Policy on personal data processing

1. General Provisions 

This policy of personal data processing is drawn up in accordance with the requirements of the  Federal Law of 27.07.2006. No. 152-FL “On Personal Data” (hereinafter – the Law on Personal  Data) and defines the procedure of personal data processing and measures to ensure the security  of personal data undertaken by the self-employed citizen Nagornyi Nikolayi Sergeevich  (hereinafter – the Operator). 

1.1. The Operator sets as its goal and condition of its activity the observance of human and  citizen’s rights and freedoms during the processing of personal data, including the protection of  the rights to privacy, personal and family secrecy. 

1.2. This Operator’s policy on personal data processing (hereinafter referred to as the Policy)  applies to all information that the Operator may obtain about visitors to the https://nagornyi.su  website. 

2. Basic concepts used in the Policy 

2.1. Automated processing of personal data – processing of personal data with the help of  computing equipment. 

2.2. Blocking of personal data – temporary cessation of personal data processing (except for  cases when processing is necessary to clarify personal data). 

2.3. Website – a set of graphic and informational materials, as well as computer programs and  databases, ensuring their availability on the Internet at the network address https://nagornyi.su. 

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. Personal data depersonalization – actions as a result of which it is impossible to determine,  without using additional information, the belonging of personal data to a particular User  or other subject of personal data. 

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed  with or without the use of automation means with personal data, including collection, recording,  systematization, accumulation, storage, clarification (update, change), extraction, use, transfer  (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal  data. 

2.7. Operator – a state body, municipal body, legal entity or individual, independently or jointly  with other persons organizing and (or) processing personal data, as well as determining the purposes of personal data processing,  composition of personal data subject to processing, actions (operations) performed with personal  data. 

2.8. Personal Data – any information relating directly or indirectly to a specific or identifiable  User of the https://nagornyi.su website. 

2.9. Personal data authorized by the subject of personal data for dissemination – personal data,  access to which is provided by the subject of personal data to an unlimited number of persons by  giving consent to the processing of personal data authorized by the subject of personal  data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter –  personal data authorized for dissemination). 

2.10. User – any visitor to the https://nagornyi.su website. 

2.11. Provision of personal data – actions aimed at disclosure of personal data to a certain person  or a certain circle of persons. 

2.12. Dissemination of personal data – any actions aimed at disclosure of personal data to an  indefinite number of persons (transfer of personal data) or familiarization of personal data to an  unlimited number of persons, including disclosure of personal data in mass 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 – transfer of personal data to the territory of a foreign  country to a foreign government authority, a foreign individual or a foreign legal entity. 

2.14. Destruction of personal data – any actions as a result of which personal data are  irretrievably destroyed with the impossibility of further recovery of the content of personal data  in the information system of personal data and (or) destruction of material carriers of personal  data. 

3. Main rights and obligations of the Operator 

3.1. The operator shall have the right to: 

3.2. The operator is obligated to: 

4. Basic rights and obligations of personal data subjects 

4.1. Personal data subjects have the right to: 

4.2. Personal data subjects are obliged to:

4.3. Persons who have passed to the Operator false information about themselves, or information  about another subject of personal data without the consent of the latter, shall be liable in  accordance with the legislation of the Russian Federation. 

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

5.1. Last name, first name, middle name.

5.2. Phone Number.

5.3. Email address.

5.4. The site also collects and processes anonymized data about visitors (including cookies)  using Internet statistics services (Yandex Metrics and Google Analytics and others). 

5.5. The aforementioned data are hereinafter in the text of the Policy united by the general term  Personal Data. 

5.6. The Operator does not process special categories of personal data concerning race,  nationality, political opinions, religious or philosophical beliefs, intimate life. 

5.7. The processing of personal data, authorized for dissemination, from among the special  categories of personal data specified in Article 10, paragraph 1 of the Law on personal data, is  allowed if the prohibitions and conditions provided for in Article 10.1 of the Law on  personal data are complied with. 

5.8. The User’s consent to the processing of personal data authorized for dissemination is  executed separately from other consents to the processing of his/her personal data. The  conditions stipulated in particular in act. 10.1 of the Law on personal data. The requirements for the content of such consent shall be  established by the authorized body for the protection of the rights of personal data subjects. 

5.8.1. The User gives consent to the processing of personal data authorized for dissemination to  the Operator directly. 

5.8.2. The Operator is obliged to publish information on the conditions of processing,  prohibitions and conditions for processing by an unlimited number of persons of personal data  authorized for dissemination within three working days from the receipt of the said consent of  the User.

5.8.3. The transfer (dissemination, provision, access) of personal data authorized by the subject  of personal data for dissemination shall be stopped at any time at the request of the subject of  personal data. This request shall include the surname, first name, patronymic (if any), contact  information (telephone number, e-mail address or postal address) of the subject of personal data,  as well as a list of personal data whose processing is subject to termination. The personal data  specified in this request may be processed only by the Operator to whom it is sent. 

5.8.4. The consent to the processing of personal data authorized for dissemination shall  terminate upon receipt by the Operator of the request specified in clause 5.8.3 of this Policy on personal data processing. 

6. Principles of personal data processing 

6.1. The processing of personal data is carried out on a lawful and fair basis. 

6.2. The processing of personal data is limited to the achievement of specific, predetermined and  legitimate purposes. Processing of personal data incompatible with the purposes of personal data  collection is not allowed. 

6.3. It is not allowed to merge databases containing personal data processed for incompatible  purposes. 

6.4. Only personal data that meet the purposes for which they are processed shall be processed. 

6.5. The content and scope of processed personal data correspond to the stated purposes of  processing. The redundancy of processed personal data in relation to the stated purposes of their  processing is not allowed. 

6.6. When processing personal data, the accuracy of personal data, their sufficiency and, where  necessary, relevance to the purposes of personal data processing are ensured. The Operator shall  take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or  inaccurate data. 

6.7. Personal data shall be stored in a form that allows identification of the subject of personal  data for no longer than required by the purposes of personal data processing, unless the period of  personal data storage is established by federal law, contract to which the subject of personal data  is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized  upon achievement of the purposes of processing or in case of loss of necessity to achieve these  purposes, unless otherwise provided for by federal law. 

7. Purposes of personal data processing 

7.1. Purpose of processing the User’s personal data: 

7.2. The Operator also has the right to send the User notifications about new products and  services, special offers and various events. The User can always refuse to receive information  messages by sending a letter to the Operator to the e-mail address support@nagornyi.su with the  note “Refusal of notifications about new products and services and special offers”. 

7.3. The anonymized data of Users collected through Internet statistics services are used to  collect information about Users’ actions on the website, to improve the quality of the website and  its content. 

8. Legal basis for personal data processing 

8.1. The legal grounds for the processing of personal data by the Operator are:

8.2. The Operator processes the User’s personal data only if it is filled in and/or sent by the User  himself/herself through special forms located on the website https://nagornyi.su or sent to the  Operator by e-mail. By filling in the relevant forms and/or sending their personal data to the  Operator, the User expresses their consent to this Policy. 

8.3. The Operator processes anonymized data about the User if it is allowed in the User’s  browser settings (cookies and JavaScript technology enabled). 

8.4. The subject of personal data independently decides 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. Conditions of personal data processing 

9.1. Personal data processing is carried out with the consent of the personal data subject to the  processing of his/her personal data. 

9.2. Processing of personal data is necessary to achieve the purposes stipulated by the  international treaty of the Russian Federation or by law, to fulfill the functions, powers and  duties assigned to the operator by the legislation of the Russian Federation.

9.3. Processing of personal data is necessary for the administration of justice, execution of a  judicial act, act of another body or official subject to execution in accordance with the  legislation of the Russian Federation on enforcement proceedings. 

9.4. The processing of personal data is necessary for the execution of a contract to which the  personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of 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. 

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate  interests of the operator or third parties or for the achievement of socially important purposes,  provided that the rights and freedoms of the personal data subject are not violated. 

9.6. Processing of personal data is carried out where access to which is granted to an unlimited  number of persons by the subject of personal data or at his/her request (hereinafter – publicly  available personal data). 

9.7. Processing of personal data subject to publication or mandatory disclosure in accordance  with federal law. 

10. Procedure for collection, storage, transfer and other types of  personal data processing 

The security of personal data processed by the Operator is ensured by implementing  legal, organizational and technical measures necessary for full compliance with the  requirements of the applicable legislation in the field of personal data protection. 

10.1. The Operator ensures the safety of personal data and takes all possible measures to  prevent unauthorized persons from accessing personal data. 

10.2. The User’s personal data will never, under no circumstances, be transferred to third  parties, except in cases related to the execution of the applicable law or if the subject of personal  data has given consent to the Operator to transfer the data to a third party for the fulfillment of  obligations under a civil law contract. 

10.3. In case of identifying inaccuracies in personal data, the User may update them  independently by sending a notice to the Operator to the Operator’s e-mail address  support@nagornui.su with the note “Personal Data Update”. 

10.4. The period of personal data processing is determined by the achievement of the purposes  for which the personal data were collected, unless another period is stipulated by the contract or  applicable law.

The User may withdraw his/her consent to the processing of personal data at any time by sending  a notice to the Operator by e-mail to the Operator’s e-mail address support@nagornyi.su marked  “Withdrawal of consent to the processing of personal data”. 

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. The subject of  personal data and/or User is obliged to familiarize himself/herself with the said documents in a  timely manner. The Operator is not responsible for the actions of third parties, including the  service providers mentioned in this clause. 

10.6. The prohibitions established by the personal data subject on the transfer (except for  granting access), as well as on the processing or conditions of processing (except for obtaining  access) of personal data authorized for dissemination shall not apply in cases of processing  personal data in the state, public and other public interest, as defined by the legislation of the  Russian Federation. 

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

10.8. The Operator shall store personal data in a form that allows to identify the subject of  personal data for no longer than required by the purposes of personal data processing, unless the  period of personal data storage is established by federal law, a contract to which the subject of  personal data is a party, beneficiary or guarantor. 

10.9. The condition for termination of personal data processing may be the achievement of the  purposes of personal data processing, expiration of the personal data subject’s consent or  withdrawal of consent by the personal data subject, as well as detection of unlawful processing  of personal data. 

11. List of actions performed by the Operator with the received  personal data 

11.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update,  change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete  and destroy personal data. 

11.2. The Operator performs automated processing of personal data with or without receiving  and/or transmitting the received information via information and telecommunication  networks. 

12. Cross-border transfer of personal data 

12.1. Prior to the commencement of trans-border transfer of personal data, the Operator is  obliged to ensure t h a t the foreign state to whose territory the personal data are transferred the transfer of personal data is supposed to be carried out, a reliable protection of the rights of  personal data subjects is ensured. 

12.2. Trans-border transfer of personal data to the territories of foreign states that do not meet  the above requirements may be carried out only if the personal data subject consents in writing to  the trans-border transfer of his/her personal data and/or fulfillment of an agreement to which the  personal data subject is a party. 

13. Confidentiality of personal data 

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

14. Final provisions 

14.1. The User may obtain any clarifications on the issues of interest regarding the processing of  his/her personal data by contacting the Operator via e-mail at support@nagornyi.su. 

14.2. This document will reflect any changes to the Operator’s personal data processing policy.  The Policy is valid indefinitely until it is replaced by a new version. 

14.3. The current version of the Policy is freely available on the Internet at  https://nagornyi.su/privacy.

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