Policy regarding the processing of personal data
1. General provisions
This personal data processing policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Ivan Ivanovich Ivanov (hereinafter referred to as the Operator).1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of 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 https://en.zelenskyroman.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 suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and information materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://en.zelenskyroman.com.
2.4. Personal data information system — 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 as a result of which it becomes impossible to determine the ownership 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 using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), 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 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 to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://en.zelenskyroman.com.
2.9. Personal data authorized for distribution by the subject of personal data — personal data, access to which is granted to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data authorized for distribution).
2.10. User — any visitor to the website https://en.zelenskyroman.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific 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 making personal data known to an unlimited circle of persons, including publication of personal data in the 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 — transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right:— to receive from the subject of personal data reliable information and/or documents containing personal data;
— in the event the subject of personal data withdraws consent to the processing of personal data, or sends an appeal demanding cessation of personal data processing, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for 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 subject of personal data, 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 appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— inform the authorized body for the protection of the rights of personal data subjects, upon request of this body, of 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 unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, 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 in the cases provided for by the Personal Data Law;
— fulfill other duties provided for by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Subjects of personal data have the right:— to receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, unless 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;
— to demand from the Operator clarification of their personal data, blocking, or destruction of it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— to require prior consent when processing personal data for the purpose of marketing goods, works, and services;
— to withdraw consent to the processing of personal data, as well as to send a demand to cease processing of personal data;
— to 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 in the processing of their 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 accurate data about themselves;
— inform the Operator of any clarification (updating, change) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another subject of personal data 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. Processing of personal data is carried out on a legal and fair basis.5.2. Processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Merging databases containing personal data processed for purposes incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Processed personal data must not be excessive in relation to the stated purposes of their processing.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their removal to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out 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 for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of personal data processing
| Purpose of processing | informing the User by sending emails |
|---|---|
| Personal data |
|
| Legal grounds |
|
| Types of personal data processing |
|
7. Conditions for processing personal data
7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, 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 to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. 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 subject of personal data are not violated.
7.6. Processing of personal data is carried out, access to which is granted to an unlimited circle of persons by the subject of personal data or at their request (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 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 current legislation in the field of personal data protection.8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or in the event that the subject of personal data has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In case of inaccuracies in the personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address zelenskyr@gmail.com marked "Personal Data Update".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the contract or current legislation.
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 the Operator's email address zelenskyr@gmail.com marked "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases of personal data processing in state, public, and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing them.
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 for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The conditions for termination of personal data processing may be the achievement of the purposes of processing personal data, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a demand to cease processing of personal data, as well as detection of unlawful processing of personal data.
9. List of actions performed by the Operator with received personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before commencing activities related to the 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 cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from foreign government authorities, 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 are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.12. Final provisions
12.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at zelenskyr@gmail.com.12.2. This document will reflect any changes to the Operator's personal data processing policy. 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 https://en.zelenskyroman.com/privacy.