Confidentiality policy

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law, as of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Architect LLC (hereinafter referred to as Operator).

1.1. Operator sets observing rights and freedoms of a person and citizen as its most important goal and condition to carry out its activities, when processing his/ her 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 Policy) applies to all information that Operator may receive about visitors of its website https://yasnosvetpavel.com.

2. Basic Notions Used in Confidentiality Policy

2.1. Automated processing of personal data is the processing of personal data using computer technology.
2.2. Blocking of personal data means a temporarily suspended processing of personal data (unless this processing is necessary to clarify personal data).
2.3. Website is a set of graphic and informational material, as well as computer programs and databases that ensure their availability on the Internet via the network address https://yasnosvetpavel.com.
2.4. Information system of personal data is a set of personal data contained in databases, information technologies and technical means that ensure their processing.
2.5. Depersonalized personal data means actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of personal data means any action (operation) or a set of actions (operations) performed, with or without the use of automation tools, regarding personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator is a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/ or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data is any information related, directly or indirectly, to a specific or identifiable User of Website https://yasnosvetpavel.com.
2.9. Personal data authorized by a personal data subject for distribution means personal data, access to which is granted to an unlimited number of persons by a personal data subject by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner stipulated by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.10. User is any visitor to Website https://yasnosvetpavel.com.
2.11. Provision of personal data means actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the 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 is the transfer of personal data, to the territory of a foreign state, for an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data means any actions as a result of which personal data is irretrievably destroyed making it impossible to further restore the content of personal data in the information system of personal data, and/ or material carriers of personal data are destroyed.

3. Basic Rights and Obligations of Operator

3.1. Operator shall be entitled to:
– receive reliable information and/ or documents containing personal data, from a personal data subject;
- in the event that a personal data subject withdraws consent to the processing of personal data, Operator has the right to continue to process personal data without the consent of this personal data subject, provided that there are grounds specified in the Law on Personal Data;
– determine independently the composition and the list of measures required and sufficient to ensure the fulfilment of the obligations stipulated by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. Operator shall be obliged to:
– provide the subject of personal data, at his/ her request, with information regarding the processing of his/ her personal data;
– organize the processing of personal data in the manner stipulated by the current legislation of the Russian Federation;
– respond to requests by personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- report to the authorized body for protecting the rights of personal data subjects, at the request of this body, necessary information, within 30 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 to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated in the Law on Personal data;
– perform other duties provided for by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects shall be entitled to:- receive information regarding the processing of his/ her personal data, except as otherwise provided by federal laws. Information is provided to the personal data subject by Operator in an accessible form, and it shall not contain personal data relating to other personal data subjects, unless there are legal grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;- require that Operator clarify his/ her personal data, block or destroy it, if the personal data is incomplete, obsolete, inaccurate, obtained illegally or not necessary for the stated purpose of processing, as well as take legal measures to protect his/ her rights;- put forward the condition of prior consent when processing personal data in order to promote goods, work and services on the market;
- withdraw consent to the processing of personal data;- appeal to the authorized body for protecting the rights of personal data subjects or in court against Operator’s illegal actions or inaction when processing his/ her personal data;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall be obliged to:– provide Operator with reliable information about himself/ herself;– inform Operator of any updates, or changes in his/ her personal data.
4.3. Persons who have provided Operator with false information about themselves or information about another personal data subject without his/ her consent shall be liable in accordance with the legislation of the Russian Federation.

5. Operator may process the following personal data of User:

5.1. Full name.
5.2. Email address.
5.3. Phone numbers.
5.4. The website collects and processes anonymous data as well (including cookies) about visitors using Internet statistics services (Yandex.Metrica, Google Analytics and others).
5.5. The above data is further united, in the text of the Policy, by the general concept of Personal data.
5.6. Operator shall not process specialized categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, and intimate life.
5.7. Processing of personal data permitted for distribution, among the specialized categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data, is allowed provided that the prohibitions and conditions stipulated in Art. 10.1 of the Law on Personal Data are observed.
5.8. User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of his/ her personal data. In this case, the conditions provided for, in particular, in Art. 10.1 of the Law on Personal Data. Requirements for the content of such consent are established by the authorized body for protecting the rights of personal data subjects.
5.8.1 User provides Operator directly with the consent to the processing of personal data permitted for distribution.
5.8.2 Operator shall be obliged, within a period of no later than three working days from the date of receiving the specified consent of User, to publish information on the terms of processing, any prohibitions and terms for processing, by an unlimited number of persons, personal data permitted for distribution.
5.8.3 Any transfer (distribution, provision, and access) of personal data authorized by a personal data subject for distribution shall be terminated at any time at the request of the personal data subject. This requirement shall include last name, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as the list of personal data, the processing of which is subject to termination. The personal data specified in this request may be only processed by Operator to whom it is sent.
5.8.4 Consent to the processing of personal data permitted for distribution terminates from the moment when Operator receives the request specified in clause
5.8.3 of this Policy regarding the processing of personal data.

6. Principles of Processing Personal Data

6.1. The processing of personal data is carried out on a legal and fair basis.
6.2. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data shall not be allowed.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
6.4. Only personal data that meet the purposes of its processing is subject to processing.
6.5. The content and scope of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, its accuracy, sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, shall be ensured. Operator takes the necessary measures and/ or ensures their adoption to remove or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows determining a personal data subject, no longer than required by the purposes of processing personal data, provided that the period for storing personal data is not established by federal law, or an agreement to which this personal data subject is a party, beneficiary, or guarantor. The processed personal data is destroyed, or depersonalized at achieving goals of its processing, or if it is no longer necessary to achieve these purposes, or upon the occurrence of other legal grounds within the time limits established by Art. 21 of the Federal Law “On Personal Data.”The following is the procedure for destructing personal data when achieving goals of its processing or if it is no longer necessary to achieve these purposes, or upon the occurrence of other legal grounds: the person responsible for processing personal data shall erase this data without the possibility of its recovery, with the drawing up of an act on destructing personal data.

7. Purposes of Personal Data Processing

7.1. The following is the purpose of processing User's personal data:
– informing User by sending e-mails;
– conclusion, execution and termination of civil law contracts;
– granting access to User to the services, information and/or material contained on website https://yasnosvetpavel.com.
7.2. Operator shall be entitled to send notifications to User as well, about new products and services, special offers and various events. User can always refuse to receive information messages by sending an email to Operator at architect127@mail.ru marked as “Refusal to receive notifications about new products, services and special offers.”
7.3. Impersonal data of Users collected using Internet statistics services is used to collect information about Users’ actions on the website, improve the quality of the website and its content.

8. Legal Grounds for Personal Data Processing

8.1. The following are legal grounds for processing personal data by Operator:
- statutory (constituent) documents of Operator;
- agreements concluded between Operator and a personal data subject;
- federal laws, other regulations in the field of personal data protection;
- consent of Users to the processing of their personal data and the processing of personal data permitted for distribution.
8.2. Operator shall process User's personal data only if it is filled in and/ or sent by User independently through special forms located on Website https://yasnosvetpavel.com or sent to Operator via email. By filling out the relevant forms and/ or sending his/ her personal data to Operator, User expresses his/ her consent to this Policy.
8.3. Operator shall process anonymized data about User, if it is allowed in User's browser settings (saving cookies and using JavaScript technology are enabled).
8.4. Any personal data subject decides independently on the provision of his/ her personal data and gives consent freely, of his/ her own free will and in his/ her own interest.

9. Terms of Processing Personal Data

9.1. The processing of personal data is carried out with the consent of a personal data subject to processing his/ her personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out functions, powers and obligations assigned by legislation of the Russian Federation to Operator.
9.3. The processing of personal data is necessary for administration of justice, execution of a judicial act, an act of another body or official, subject to execution in accordance with legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for performing an agreement to which a personal data subject is a party, or beneficiary, or guarantor, as well as to conclude an agreement on the initiative of a personal data subject or an agreement under which a personal data subject will be beneficiary or guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of Operator, or third parties, or to achieve socially significant goals, provided that the rights and freedoms of a personal data subject are not violated.
9.6. The processing of personal data is carried out when the access to this data for an unlimited number of persons is provided by a personal data subject, or at his/ her request (hereinafter referred to as publicly available personal data).
9.7. The processing of personal data is carried out when it is subject to publication or mandatory disclosure in accordance with federal law.

10. The procedure for Collecting, Storing, Transferring and Other Types of Personal Data Processing The security of personal data processed by Operator shall be ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

10.1. Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by any unauthorized persons.
10.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law, or if the subject of personal data has given consent to Operator to transfer data to a third party to fulfil obligations under a civil law contract.
10.3. In case of detected inaccuracies in personal data, User may update it independently by sending a notification to Operator to Operator's e-mail address architect127@mail.ru with the notice “Updated personal data.”
10.4. The term for processing personal data is determined by achieving the purposes for which the personal data was collected, unless a different period is provided by a contract or applicable law.
User may revoke, at any time, his/ her consent to processing personal data, by sending Operator a notification by e-mail to Operator's email address architect127@mail.ru marked as “Withdrawal of consent to personal data processing.”
10.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. A personal data subject and/ or User shall be obliged to independently familiarize themselves with the specified documents in a timely manner. Operator shall not be responsible for the actions of third parties, including any service providers specified in this paragraph.
10.6. Any prohibitions established by a personal data subject for transferring (except for granting access), as well as processing, or terms of processing (except for obtaining access) personal data permitted for distribution shall not apply in cases of processing personal data in state, general public, or other public interests determined by RF law.
10.7. When processing personal data, Operator ensures the confidentiality of personal data.
10.8. Operator shall store personal data in a form that allows determining a personal data subject, no longer than required by the purposes of processing personal data, provided that the period of storing personal data is not established by federal law, an agreement to which a personal data subject is a party, beneficiary, or guarantor.
10.9. Achieving the purposes of processing personal data, expired consent of a personal data subject, or withdrawn consent by a personal data subject, as well as identified unlawful processing of personal data may be the condition to terminate the processing of personal data.

11. List of Actions Performed by Operator with the Received Personal Data

11.1. Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
11.2. Operator carries out automated processing of personal data with the receipt and/ or transmission of the received information via information and telecommunication networks, or without it.

12. Cross-Border Transfer of Personal Data

12.1. Before starting cross-border transfer of personal data, Operator shall be obliged to ensure that the foreign state into whose territory it is intended to transfer personal data provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if there is a written consent of a personal data subject to the cross-border transfer of his/ her personal data and/ or execution of an agreement to which a personal data subject is a party.

13. Confidentiality of Personal Data Operator and other persons who have gained access to personal data shall be obliged not to disclose to third parties and not to distribute personal data without the consent of a personal data subject, unless otherwise provided by federal law.

14. Final Provisions
14.1. User may have any clarifications on issues of interest regarding the processing of his/ her personal data by contacting Operator via e-mail: architect127@mail.ru.14.2. This document reflects any changes in the policy of processing personal data by Operator. The policy shall be valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available online at https://yasnosvetpavel.com/politics.

TIN 5406832337    OGRN  1235400023902

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© Pavel Yasnosvet 2022-2024