensure their availability on the Internet at a network address https://nataliajelonkina.ru
2.4. Personal data information system - a set of personal data contained in databases and providing their processing of information technologies and technical means.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without using additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed using automation means or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity or individual, independently or together with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal Data means any information relating directly or indirectly to a particular or defined Website User https://nataliajelonkina.ru.
2.9. Personal data authorized by the subject of personal data for distribution - personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in accordance with the procedure provided for by the Law on Personal Data (hereinafter - personal data allowed for distribution).
2.10. User - any visitor to the website https://nataliajelonkina.ru.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Distribution of personal data - any actions aimed at the disclosure of personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with personal data of an unlimited range of persons, including the publication of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoration of personal data content in the personal data information system and (or) destruction of material media of personal data.
3. Basic rights and obligations of the Operator
3.1. The operator has the right to:
- receive reliable information and/or documents containing personal data from the personal data subject;
- if the personal data subject revokes consent to the processing of personal data, the Operator shall be entitled to continue processing 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 provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator shall:
- provide the personal data subject with information concerning the processing of his personal data at his request;
- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request;
- publish or otherwise ensure unlimited access to this Personal Data Processing Policy;
- take legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- perform other duties stipulated by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- receive information concerning the processing of his personal data, except for cases provided for by federal laws. 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, unless there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- require the operator to clarify his personal data, block them or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
- withdrawal of consent for processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing its personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
- provide the Operator with reliable data about itself;
- inform the Operator about the clarification (update, change) of its personal data.
4.3. Persons who have transmitted to the Operator false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
5. The operator can process the following personal user information
5.1. Surname, name, middle name.
5.2. E-mail address.
5.3. Phone numbers.
5.4. Also on the website there is a collecting and processing of the depersonalized data on visitors (including the cookie files) by means of services of Internet statistics (Yandex the Metrics and Google of the Analyst and others).
5.5. Above-mentioned data in the text of Policy are united further by the general concept Personal data.
5.6. Processing of special categories of the personal data concerning racial, national identity, political views, religious or philosophical beliefs, intimate life by the Operator isn't carried out.
5.7. Processing of the personal data allowed for distribution from among special categories of the personal data specified in Part 1 of Article 10 of the Law on personal data is allowed if the bans and conditions provided by Article 10.1 of the Law on personal data are observed.
5.8. The consent of the User to processing of the personal data allowed for distribution is made out separately from other soglasiya on processing of his personal data. At the same time the conditions provided, in particular, by Article 10.1 of the Law on personal data are met. Requirements to the content of such consent are established by authorized body on protection of the rights of subjects of personal data.
5.8.1 The User provides consent to processing of the personal data allowed for distribution to the Operator directly.
5.8.2 The operator is obliged no later than three working days in time from the moment of receiving the specified consent of the User to publish information on processing conditions, on existence of the bans and conditions on processing by an unlimited circle of people of the personal data allowed for distribution.
5.8.3 Transfer (distribution, granting, access) of the personal data allowed by the subject of personal data for distribution has to be stopped upon the demand of the subject of personal data at any time. This requirement has to include a surname, a name, a middle name (in the presence), contact information (phone number, the e-mail address or the postal address) of the subject of personal data and also the list of personal data which processing is subject to the termination. The personal data specified in this requirement can be processed only by the Operator to whom it is sent.
5.8.4 Consent to processing of the personal data allowed for distribution stops the action from the moment of receipt to the Operator of the requirement specified in item 5.8.3 of the real Policy for processing of personal data.
6. Principles of processing of personal data
6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to achievement of concrete, in advance definite and lawful purposes. The processing of personal data incompatible with the purposes of collecting personal data isn't allowed.
6.3. Combination of the databases containing personal data which processing is carried out for, incompatible among themselves isn't allowed.
6.4. Only personal data which answer the purposes of their processing are subject to processing.
6.5. Content and volume of the processed personal data answer stated purposes of processing. The redundancy of the processed personal data in relation to stated purposes of their processing isn't allowed.
6.6. When processing personal data the accuracy of personal data, their sufficiency, and in necessary cases and relevance in relation to the purposes of processing of personal data is provided. The operator takes necessary measures and/or provides their acceptance on removal or specification of incomplete or inexact data.
6.7. Storage of personal data is carried out in the form allowing to define the subject of personal data, not longer than it is demanded by the purposes of processing of personal data if the period of storage of personal data isn't established by the federal law, the contract, which party, the beneficiary or the guarantor on whom the subject of personal data is. The processed personal data are destroyed or depersonalized on reaching the purposes of processing or in case of loss of need for achievement of these purposes if other isn't provided by the federal law.
7. Purposes of processing of personal data
7.1. Purpose of processing of personal user information:
– informing the User by means of sending e-mails;
– providing access to the User to services, information and/or materials which are contained on the https://nataliajelonkina.ru website.
7.2. Also the Operator has the right to send to the User of the notice of new products and services, special offers and various events. The user can always refuse obtaining information messages, having sent the Operator a letter on firstname.lastname@example.org e-mail address with a mark "Refusal of notices of new products and services and special offers".
8. Legal grounds of processing of personal data
8.1. Legal grounds of processing of personal data by the Operator are:
– the contracts signed between the operator and the subject of personal data;
– federal laws, other normative legal acts in the sphere of protection of personal data;
– the consent of Users to processing of their personal data, to processing of the personal data allowed for distribution.
8.2. The operator processes personal user information only in case of their filling and/or sending by the User independently through the special forms located on the website https://nataliajelonkina.ru or sent to the Operator by e-mail. Filling the corresponding forms and/or sending the personal data to the Operator, the User expresses the consent with this Policy.
8.4. The subject of personal data independently makes the decision on providing his personal data and agrees freely, the will and in the interest.
9. Conditions of processing of personal data
9.1. Processing of personal data is carried out with the consent of the subject of personal data on processing of his personal data.
9.2. Processing of personal data is necessary for achievement of the goals provided by the international treaty of the Russian Federation or the law, for implementation assigned by the legislation of the Russian Federation to the operator of functions, powers and duties.
9.3. Processing of personal data is necessary for the implementation of justice, execution of the court ruling, the act of other body or the official who are subject to execution according to the legislation of the Russian Federation on enforcement proceeding.
9.4. Processing of personal data is necessary for performance of the contract which party either the beneficiary or the guarantor on whom the subject of personal data and also for signing of the contract at the initiative of the subject of personal data or the contract under which the subject of personal data will be a beneficiary or the guarantor is.
9.5. Processing of personal data is necessary for implementation of the rights and legitimate interests of the operator or the third parties or for achievement of the socially significant purposes provided that at the same time the rights and freedoms of the subject of personal data aren't violated.
9.6. Processing of personal data, access of an unlimited circle of people to which is provided by the subject of personal data or at his request (further – public personal data), is carried out.
9.7. Processing of the personal data which are subject to publication or obligatory disclosure according to the federal law is carried out.
10. Order of collecting, storage, transfer and other types of processing of personal data
Safety of personal data which are processed by the Operator is provided by realization of the legal, organizational and technical measures necessary for implementation in full of requirements of the current legislation in the field of protection of personal data.
10.1. The operator ensures safety of personal data and takes all possible measures excluding access to personal data of unauthorized persons.
10.2. Personal user information never, under no circumstances will be transferred to the third parties, except for the cases connected with performance of the current legislation or in case by the subject of personal data it is agreed to the Operator to data transmission to the third party for performance of obligations under the civil contract.
10.3. In case of identification of inaccuracies in personal data, the User can update them independently, by the direction to the Operator the notice on the e-mail address of email@example.com Operator with a mark "Updating of personal data".
10.4. The term of processing of personal data is defined by achievement of the goals for which personal data were collected if other term isn't provided by the contract or the current legislation.
The user can withdraw at any time the consent to processing of personal data, having directed to the Operator the notice by e-mail to the e-mail address of firstname.lastname@example.org Operator with a mark "A response of consent to processing of personal data".
10.6. The prohibitions established by the subject of personal data on the transfer (except for the provision of access), as well as on the processing or conditions for the processing (except for access) of personal data allowed for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
10.7. When processing personal data, the operator ensures the confidentiality of personal data.
10.8. The Operator shall store personal data in a form that allows to determine the subject of personal data no longer than the purpose of personal data processing requires, unless the term of personal data storage is established by federal law, an agreement to which the beneficiary or guarantor is the subject of personal data.
10.9. The condition for termination of personal data processing may be achievement of personal data processing goals, expiration of the personal data subject's consent or withdrawal of the personal data subject's consent, as well as detection of illegal processing of personal data.
11. List of actions performed by the Operator with the received personal data
11.1. The Operator shall collect, record, organize, accumulate, store, update (update, modify), extract, use, transfer (distribute, provide, access), depersonalize, block, delete and destroy personal data.
11.2. The Operator performs automated processing of personal data with receipt and/or transmission of received information via information and telecommunication networks or without it.
12. Cross-border transfer of personal data
12.1. Before the start of the cross-border transfer of personal data, the operator is obliged to make sure that a foreign state to the territory of which personal data is supposed to be transferred ensures reliable protection of the rights of personal data subjects.
12.2. The cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if the personal data subject agrees in writing to the cross-border transfer of his personal data and/or the execution of the contract to which the personal data subject is a party.
13. Privacy of Personal Data
The operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final provisions
14.1. The User may obtain any clarification on the questions of interest concerning the processing of his personal data by contacting the Operator by e-mail email@example.com.
14.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until replaced with a new version.
14.3. The current version of the Free Access Policy is located on the Internet at https://nataliajelonkina.ru/privacypolicy.