PERSONAL DATA PROCESSING POLICY
1. GENERAL PROVISIONS
This Personal Data Processing Policy (hereinafter — the «Policy») is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 «On Personal Data» and defines the procedure for processing personal data and measures to ensure the security of personal data, which may be obtained by Vyacheslav Alexandrovich Prokhorov, TIN — 231 119626 828 (hereinafter — the «Operator»), about the User when using the website https://prokhorov-media.com (hereinafter — the «Website»).
By registering on the Website and/or using the Website, the User gives their full consent to the terms of this Policy.
The User may obtain any clarifications on matters related to the processing of their personal data by contacting the Operator via email at prokhorov.contacts@gmail.com (hereinafter — the «Operator’s Email»).
2. KEY TERMS USED IN THE POLICY
Personal data — any information relating directly or indirectly to a specific or identifiable individual (personal data subject).
User — an individual, the subject of personal data, using the Website for its intended purpose.
Cookies — small pieces of data relating to personal data that are stored in the browser of a computer, mobile phone, or other device after the User visits the Website.
Automated processing of personal data — processing of personal data using computer technology.
Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
Personal data information system — a set of personal data contained in databases, as well as information technologies and technical means that ensure their processing.
Depersonalization of personal data — actions resulting in the impossibility of determining, without additional information, the ownership of personal data to a specific User or another 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, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
Provision of personal data — actions aimed at disclosing personal data to a specific person or a certain group of persons.
Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in mass media, posting in information and telecommunications networks, or providing access to personal data in any other way.
Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or resulting in the destruction of material carriers of personal data.
3. SUBJECT OF THE POLICY
3.1. The User’s use of the Website means consent to this Policy and the terms of processing of the User’s personal data. Consent to this Policy constitutes the User’s consent to the processing of their personal data.
3.2. In case of disagreement with the terms of this Policy, the User undertakes to stop using the Website.
3.3. Personal data permitted for processing under this Policy are provided by the User voluntarily by filling out the User data form on the Website.
3.4. Personal data permitted for processing under this Privacy Policy are provided by the User by filling out forms on the Operator’s Website and include the following information:
● User’s first and last name;
● User’s contact phone number;
● User’s email address;
● Links to the User’s social media profiles;
● Cookies.
The above-mentioned data are hereinafter collectively referred to as Personal Data.
4. PURPOSES OF PERSONAL DATA PROCESSING
4.1. The processing of the User’s personal data is carried out in accordance with the legislation of the Russian Federation. The Operator processes the User’s personal data for the following purposes:
● identification of the party within the framework of agreements and contracts concluded with the Operator;
● providing the User with services, access to the Website, and services;
● communication with the User, sending letters to the User upon registration on the Website and/or upon receipt of payment from the User, sending notifications and requests within the framework of concluded contracts;
● settlements with the User under concluded contracts;
● confirmation of the accuracy and completeness of the personal data provided by the User;
● granting the User access to the Operator’s partner websites or services in order to obtain products, updates, and services;
● carrying out advertising activities with the User’s consent;
● providing the User with effective customer and technical support in case of issues related to the use of the Website.
4.2. The User may always opt out of receiving informational messages by sending an email to the Operator’s Email with the note «Unsubscribe from notifications.»
5. RIGHTS AND OBLIGATIONS OF THE PARTIES
5.1. The Operator has the right to:
● receive accurate information containing personal data from the User.
5.2. The Operator is obliged to:
● process personal data in accordance with the current legislation of the Russian Federation;
● ensure the confidentiality of personal data, not disclose them without the prior written consent of the User, and not sell, exchange, publish, or disclose the User’s personal data by other possible means, except as provided by this Policy;
● use the obtained information exclusively for the purposes specified in this Privacy Policy;
● consider the User’s inquiries regarding the processing of personal data and provide reasoned responses;
● take measures to clarify or destroy the User’s personal data upon their (or their legal representative’s) lawful and justified request;
● organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation.
5.3. The User has the right to:
● obtain complete information about their personal data processed by the Operator;
● request the correction, blocking, or destruction of their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
● contact the Operator with a request for clarification, modification, or blocking of personal data by sending a relevant notification to the Operator’s Email;
● withdraw consent to the processing of personal data;
● take legal measures to protect their rights;
● exercise other rights provided for by the legislation of the Russian Federation.
5.4. The User is obliged to:
● provide only accurate data about themselves to the Operator.
6. PROCEDURE FOR COLLECTION, STORAGE, TRANSFER, AND OTHER TYPES OF PERSONAL DATA PROCESSING
6.1. The User’s personal data are processed without limitation of time, in any lawful way, including in personal data information systems using both automated and non-automated processing tools.
6.2. The Operator provides access to the User’s personal data only to contractors and affiliated persons who need this information to ensure the functioning of the Website and the provision of services under concluded contracts.
6.3. 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 the current legislation in the field of personal data protection.
6.4. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
6.5. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s Email with the note «Update of personal data.»
6.6. The Operator has the right to store (archive) and compile documents and personal data.
6.7. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s Email with the note «Withdrawal of consent to personal data processing.»
6.8. The Operator has the right to transfer the User’s personal data to third parties in the following cases:
6.8.1. The User has given consent to such actions;
6.8.2. The transfer is necessary for the User to use a particular service or to fulfill a certain agreement or contract with the User;
6.8.3. The transfer is provided for by Russian or other applicable legislation under the procedure established by law.
7. COOKIES
7.1. The Website collects the following types of cookies:
7.1.1. Technical cookies — the collection of these files cannot be disabled when visiting the Website, as they are necessary for its proper operation and the provision of full functionality.
7.1.2. Analytical cookies — collected through web analytics tools for the general analysis of Website usage and obtaining data on Users’ actions on the Website to improve its functionality.
7.2. The purposes of collecting cookies are:
● authentication of Website Users;
● as a security measure used to protect user accounts, including preventing fraudulent use of login credentials, as well as to protect the Website as a whole;
● for data analytics purposes.
7.3. If the User does not want cookies to be stored on their device, they may disable this option in their browser settings. Saved cookies may also be deleted at any time in the system settings of the browser. The User may change their browser settings to accept or reject all cookies by default or only cookies from the Website. By disabling cookies, the User may not be able to use certain functions and tools of the Website.
8. DISPUTE RESOLUTION
8.1. Before filing a lawsuit regarding disputes arising between the Website User and the Operator, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).
8.2. The recipient of the claim shall notify the claimant in writing of the results of the claim review within 30 (thirty) calendar days from the date of receipt of the claim.
8.3. If no agreement is reached, the dispute will be referred to court in accordance with the current legislation of the Russian Federation.
8.4. This Policy and the relationship between the User and the Operator are governed by the current legislation of the Russian Federation.
9. FINAL PROVISIONS
9.1. The Operator has the right to amend this Policy without the User’s consent.
9.2. The new Personal Data Processing Policy comes into force from the moment it is published on the Website, unless otherwise provided by the new version of the Privacy Policy.
9.3. The current version of the Policy is publicly available on the Internet at https://prokhorov-media.com/legal-privacy