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Personal Data Processing Policy
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1. General Provisions
This personal data processing policy (hereinafter – the “Policy”) has been drafted in accordance with Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter – the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure the security of personal data.
1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data, including the right to privacy, personal and family secrecy, as one of its most important goals and conditions for carrying out its activities.
1.2. This Policy applies to all information that the Operator may receive about visitors to the website https://rinashnei.com/.
2. Key Terms 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 the processing of personal data (except when processing is necessary to clarify the personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases, made available on the Internet at https://rinashnei.com/.
2.4. Information system of personal data – a collection of personal data contained in databases and IT systems that provide their processing.
2.5. Depersonalization of personal data – actions that make it impossible to determine the affiliation of personal data to a specific User or other subject without using additional information.
2.6. Processing of personal data – any action (operation) or set of actions performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
2.7. Operator – a state, municipal authority, legal or physical person who organizes and/or performs the processing of personal data and determines the purposes, scope, and means of processing.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://rinashnei.com/.
2.9. Personal data permitted for distribution – personal data made publicly available by the subject by providing consent for processing under the terms outlined by the Personal Data Law.
2.10. User – any visitor of the website https://rinashnei.com/.
2.11. Provision of personal data – actions aimed at disclosure of personal data to a specific person or group.
2.12. Distribution of personal data – any actions aimed at disclosure of personal data to an indefinite number of persons (transmission or public disclosure), including publication in media, posting online, or otherwise providing access.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign country, to a foreign government authority, individual, or legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data so that it cannot be restored, including the destruction of physical media.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
– obtain from the data subject reliable information and/or documents containing personal data;
– continue processing personal data without the subject's consent if permitted by the Personal Data Law;
– independently determine the scope of measures required to fulfill legal obligations.
3.2. The Operator is obliged to:
– provide the data subject with information regarding their data processing;
– organize data processing in accordance with Russian law;
– respond to requests from data subjects and their representatives;
– provide information to the authorized body upon request;
– publish and ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data;
– stop data transmission and destroy personal data when required by law;
– fulfill other obligations stipulated by law.
4. Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to:
– access their personal data and information about processing;
– request correction, blocking, or destruction of inaccurate or illegally obtained data;
– set conditions for processing for marketing purposes;
– withdraw consent to processing;
– file complaints with authorities or courts;
– exercise other rights under Russian law.
4.2. Data subjects must:
– provide accurate personal data;
– notify the Operator of changes to their data.
4.3. Persons providing inaccurate or unauthorized data are liable under Russian law.
5. Personal Data Processed by the Operator
5.1. Full name.
5.2. Email address.
5.3. Phone numbers.
5.4. Anonymized data collected through analytics services (e.g., Yandex Metrica, Google Analytics).
5.5. These are collectively referred to as "Personal Data".
5.6. Special categories of personal data (race, religion, political beliefs, etc.) are not processed.
5.7. Exceptions apply under Art. 10.1 of the Personal Data Law.
5.8. Consent to public processing must be obtained separately and comply with legal requirements.
5.8.1–5.8.4 outline how such consent is provided, published, and revoked.
6. Principles of Data Processing
6.1. Processing must be lawful and fair.
6.2. Processing must pursue specific, legal goals.
6.3. Databases with incompatible purposes may not be merged.
6.4. Only data necessary for processing is handled.
6.5. Excessive data collection is not permitted.
6.6. Accuracy, relevance, and adequacy must be ensured.
6.7. Data must not be stored longer than necessary.
7. Purposes of Data Processing
7.1. Purposes include:
– Sending informational emails;
– Fulfilling contracts;
– Providing access to website services.
7.2. Anonymized data is used to analyze user behavior and improve the website.
8. Legal Grounds for Processing
8.1. Legal grounds include:
– Federal Law No. 149-FZ “On Information”;
– Other laws and regulations;
– User consent.
8.2. Data is processed only if submitted by the User through forms or email.
8.3. Anonymized data is processed if enabled in browser settings.
8.4. The subject provides data voluntarily and freely.
9. Conditions of Processing
9.1. Based on consent.
9.2. To fulfill legal obligations.
9.3. For justice and legal enforcement.
9.4. To execute or initiate a contract.
9.5. To protect legitimate interests, without violating rights.
9.6. Publicly accessible data may be processed.
9.7. Required by law to be disclosed.
10. Collection, Storage, and Transmission of Data
10.1. The Operator ensures data security through legal and technical measures.
10.2. Data is not shared with third parties without consent or legal basis.
10.3. Third-party services (e.g., payment systems) handle their own data and policies.
10.4. Legal limitations on data dissemination do not apply to public interest processing.
10.5. Data is kept confidential.
10.6. Storage is limited to the duration needed for processing.
10.7. Processing may stop upon consent withdrawal or unlawful use detection.
11. Actions Performed by the Operator
11.1. Includes collection, recording, systematization, accumulation, storage, updating, retrieval, use, dissemination, depersonalization, blocking, deletion, and destruction.
11.2. Automated processing may involve telecommunication networks.
12. Cross-Border Data Transfer
12.1. The Operator must ensure the foreign country provides adequate data protection.
12.2. Transfers to countries lacking adequate protection are allowed only with written consent or contract fulfillment.
13. Confidentiality
The Operator and any other person who gains access to personal data must not disclose or distribute it without the subject’s consent, unless required by law.
Let me know if you'd like it formatted as a PDF, DOCX, or in a formal layout.
1. General Provisions
This personal data processing policy (hereinafter – the “Policy”) has been drafted in accordance with Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter – the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure the security of personal data.
1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data, including the right to privacy, personal and family secrecy, as one of its most important goals and conditions for carrying out its activities.
1.2. This Policy applies to all information that the Operator may receive about visitors to the website https://rinashnei.com/.
2. Key Terms 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 the processing of personal data (except when processing is necessary to clarify the personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases, made available on the Internet at https://rinashnei.com/.
2.4. Information system of personal data – a collection of personal data contained in databases and IT systems that provide their processing.
2.5. Depersonalization of personal data – actions that make it impossible to determine the affiliation of personal data to a specific User or other subject without using additional information.
2.6. Processing of personal data – any action (operation) or set of actions performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
2.7. Operator – a state, municipal authority, legal or physical person who organizes and/or performs the processing of personal data and determines the purposes, scope, and means of processing.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://rinashnei.com/.
2.9. Personal data permitted for distribution – personal data made publicly available by the subject by providing consent for processing under the terms outlined by the Personal Data Law.
2.10. User – any visitor of the website https://rinashnei.com/.
2.11. Provision of personal data – actions aimed at disclosure of personal data to a specific person or group.
2.12. Distribution of personal data – any actions aimed at disclosure of personal data to an indefinite number of persons (transmission or public disclosure), including publication in media, posting online, or otherwise providing access.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign country, to a foreign government authority, individual, or legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data so that it cannot be restored, including the destruction of physical media.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
– obtain from the data subject reliable information and/or documents containing personal data;
– continue processing personal data without the subject's consent if permitted by the Personal Data Law;
– independently determine the scope of measures required to fulfill legal obligations.
3.2. The Operator is obliged to:
– provide the data subject with information regarding their data processing;
– organize data processing in accordance with Russian law;
– respond to requests from data subjects and their representatives;
– provide information to the authorized body upon request;
– publish and ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data;
– stop data transmission and destroy personal data when required by law;
– fulfill other obligations stipulated by law.
4. Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to:
– access their personal data and information about processing;
– request correction, blocking, or destruction of inaccurate or illegally obtained data;
– set conditions for processing for marketing purposes;
– withdraw consent to processing;
– file complaints with authorities or courts;
– exercise other rights under Russian law.
4.2. Data subjects must:
– provide accurate personal data;
– notify the Operator of changes to their data.
4.3. Persons providing inaccurate or unauthorized data are liable under Russian law.
5. Personal Data Processed by the Operator
5.1. Full name.
5.2. Email address.
5.3. Phone numbers.
5.4. Anonymized data collected through analytics services (e.g., Yandex Metrica, Google Analytics).
5.5. These are collectively referred to as "Personal Data".
5.6. Special categories of personal data (race, religion, political beliefs, etc.) are not processed.
5.7. Exceptions apply under Art. 10.1 of the Personal Data Law.
5.8. Consent to public processing must be obtained separately and comply with legal requirements.
5.8.1–5.8.4 outline how such consent is provided, published, and revoked.
6. Principles of Data Processing
6.1. Processing must be lawful and fair.
6.2. Processing must pursue specific, legal goals.
6.3. Databases with incompatible purposes may not be merged.
6.4. Only data necessary for processing is handled.
6.5. Excessive data collection is not permitted.
6.6. Accuracy, relevance, and adequacy must be ensured.
6.7. Data must not be stored longer than necessary.
7. Purposes of Data Processing
7.1. Purposes include:
– Sending informational emails;
– Fulfilling contracts;
– Providing access to website services.
7.2. Anonymized data is used to analyze user behavior and improve the website.
8. Legal Grounds for Processing
8.1. Legal grounds include:
– Federal Law No. 149-FZ “On Information”;
– Other laws and regulations;
– User consent.
8.2. Data is processed only if submitted by the User through forms or email.
8.3. Anonymized data is processed if enabled in browser settings.
8.4. The subject provides data voluntarily and freely.
9. Conditions of Processing
9.1. Based on consent.
9.2. To fulfill legal obligations.
9.3. For justice and legal enforcement.
9.4. To execute or initiate a contract.
9.5. To protect legitimate interests, without violating rights.
9.6. Publicly accessible data may be processed.
9.7. Required by law to be disclosed.
10. Collection, Storage, and Transmission of Data
10.1. The Operator ensures data security through legal and technical measures.
10.2. Data is not shared with third parties without consent or legal basis.
10.3. Third-party services (e.g., payment systems) handle their own data and policies.
10.4. Legal limitations on data dissemination do not apply to public interest processing.
10.5. Data is kept confidential.
10.6. Storage is limited to the duration needed for processing.
10.7. Processing may stop upon consent withdrawal or unlawful use detection.
11. Actions Performed by the Operator
11.1. Includes collection, recording, systematization, accumulation, storage, updating, retrieval, use, dissemination, depersonalization, blocking, deletion, and destruction.
11.2. Automated processing may involve telecommunication networks.
12. Cross-Border Data Transfer
12.1. The Operator must ensure the foreign country provides adequate data protection.
12.2. Transfers to countries lacking adequate protection are allowed only with written consent or contract fulfillment.
13. Confidentiality
The Operator and any other person who gains access to personal data must not disclose or distribute it without the subject’s consent, unless required by law.
Let me know if you'd like it formatted as a PDF, DOCX, or in a formal layout.
