Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”), and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Alexander Fedorovich Kulakevich (hereinafter referred to as the “Operator”).

1.1. The Operator considers respect for the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy and personal and family secrets, to be its most important objective and condition for carrying out its activities.
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 receive about visitors to the website https://winterkhor.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 the processing of personal data, except in cases where processing is necessary to clarify the personal data.
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at https://winterkhor.ru.
2.4. Personal data information system — a set of personal data contained in databases, together with information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine, without using additional information, the affiliation of personal data with a specific User or another data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the categories of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://winterkhor.ru.
2.9. Personal data permitted by the data subject for dissemination — personal data to which an unlimited number of persons have been granted access by the data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law.
2.10. User — any visitor to the website https://winterkhor.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unlimited number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data by any 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 resulting in the irreversible destruction of personal data, making it impossible to restore their contents in the personal data information system and/or resulting in the destruction of physical media containing 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 data subject;
— in the event that the data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing personal data without the data subject's consent where grounds specified by the Personal Data Law exist;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the data subject, upon request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with applicable Russian law;
— respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body responsible for protecting the rights of data subjects, upon its request, with the necessary information within 10 days from the date of receiving such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions involving personal data;
— terminate the transfer (dissemination, provision, access) and processing of personal data and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other obligations provided for by the Personal Data Law.

4. Main Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
— appeal unlawful actions or omissions of the Operator in the processing of their personal data to the authorized body responsible for protecting the rights of data subjects or through the courts;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification, update, or change to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another data subject without that person's consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which the data were collected is not permitted.
5.3. Databases containing personal data processed for purposes that are incompatible with one another shall not be combined.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and volume of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. The accuracy and sufficiency of personal data, and, where necessary, their relevance to the purposes of processing, shall be ensured. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the data subject to be identified for no longer than necessary to achieve the purposes of processing, unless the retention period is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymized once the purposes of processing have been achieved or when the need to achieve such purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: conclusion, performance, and termination of civil-law contracts.
Personal data: telephone numbers.
Legal grounds: contracts concluded between the Operator and the data subject.
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.

7. Conditions for the Processing of Personal Data

7.1. Personal data shall be processed with the consent of the 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 by law, and to perform the functions, powers, and duties assigned to the Operator by law.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a court judgment, or an act of another body or official that is subject to execution in accordance with Russian legislation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for exercising the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data that have been made publicly available by the data subject or at their request are processed (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.

8. Procedure for the Collection, Storage, Transfer, and Other 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 applicable legislation concerning personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies are identified in personal data, the User may update them independently by sending a notification to the Operator's email address, Black_hellfire@mail.ru, with the subject line “Personal Data Update.”
8.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is established by contract or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending the Operator a notification by email to Black_hellfire@mail.ru with the subject line “Withdrawal of Consent to the Processing of Personal Data.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreements and Privacy Policies. The data subject and/or [text incomplete in the original] with the aforementioned documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for granting access) of personal data permitted for dissemination, shall not apply where personal data are processed in 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 personal data.
8.8. The Operator stores personal data in a form that allows the data subject to be identified for no longer than required by the purposes of processing, unless the retention period is established by law or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the data subject's consent, withdrawal of consent by the data subject, a request to terminate processing, or identification of unlawful processing of personal data.

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

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (disseminates, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data involving the receipt and/or transmission of information via information and telecommunications networks or without such networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator must notify the authorized body responsible for protecting the rights of data subjects of its intention to carry out such cross-border transfer. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the aforementioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have access to personal data are obliged not to disclose personal data to third parties or disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarification concerning the processing of their personal data by contacting the Operator via email at Black_hellfire@mail.ru.
12.2. Any changes to the Operator's Personal Data Processing Policy shall be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://winterkhor.ru/policy.