Policy on Personal Data ProcessingGeneral ProvisionsThis policy on personal data processing is drafted in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and outlines the procedures for processing personal data and measures to ensure the security of personal data taken by Natalia Alexandrovna Poletaeva (hereinafter referred to as the Operator) in the course of her activities.
1.1. The Operator sets compliance with the rights and freedoms of individuals as the paramount goal and condition for carrying out her activities when processing their personal data, including the protection of the right 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://pnburo.com.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data: processing personal data using computer technology means.
2.2. Blocking of personal data: the temporary cessation of personal data processing (except in cases where 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://pnburo.com.
2.4. Information system of personal data: a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data: actions that make it impossible to determine the belonging of personal data to a specific User or another subject of personal data without the use of additional information.
2.6. Processing of personal data: any action (operation) or a set of actions (operations) carried out with personal data using automation or without the use of such means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, 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 carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data: any information directly or indirectly related to a specific User of the website
http://pnburo.com.
2.9. Personal data permitted by the subject of personal data for distribution: personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data permitted for distribution in the manner provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User: any visitor to the website
http://pnburo.com.
2.11. Provision of personal data: actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data: any actions aimed at disclosing personal data to an indefinite circle of persons (transmission of personal data) or acquainting an unlimited number of persons with personal data, including the publication of personal data in mass 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 a foreign legal entity.
2.14. Destruction of personal data: any actions that result in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the information system of personal data and/or the destruction of material carriers of personal data.
3. Main 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 data subject;
- in case of withdrawal by the data subject of consent for the processing of personal data, as well as the submission of a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the 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 obligations provided by the Personal Data Law and 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 data subject, upon request, with information regarding the processing of their personal data;
- organize the processing of personal data in accordance with the current legislation of the Russian Federation;
- respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of data subjects upon request of this body within 10 days from the date of receiving such a request;
- publish or otherwise ensure unlimited access to this Policy on the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with respect to personal data;
- cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in accordance with the cases and procedures provided by the Personal Data Law;
- fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
- receive information about the processing of their personal data, except as provided by federal laws. Information is provided to the data subject by the Operator in an accessible form and should not contain personal data related to other data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- demand from the operator the clarification of their personal data, their blocking, or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as take legal measures to protect their rights;
- impose a condition for the prior consent when processing personal data for marketing purposes;
- withdraw consent for the processing of personal data, as well as submit a request to stop the processing of personal data;
- appeal to the authorized body for the protection of the rights of data subjects or in a judicial procedure against the unlawful actions or inaction of the Operator in the processing of their personal data;
- exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
- provide the Operator with accurate information about themselves;
- inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with false information about themselves or information about another data subject without the latter's consent bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predefined, and legal purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The combination of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that corresponds to the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the data subject for no longer than required by the purposes of processing personal data, unless the storage period is established by federal law, a contract, the party to which, the beneficiary or guarantor of which is the data subject. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Processing Purpose: Informing the User by sending emails
Personal Data: Last name, first name, patronymic
Email address
Phone numbers
Legal Basis: Federal Law "On Information, Information Technologies, and Information Protection" dated July 27, 2006 No. 149-FZ
Types of Personal Data Processing: Sending informational emails to the email address
7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or the law, for the implementation of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a court act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract, where the data subject is a party, beneficiary, or guarantor of the contract, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to protect 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 data subject are not violated.
7.6. Processing of personal data is carried out for personal data that is publicly available to an unlimited circle of persons, either at the request of the data subject (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
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 in the field of personal data protection.
8.1. The Operator ensures the integrity of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address nato.workshop@gmail.com with the subject "Update of Personal Data."
8.4. The processing period of personal data is determined by achieving the goals for which personal data were collected, unless another period is provided by the contract or current legislation. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address nato.workshop@gmail.com with the subject "Revocation of Consent to the Processing of Personal Data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions on the transfer (except for providing access), as well as on the processing or conditions for processing (except for gaining access) of personal data established by the data subject, do not apply in cases of processing personal data in the public, social, and other public interests 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 allows identifying the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, a party to which is the subject of personal data, the beneficiary, or guarantor.
8.9. The termination of the processing of personal data may be due to the achievement of the purposes of processing personal data, the expiration of the validity period of the consent of the data subject to the processing of personal data, the revocation of the consent of the data subject to the processing of personal data, or the demand to stop processing personal data, as well as the identification of illegal processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without them.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border data transfer (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, foreign legal entities, to which the cross-border transfer of personal data is planned, relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at nato.workshop@gmail.com.
12.2. Any changes to the policy of personal data processing by the Operator will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at
http://pnburo.com/privacy/en.