1. General Provisions

This personal data processing policy is compiled 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 determines the procedure for processing personal data and measures to ensure the security of personal data, undertaken by Anastasia Uglyantseva (hereinafter referred to as the “Operator”).

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data as its most important goal and condition for performing its activities, including protecting the rights to privacy, personal and family secrets.

1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the website https://anastasianebotova.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 cessation of processing 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 computer programs and databases, ensuring their availability on the Internet at the network address https://anastasianebotova.com.

2.4. Information system of personal data — a set of personal data contained in databases, and ensuring their processing by information technologies and technical means.

2.5. Anonymization of personal data — actions resulting in the inability to determine, without the use of additional information, the ownership of personal data to a specific User or another subject of personal data.

2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collecting, recording, systematizing, accumulating, storing, clarifying (updating, changing), extracting, using, transferring (distributing, providing, accessing), anonymizing, blocking, deleting, and destroying personal data.

2.7. Operator — a state body, municipal body, legal or natural person who independently or jointly with others 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, 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://anastasianebotova.com.

2.9. Personal data allowed by the subject for dissemination — personal data to which access is granted to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data allowed by the subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as “personal data allowed for dissemination”).

2.10. User — any visitor to the website https://anastasianebotova.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 (transferring personal data) or at making personal data available to an unlimited circle of persons, including public disclosure of personal data in the media, posting 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 the authority of a foreign state, a foreign natural or foreign legal person.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of the 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 subject of personal data;

— in case of revocation by the subject of personal data of consent to the processing of personal data, as well as in case of sending a request to stop processing personal data, 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;

— 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 regulatory legal acts 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 regarding the processing of their personal data;

— organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;

— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;

— report to the authorized body for the protection of the rights of subjects of personal data, upon the request of this body, the necessary information within 10 days from the date of receipt of such a request;

— publish or otherwise provide 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, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;

— stop transferring (disseminating, providing, accessing) personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;

— fulfill other obligations provided for 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. 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, 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 that the operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and take measures provided by law to protect their rights;

— set the condition of prior consent when processing personal data for promoting goods, works, and services on the market;

— revoke consent to the processing of personal data, as well as send a request to stop processing personal data;

— 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;

— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

— provide the Operator with reliable data about themselves;

— inform the Operator about clarifying (updating, changing) their personal data.

4.3. Persons who transferred unreliable information about themselves to the Operator 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 lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. It is not allowed to process personal data incompatible with the purposes of collecting personal data.

5.3. The combination of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meet the purposes of their processing are 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. The accuracy of personal data, their sufficiency, and, if necessary, relevance concerning the purposes of processing personal data are ensured during the processing of personal data. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

5.7. Personal data storage is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, a contract, a party to which, the beneficiary or guarantor of which is the subject of personal data. Processed personal data are destroyed or anonymized upon achieving the purposes of processing or in case of loss of the necessity to achieve these purposes unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

6.1. The purpose of processing the User’s personal data:

6.1.1. Informing the User by sending emails;

6.1.2. Providing services to clients;

6.1.3. Providing the User with access to services, information, and/or materials contained on the website.

6.1.4. Establishing feedback.

6.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the Operator’s email address.

6.3. Anonymized data of Users collected using internet statistics services are used to collect information about Users’ actions on the site, improve the site’s quality, and its content.

7. The Operator may process the following personal data

7.1. Last name, first name, middle name.

7.2. Email address.

7.3. Phone numbers.

7.4. The website also collects and processes anonymized data about visitors using internet statistics services.

8. Conditions for processing personal data

8.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

8.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and responsibilities assigned by the legislation of the Russian Federation to the Operator.

8.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official, to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

8.4. Processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.

8.5. 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 goals, provided that the rights and freedoms of the subject of personal data are not violated.

8.6. Processing of personal data is carried out, access to which an unlimited number of persons is provided by the subject of personal data or at their request (hereinafter – publicly available personal data).

8.7. Processing of personal data is carried out, which are subject to publication or mandatory disclosure in accordance with federal law.

8.8. The Operator processes the User’s personal data in case they are filled in and/or sent by the User independently through special forms located on the website or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User agrees to this Policy.

8.9. The Operator processes anonymized data about the User if it is allowed in the User’s browser settings.

8.10. The subject of personal data independently decides on the provision of their personal data and gives consent freely, by their will, and in their interest.

9. Procedure for collecting, storing, transferring, and other types of processing of personal data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

9.1. The Operator ensures the security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

9.2. 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 the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil law contract.

9.3. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator’s email address contact@anastasianebotova.com marked “Personal data update.”

9.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected unless otherwise provided by the contract or current legislation.

The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to the Operator’s email address contact@anastasianebotova.com marked “Withdrawal of consent to the processing of personal data.”

9.5. All information collected by third-party services, including payment systems, communication tools, 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 the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

9.6. The restrictions 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 permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.

9.7. The Operator ensures the confidentiality of personal data during its processing.

9.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data unless a different period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.

9.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the subject of personal data’s consent, the withdrawal of consent by the subject of personal data, or the requirement to stop processing personal data, as well as the identification of unlawful processing of personal data.

10. List of actions performed by the Operator with the received personal data

10.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.

10.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such networks.

11. Cross-border transfer of personal data

11.1. Before starting cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of their intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).

11.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.

12. 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 distribute personal data without the consent of the subject of personal data unless otherwise provided by federal law.

13. Final provisions

13.1. The User can receive any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at contact@anastasianebotova.com.

13.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

13.3. The current version of the Policy is freely available on the Internet at https://anastasianebotova.com/privacy-policy.

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