1. General ProvisionsThis Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Maxim Viktorovich Grishin (hereinafter referred to as the "Operator").
1.1. The Operator's primary goal and condition for carrying out its activities is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Operator's Policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://cso-culture.org.
2. Basic Concepts Used in the Policy2.1.
Automated processing of personal data – processing of personal data using computer technology.
2.2.
Blocking of personal data – temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3.
Website – a collection of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://cso-culture.org.
2.4.
Personal data information system – a set of personal data contained in databases, and information technologies and technical means ensuring their processing.
2.5.
Anonymization of personal data – actions that make it impossible to determine the ownership of personal data to a specific User or other personal data subject without using additional information.
2.6.
Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7.
Operator – a state body, municipal body, legal entity or individual, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, 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 a specific or identifiable User of the website https://cso-culture.org.
2.9.
Personal data authorized for distribution by the personal data subject – personal data to which an unlimited circle of persons has been granted access by the personal data subject by giving consent to the processing of personal data authorized for distribution in the manner prescribed by the Personal Data Law (hereinafter – "personal data authorized for distribution").
2.10.
User – any visitor to the website https://cso-culture.org.
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 circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publishing personal data in the media, posting it in information and telecommunication networks, or providing access to personal data in any other way.
2.13.
Cross-border transfer of personal data – transferring personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14.
Destruction of personal data – any actions that result in personal data being permanently destroyed with no possibility of further restoration of the content of the personal data in the personal data information system and/or the physical media containing the personal data being destroyed.
3. Basic Rights and Obligations of the Operator3.1. The Operator has the right to:
- Receive from the personal data subject reliable information and/or documents containing personal data;
- In the event that the personal data subject withdraws consent for the processing of personal data, or submits a request to cease processing, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- Independently determine the composition and list of measures necessary and sufficient to ensure compliance with 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 related 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;
- Notify the authorized body for the protection of the rights of personal data subjects, upon request from this body, of the necessary information within 10 days from the date of receiving 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 unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
- Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- Perform other duties stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:
- Receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, except 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;
- Request that the Operator clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights;
- Impose a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services;
- Withdraw consent for the processing of personal data, as well as submit a request to cease processing of personal data;
- Appeal against unlawful actions or inaction of the Operator when processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
- 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 the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, pre-determined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated processing purposes. Redundancy of processed personal data relative to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance concerning the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or if the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose of Processing | Informing the User by sending emails |
Personal Data | ● Email address ● Phone numbers |
Legal Basis | ● Operator's constituent (founding) documents |
Types of Personal Data Processing | ● Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data |
7. Conditions for Processing Personal Data7.1. Processing of personal data 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 purposes provided for by an international treaty of the Russian Federation or a law, to carry out the functions, powers, and duties assigned by the legislation of the Russian Federation to the Operator.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an 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 at 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 to which access by an unlimited circle of persons 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 Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured by implementing 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 to prevent 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 the implementation of current legislation, or if the personal data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in the personal data are identified, the User can update them independently by sending a notification to the Operator's email address richbandmoscow@gmail.com marked "Update of personal data".
8.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected, unless another period is provided for by a contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at richbandmoscow@gmail.com marked "Withdrawal of consent for personal data processing".
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on transfer (except for providing access), as well as on processing or conditions for processing (except for obtaining access) of personal data authorized for distribution, established by the personal data subject, do not apply in cases where personal data is processed for state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of the personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the processing purposes, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may be conditioned upon achieving the purposes of processing, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject or a request to cease processing, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with or without the receipt and/or transmission of the received information over information and telecommunication networks.
10. Cross-border Transfer of Personal Data10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the 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 the intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the foreign government authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal DataThe 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 Provisions12.1. The User may obtain any clarification on questions regarding the processing of their personal data by contacting the Operator via email at richbandmoscow@gmail.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. This Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://cso-culture.org.