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PRIVACY POLICY REGARDING THE PROCESSING OF PERSONAL DATA

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 Individual Entrepreneur Irina Anatolyevna Zolotova (hereinafter referred to as the Operator).

1.1.

The Operator considers the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy, personal and family confidentiality, to be its most important goal and a prerequisite for carrying out its activities.

1.2.

This Policy of the Operator 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://www.zzburo.com/

2. BASIC TERMS USED IN THIS POLICY

2.1.

Automated Processing of Personal Data — processing of personal data using computer technology.

2.2.

Blocking of Personal Data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).

2.3.

Website — a collection of graphic and informational materials, as well as computer software and databases, ensuring their availability on the Internet at:

https://www.zzburo.com/

2.4.

Personal Data Information System — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.

2.5.

Depersonalization of Personal Data — actions that make it impossible to determine, without the use of additional information, whether personal data belongs to 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 in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, 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, as well as determines 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 an identified or identifiable User of the website:

https://www.zzburo.com/

2.9.

Personal Data Authorized by the Data Subject for Distribution — personal data to which the data subject has granted unrestricted access by giving consent to the processing of personal data authorized for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as Personal Data Authorized for Distribution).

2.10.

User — any visitor to the website:

https://www.zzburo.com/

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 number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication 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 public authority, foreign individual, or foreign legal entity.

2.14.

Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data with no possibility of restoring its content within the personal data information system and/or the destruction of physical media containing personal data.

3. BASIC RIGHTS AND OBLIGATIONS OF THE OPERATOR

3.1. The Operator has the right to:

  • receive accurate information and/or documents containing personal data from the personal data subject;

  • continue processing personal data without the consent of the personal data subject if the subject withdraws consent or requests termination of processing, provided that the grounds specified in 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 other applicable legal acts, 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 request, with information relating to the processing of their personal data;

  • organize the processing of personal data in accordance with the current legislation of the Russian Federation;

  • respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

  • provide the authorized body responsible for the protection of the rights of personal data subjects with the information requested by such body within ten (10) days from the date of receipt of the request;

  • publish or otherwise ensure unrestricted access to this Privacy Policy regarding the processing of personal data;

  • take legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions involving personal data;

  • cease the transfer (distribution, provision, access) of personal data, terminate the processing of personal data, and destroy personal data in the cases and in the manner prescribed by the Personal Data Law;

  • perform other duties stipulated by the Personal Data Law.
     

  • 4. BASIC 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 for by federal law. Such 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 legal 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 is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and 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, or services on the market;

  • withdraw consent to the processing of personal data and request the termination of such processing;

  • appeal unlawful actions or omissions of the Operator in relation to the processing of 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 accurate personal information about themselves;

  • notify the Operator of any clarification (update or amendment) to their personal data.

  • 4.3.

  • Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent shall bear responsibility 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 that is incompatible with the purposes for which the personal data was collected shall not be permitted.

  • 5.3.

  • Databases containing personal data processed for purposes that are incompatible with one another shall not be merged.

  • 5.4.

  • Only personal data that is relevant to the purposes of its processing shall be processed.

  • 5.5.

  • The content and scope of the processed personal data shall correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of processing shall not be permitted.

  • 5.6.

  • When processing personal data, the Operator shall ensure the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate personal data.

  • 5.7.

  • Personal data shall be stored in a form that makes it possible to identify the personal data subject for no longer than is required by the purposes of processing, unless a longer storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.

  • Processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or if the need to achieve such purposes no longer exists, unless otherwise provided by federal law.

  • 6. PURPOSES OF PERSONAL DATA PROCESSING

  • Purpose of Processing

  • Providing the User with access to the services, information, and/or materials available on the website.

  • Personal Data

  • Name

  • Telephone number

  • Email address

  • Legal Basis

  • Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection."

  • Types of Personal Data Processing

  • Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
     

  • 7.1.

  • Personal data shall be processed with the consent of the personal data subject.

  • 7.2.

  • The processing of personal data is necessary for achieving the purposes stipulated by an international treaty of the Russian Federation or by law, as well as for the performance of functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.

  • 7.3.

  • The processing of personal data is necessary for the administration of justice and for the execution of a judicial act or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

  • 7.4.

  • The 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 entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will become a beneficiary or guarantor.

  • 7.5.

  • The processing of personal data is necessary for the exercise of the legitimate rights and interests of the Operator or third parties, or for achieving socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.

  • 7.6.

  • Personal data made publicly available by the personal data subject or at their request (hereinafter referred to as Publicly Available Personal Data) may be processed.

  • 7.7.

  • Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.

  • 8. PROCEDURE FOR THE COLLECTION, STORAGE, TRANSFER, AND OTHER TYPES OF 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 applicable legislation on personal data protection.

  • 8.1.

  • The Operator shall ensure the security of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.

  • 8.2.

  • Under no circumstances shall the User's personal data be transferred to third parties, except where required by applicable law or where the personal data subject has given consent to the Operator for such transfer in order to fulfill obligations arising under a civil law agreement.

  • 8.3.

  • If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator via email at:

  • zz.buro@yandex.ru

  • with the subject line:

  • "Personal Data Update"

  • 8.4.

  • The period for processing personal data shall be determined by the achievement of the purposes for which the personal data was collected, unless another period is established by law or by contract.

  • 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:

  • zz.buro@yandex.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, shall be stored and processed by such persons (Operators) in accordance with their respective User Agreements and Privacy Policies.

  • The personal data subject is responsible for reviewing such documents.

  • The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.

  • 8.6.

  • Restrictions established by the personal data subject regarding the transfer (except for granting access), processing, or conditions for processing personal data authorized for distribution shall not apply where such processing is carried out in the public, governmental, or other public interests as provided by the legislation of the Russian Federation.

  • 8.7.

  • When processing personal data, the Operator shall ensure the confidentiality of personal data.

  • 8.8.

  • The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than is required to achieve the purposes of processing, unless a longer retention period is established by federal law or by a contract to which the personal 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 validity period of the personal data subject's consent;

  • withdrawal of consent by the personal data subject;

  • receipt of a request from the personal data subject to terminate processing;

  • identification of unlawful processing of personal data.

  • 9. LIST OF ACTIONS PERFORMED BY THE OPERATOR WITH PERSONAL DATA

  • 9.1.

  • The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating and modification), retrieval, use, transfer (distribution, provision, and access), anonymization, blocking, deletion, and destruction of personal data.

  • 9.2.

  • The Operator performs automated processing of personal data with or without the receipt and/or transfer of information via information and telecommunications networks.
     

  • 10. CROSS-BORDER TRANSFER OF PERSONAL DATA

  • 10.1.

  • Before commencing any cross-border transfer of personal data, the Operator shall notify the authorized body responsible for the protection of the rights of personal data subjects of its intention to carry out such transfer (this notification shall be submitted separately from the notification of the intention to process personal data).

  • 10.2.

  • Before submitting the above-mentioned notification, the Operator shall obtain the necessary information from the foreign public authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is intended.

  • 11. CONFIDENTIALITY OF PERSONAL DATA

  • The Operator and any other persons who have obtained access to personal data shall be 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 PROVISIONS

  • 12.1.

  • The User may obtain any clarification regarding the processing of their personal data by contacting the Operator via email at:

  • zz.buro@yandex.ru

  • 12.2.

  • Any amendments to this Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in effect indefinitely until it is replaced by a new version.

  • 12.3.

  • The current version of this Policy is publicly available on the Internet at:

  • https://www.zzburo.com/

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