PERSONAL DATA PROCESSING POLICY
1. General Provisions
This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter — Law on Personal Data) and determines the procedure for processing personal data and measures to ensure personal data security taken by Individual Entrepreneur Yulia Vladimirovna Kirchgesner (hereinafter — the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms during the processing of personal data, including the protection of rights to privacy, personal and family secrecy.
1.2. This Operator’s policy regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://saint-art.net/.
2. Basic Concepts Used in the Policy
- Automated processing of personal data — processing of personal data using computer technology.
- Blocking of personal data — temporary termination of personal data processing (except when processing is necessary to clarify personal data).
- Website — a collection of graphic and information materials, as well as computer programs and databases ensuring their accessibility on the Internet at the network address https://saint-art.net/.
- Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
- Anonymization (Depersonalization) of personal data — actions resulting in the impossibility of determining, without using additional information, the ownership of personal data to a specific User or other subject of personal data.
- 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, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
- Operator — a state body, municipal body, legal entity, or individual who independently or jointly with other persons organizes and/or carries out personal data processing, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
- Personal data — any information relating directly or indirectly to a specific or determinable User of the website https://saint-art.net/.
- Personal data permitted for distribution by the personal data subject — personal data access to an unlimited number of persons to which is granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data permitted for distribution).
- User — any visitor to the website https://saint-art.net/.
- Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
- Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including publishing personal data in mass media, placing in information and telecommunication networks, or providing access to personal data in any other way.
- Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, foreign individual, or foreign legal entity.
- Destruction of personal data — any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or destruction of material media of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right:
- To receive truthful information and/or documents containing personal data from the personal data subject;
- In case of revocation of consent to personal data processing by the personal data subject, as well as submission of a request to terminate personal data processing, the Operator has the right to continue personal data processing without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
- To independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged:
- To provide the personal data subject, at their request, with information regarding the processing of their personal data;
- To organize the processing of personal data in accordance with the procedure established by the effective legislation of the Russian Federation;
- To respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- To submit to the authorized body for the protection of rights of personal data subjects, upon request of this body, necessary information within 10 days from the date of receipt of such request;
- To publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
- To take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
- To cease transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided by the Law on Personal Data;
- To perform other duties provided by the Law on Personal Data.
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 by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data belonging to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- To demand that the operator clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
- To make the condition of prior consent when processing personal data for marketing goods, works, and services;
- To revoke consent to personal data processing, as well as send a request to terminate personal data processing;
- To appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of rights of personal data subjects or in court;
- To exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
- To provide the Operator with truthful data about themselves;
- To inform the Operator about clarification (updating, changing) of their personal data.
4.3. Persons who transferred inaccurate information about themselves to the Operator, 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. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.3. Combining databases containing personal data processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. Redundancy of processed personal data in relation to stated processing purposes is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance to the purposes of processing personal data is ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving processing goals or in case of loss of necessity to achieve these goals, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of Processing | Processed Personal Data | Legal Grounds | Types of Processing |
| Providing User access to services, information, and/or materials contained on the website | • Surname, First Name, Patronymic • Email address • Telephone numbers • Year, month, date, and place of birth | Contracts concluded between the Operator and the personal data subject | Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data |
7. Conditions of Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the goals provided by an international treaty of the Russian Federation or law, for the execution of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. 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 concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. 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 the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data access to an unlimited circle of persons to which is provided by the personal data subject or at their request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Processing
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.
8.1. The Operator ensures the safety of personal data and takes all possible measures excluding 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 compliance with effective legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator’s email address magazine.saint.art@gmail.com marked “Updating personal data”.
8.4. The processing period for personal data is determined by achieving the purposes for which the personal data was collected, unless another period is provided by contract or effective legislation. The User may at any time revoke their consent to personal data processing by sending a notification to the Operator via email to magazine.saint.art@gmail.com marked “Revocation of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by specified entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on transfer (except granting access), as well as on processing or conditions of processing (except obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by Russian legislation.
8.7. The Operator ensures confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form allowing identification of the personal data subject for no longer than required by processing purposes, unless the storage period is established by federal law, contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The condition for terminating personal data processing may be the achievement of processing goals, expiration of consent validity, revocation of consent by the subject or demand to stop processing, as well as identification of unlawful processing.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transmission of obtained information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to carry out personal data processing).
10.2. Prior to submitting the above notification, the Operator is obliged to obtain relevant information from foreign authorities, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned.
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 or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarification on questions of interest regarding the processing of their personal data by contacting the Operator via email magazine.saint.art@gmail.com.
12.2. This document will reflect any changes in the personal data processing policy by the Operator. The Policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://saint-art.net/privacy.
