Personal Data Processing Policy

1. General Provisions

This personal data processing policy is developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure for processing personal data and measures for ensuring the security of personal data taken by Grigoryan Zhan Ovikoivich (hereinafter - the operator).

1.1

The operator's primary goal and condition for carrying out their activities is the observance of human and citizen rights and freedoms when processing personal data, including the protection of the right to privacy and family secrets.

1.2

This policy of the operator regarding personal data processing (hereinafter - the policy) applies to all information that the operator may receive about visitors to the website https://hxnnxs.ru

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 cessation of processing personal data (except in cases where processing is necessary to clarify personal data).

2.3

Website — a collection of graphic and informational materials, as well as software and databases that provide access to them on the internet via the network address https://hxnnxs.ru

2.4

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

2.5

Anonymization of personal data — actions that make it impossible to identify personal data without using additional information.

2.6

Processing of personal data — any action (operation) or a set of actions (operations) performed with personal data using automated means or without such means, including collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7

Operator — a government authority, municipal authority, legal entity, or individual, independently or together with others, organizing and/or performing the processing of personal data, and determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8

Personal data — any information related directly or indirectly to a specific or identifiable user of the website https://hxnnxs.ru

2.9

Personal data authorized by the data subject for distribution — personal data for which access to an unlimited circle of individuals is granted by the data subject by giving consent to the processing of personal data authorized by the data subject for distribution as provided for in the Personal Data Law (hereinafter - personal data authorized for distribution).

2.10

User — any visitor to the website https://hxnnxs.ru

2.11

Provision of personal data — actions aimed at disclosing personal data to a specific individual or group of individuals.

2.12

Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of individuals ( transfer of personal data) or making personal data available to an unlimited circle of people, including public disclosure of personal data in the media, placing it in information and telecommunication networks, or providing access to personal data by other means.

2.13

Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.

2.14

Destruction of personal data — any actions that result in the permanent destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or destruction of physical media containing personal data.

3. Operator's Rights and Obligations

3.1 The operator has the right to:

  • Obtain reliable information and/or documents containing personal data from the data subject;
  • In case of withdrawal of consent to process personal data by the data subject or a request to stop processing personal data, the operator may continue processing personal data without consent when there are legal grounds as indicated in the Personal Data Law;
  • Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations prescribed by the Personal Data Law and related regulatory legal acts unless otherwise provided by law.

3.2 The operator is obliged to:

  • Provide the data subject with information regarding the processing of their personal data upon request;
  • Organize the processing of personal data in accordance with the applicable laws of the Russian Federation;
  • Respond to inquiries from data subjects and their legal representatives as required by the Personal Data Law;
  • Notify the authorized body for the protection of data subjects' rights upon request within 10 days;
  • Publish or otherwise ensure unrestricted access to this policy regarding personal data processing;
  • Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other illegal actions;
  • Terminate the transfer (distribution, provision, access) of personal data and stop processing and destroy personal data as required by the Personal Data Law;
  • Perform other obligations provided by the Personal Data Law.

4. Rights and Obligations of Personal Data Subjects

4.1 Data subjects have the right to:

  • Receive information regarding the processing of their personal data, except as otherwise provided by federal laws;
  • Demand the correction, blocking, or destruction of their personal data if they are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared processing purpose;
  • Withdraw consent for personal data processing;
  • Appeal to the authorized body or through the court in case of unlawful actions by the operator during the processing of personal data.

4.2 Data subjects must:

  • Provide truthful information about themselves to the operator;
  • Notify the operator of any updates or changes to their personal data.

4.3 Individuals who provided false information about themselves or another person without consent shall be held liable in accordance with Russian legislation.

5. Principles of Personal Data Processing

5.1

Personal data is processed on a lawful and fair basis.

5.2

Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing personal data incompatible with the collection purposes is not allowed.

5.3

Merging databases containing personal data for incompatible processing purposes is prohibited.

5.4

Only personal data necessary for achieving the processing objectives is processed.

5.5

The content and volume of processed personal data correspond to the declared processing objectives. Data overload is not allowed.

5.6

Personal data processing ensures their accuracy, sufficiency, and, where necessary, relevance for the purposes of processing. Necessary measures are taken to delete or clarify incomplete or inaccurate data.

5.7

Personal data is stored in a form that allows identifying the data subject for no longer than necessary to achieve the processing objectives, unless otherwise specified by federal law or a contract.

6. Purposes of Personal Data Processing

The purpose of processing is to provide the user with access to services, information, and/or materials on the website.

Personal data:

  • Email address
  • Photos
  • Nickname

Legal basis:

  • Founding documents of the operator

Types of personal data processing:

  • Collection, recording, systematization, accumulation, storage, destruction, and anonymization.

7. Conditions for Processing Personal Data

7.1

Personal data is processed with the data subject's consent.

7.2

Processing is necessary for achieving the purposes provided by international agreements or Russian law, or for fulfilling the operator’s legal functions, powers, and obligations.

7.3

Processing is necessary for judicial proceedings, enforcement of a judicial act, or another act by an authority or official in accordance with Russian enforcement laws.

7.4

Processing is necessary to fulfill a contract or for the conclusion of a contract at the data subject's initiative.

7.5

Processing is necessary to achieve legal interests of the operator or third parties, provided that it does not infringe upon the rights and freedoms of the data subject.

7.6

Personal data, for which unrestricted access is provided by the data subject or at their request, is processed.

7.7

Processing is necessary to fulfill legal disclosure obligations under Russian law.

8. Collection, Storage, Transfer, and Other Processing of Personal Data

Personal data security is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the laws of the Russian Federation.

8.1

The operator ensures the protection of personal data and takes all possible measures to prevent unauthorized access.

8.2

Personal data will never be transferred to third parties, except when required by law or with the data subject’s consent for the fulfillment of civil law obligations.

8.3

In case of inaccuracies in the personal data, the user can update it by sending an email to the operator.

8.4

The duration of personal data processing is determined by the achievement of processing objectives, unless otherwise stated in a contract or law.

8.5

Any information collected by third-party services, such as payment systems, is stored and processed in accordance with their privacy policies. The operator is not responsible for third-party actions.

8.6

Data subject's prohibitions on transmission or processing of personal data may not apply in cases defined by Russian legislation.

8.7

The operator ensures the confidentiality of personal data during processing.

8.8

The operator stores personal data only for as long as necessary to achieve processing goals.

8.9

The processing of personal data can be terminated when the processing goals are achieved or the data subject withdraws their consent.

9. Actions Performed by the Operator with Received Personal Data

9.1

The operator performs collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, anonymization, blocking, deletion, and destruction of personal data.

9.2

The operator performs automated processing of personal data, with or without transferring the information through telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1

The operator must notify the authorized body before engaging in cross-border data transfer.

10.2

The operator must obtain the necessary information from the authorities or entities in the foreign state before initiating the transfer.

11. Confidentiality of Personal Data

The operator and other individuals with access to personal data must not disclose or distribute personal data without the data subject's consent, except as required by federal law.

12. Final Provisions

12.1

The user may obtain clarifications regarding the processing of their personal data by contacting the operator via email.

12.2

This document will reflect any changes to the operator's personal data processing policy. The policy is effective indefinitely until replaced by a new version.

12.3

The current version of the policy is available online at https://hxnnxs.ru/privacy.