Privacy Policy on the Processing of Personal Data
1. General Provisions
This personal data processing policy has been prepared 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 the measures taken to ensure the security of personal data by Pavlenko Zarina Vasilevna (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the right to privacy, personal and family secrecy, as its most important goal and a fundamental condition for carrying out its activities.
1.2. This Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website http://bar-b.tilda.ws/.
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2. Basic 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 personal data processing (except where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address http://bar-b.tilda.ws/.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions as a result of which it becomes impossible, without the use of additional information, to determine whether the personal data belongs to a specific user or another subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, 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 or municipal body, legal or natural person, independently or jointly with other persons, that organizes and/or carries out the processing of personal data, as well as determines 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 an identified or identifiable user of the website http://bar-b.tilda.ws/.
2.9. Personal data permitted by the subject for distribution – personal data to which an unlimited number of persons are granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User – any visitor to the website http://bar-b.tilda.ws/.
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 number of persons (transfer of personal data) or familiarizing 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 – transfer of personal data to the territory of a foreign state, to an authority of a foreign state, to a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or material media containing personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— continue processing personal data without the consent of the personal data subject in cases where the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, provided that 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 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 personal data subject, upon their request, with information relating to 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 inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of 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 unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to personal data;
— cease the transfer (distribution, provision, access), terminate processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations established by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Such information must be provided by the Operator to the personal data subject in an accessible form and must not contain personal data relating to other personal data subjects, unless there are lawful grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— request that the Operator clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take statutory measures to protect their rights;
— require prior consent for the processing of personal data for the purposes of promoting goods, works, and services on the market;
— withdraw their consent to the processing of personal data and/or submit a request to terminate the processing of personal data;
— lodge complaints with the authorized body for the protection of the rights of personal data subjects or file a lawsuit regarding unlawful actions or omissions of the Operator when processing their personal data;
— exercise other rights established by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent bear liability 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 lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. It is not permitted to combine databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data being processed must correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing must be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than is required by the purposes of personal data processing, unless a personal data storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or if there is no further need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of Processing - Informing the User by sending email messages
Personal Data- Full name (surname, first name, patronymic); Email address; Phone numbers
Legal Basis - Federal Law “On Information, Information Technologies and Protection of Information” No. 149-FZ of July 27, 2006
Types of Personal Data Processing - Transfer of personal data
7. Conditions for Personal Data Processing
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the objectives provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official to be executed 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 personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. The processing of personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as public personal data) shall be carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law shall be 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 through the implementation of legal, organizational, and technical measures required to fully comply with the current legislation on personal data protection.
8.1. The Operator ensures the confidentiality and security of personal data and takes all possible measures to prevent unauthorized persons from gaining access to personal data.
8.2. Under no circumstances will the User’s personal data be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given the Operator consent to transfer data to a third party for the purpose of fulfilling obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to the Operator’s email address zarina.pt.pav@gmail.com with the subject line “Update of Personal Data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is established by contract or applicable law.
The User may 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 zarina.pt.pav@gmail.com with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including those service providers mentioned in this paragraph.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access) or processing, as well as conditions for processing (except for obtaining access), of personal data permitted for distribution shall not apply in cases of processing personal data in state, public, or other public interests determined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during their processing.
8.8. The Operator shall store personal data in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The grounds for terminating the processing of personal data may include the achievement of the purposes of personal data processing, the expiration of the consent period of the personal data subject, the withdrawal of consent by the personal data subject, a request to terminate the processing of personal data, or the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Collected Personal Data
9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), 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 such networks.
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10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfers 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 the cross-border transfer of personal data. Such notification shall be submitted separately from the notification of the Operator’s intention to process personal data.
10.2. Prior to submitting the above-mentioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which cross-border transfers of personal data are planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at zarina.pt.pav@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy shall remain in force indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: http://bar-b.tilda.ws/ppd.
