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 referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Katya Samana (hereinafter referred to as the Operator).
1.1. The Operator's most important goal and condition for its activities is to respect human and civil rights and freedoms in the processing of personal data, including protecting 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 https://katyasamana.wixsite.com/katya-samana.
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 processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as software and databases, ensuring their availability on the internet at https://katyasamana.wixsite.com/katya-samana.
2.4. Information system of personal data — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine the ownership of personal data by a specific User or another subject of personal data without additional information.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with personal data, with or without the use of automation, 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 or physical entity, independently or jointly with other entities 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 — any information relating directly or indirectly to a specific or identifiable User of the website https://katyasamana.wixsite.com/katya-samana.
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which the subject of personal data has given consent for processing and dissemination in accordance with the procedure provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://katyasamana.wixsite.com/katya-samana.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution 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 indefinite circle of persons, including publication 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 — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of personal data content in the personal data information system and (or) the destruction of physical media of personal data.
3. Main 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 subject of personal data;
continue processing personal data without the consent of the subject of personal data if the subject of personal data withdraws consent for the processing of personal data, as well as in case of a request for termination of the processing of personal data, in cases specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of 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 subject of personal data with information regarding the processing of their personal data upon request;
organize the processing of personal data in accordance with the requirements of the current legislation of the Russian Federation;
respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
notify the authorized body for the protection of the rights of subjects of personal data about necessary information within 10 days from the date of receiving such a 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, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
terminate the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data in the manner and cases provided 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. Subjects of personal data have the right to:
receive information concerning the processing of their personal data, except in cases provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, 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 the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the declared purpose of processing, as well as take measures provided by law to protect their rights;
set the condition of prior consent when processing personal data in order to promote goods, works, and services in the market;
withdraw consent to the processing of personal data, as well as to send a request for the termination of processing of personal data;
complain to the authorized body for the protection of the rights of subjects of personal data or in court about unlawful actions or inaction of the Operator in processing their personal data;
exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
provide the Operator with accurate information about themselves;
inform the Operator about clarifying (updating, changing) their personal data.
4.3. Persons who have provided the Operator with 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. Principles of Personal Data Processing
5.1. The 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, predetermined, and legitimate goals. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, 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 to which the subject of personal data is a party, beneficiary, or guarantor. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of loss of necessity in achieving 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: surname, first name, patronymic, phone numbers
Legal basis: federal laws and regulations adopted on their basis, regulating relations related to the activities of the operator
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals provided by an international treaty of the Russian Federation or by law, for the exercise of functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial 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. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of 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. 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 this does not violate the rights and freedoms of the subject of personal data.
7.6. The processing of personal data is carried out, access to which is granted to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as personal data made publicly available by the subject of personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collecting, Storing, Transferring, 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 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 the execution of current legislation or if 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 personal data, the User can update them independently by sending a notification to the Operator to the Operator's email address marked "Updating personal data."
8.4. The term for processing personal data is determined by achieving the purposes for which personal data was collected unless another term is provided by the contract or current legislation.
The User can withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator's email address marked "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including those specified in this paragraph.
8.6. The prohibitions established by the subject of personal data on the transfer (except for granting access) and processing or conditions of processing (except for obtaining access) of personal data permitted for distribution do not apply in cases of processing personal data in the state, public and other public interests as defined by Russian law.
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 determining the subject of personal data no longer than required by the purposes of processing personal data, unless the period for storing 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 condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or the requirement to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received 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 performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such.
10. Cross-border Transfer of Personal Data
10.1. Before starting the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state, to whose territory the transfer of personal data is supposed to be carried out, provides reliable protection of the rights of subjects of personal data.
10.2. The cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements can be carried out only if there is written consent from the subject of personal data to the cross-border transfer of their personal data and/or the execution of a contract to which the subject of personal data is a party.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained 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 receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email.
12.2. This document will reflect any changes in the personal data processing policy by the Operator. 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://katyasamana.wixsite.com/katya-samana.