Personal Data Processing Policy1. General Provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006. № 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for personal data processing and measures to ensure the security of personal data taken by IP Bronina Karina Dmitrievna (hereinafter — Operator).
1.1. Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of individuals and citizens during the processing of their personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This policy Operatorregarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that Operator may obtain about visitors to the website https://guruai.space.
2. Key Definitions, used in the Policy
2.1. Automated Processing of Personal Data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary for clarifying personal data).
2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://guruai.space.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without additional information, to which specific User or other personal data subject the personal data belongs.
2.6. Personal Data Processing — any action (operation) or set of actions (operations) performed with or without automation tools on 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 government body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or carries out personal data processing, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal Data — any information relating directly or indirectly to a specific or identifiable User of the website https://guruai.space.
2.9. Personal Data Permitted for Distribution by the Personal Data Subject — personal data to which an unlimited number of persons are granted access by the personal data subject through giving consent for processing of personal data permitted for distribution by the personal data subject in the manner prescribed by the Personal Data Law (hereinafter — Personal Data Permitted for Distribution).
2.10. User — any visitor to the website https://guruai.space.
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 familiarizing an unlimited number of persons with personal data, including publishing personal data in mass media, posting on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irretrievably destroyed with no possibility of further recovery of the personal data content in the personal data information system and/or physical media of personal data is destroyed.
3. Main Rights and Obligations of the Operator
3.1. Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, as well as in the event of a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. Operator is obligated to:
— provide the personal data subject, upon their request, with information concerning the processing of their personal data;
— to organize personal data processing in accordance with the procedure established by current Russian legislation;
— to respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to report to the authorized body for the protection of personal data subjects' rights upon request of this body the necessary information within 10 days from the date of receiving such request;
— to publish or otherwise ensure unlimited access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with respect to personal data;
— to cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— to fulfill other obligations provided by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— to receive information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the personal data subject Operatoror in an accessible form, and they must not contain personal data relating to other personal data subjects, except in cases where there are legitimate 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 their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— require prior consent as a condition for processing personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to personal data processing, as well as to send a demand for cessation of personal data processing;
— to appeal to the authorized body for the protection of personal data subjects' rights or in court against unlawful actions or inaction of Operatoror when processing their personal data;
— to exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obligated to:
— provide Operatorreliable data about themselves;
— notify the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who transmitted Operatorunreliable information about themselves or information about another personal data subject without the latter's consent bear responsibility in accordance with Russian legislation.
5. Principles of Personal Data Processing
5.1. Personal Data Processing is carried out on a lawful and fair basis.
5.2. Personal Data Processing is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not permitted.
5.6. During personal data processing, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of personal data processing are ensured. Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of processing purposes or if the need to achieve those purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
- Processing purposeinforming the User by sending emailsPersonal Datasurname, first name, patronymic
- email address
- phone numbers
- Legal GroundsFederal Law "On Information, Information Technologies, and Information Protection" dated July 27, 2006 N 149-FZ
- Types of Personal Data ProcessingCollection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
- Sending informational emails to the email address
7. Conditions for Personal Data Processing
7.1. Personal Data Processing is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. Personal Data Processing is necessary for achieving goals provided for by an international treaty of the Russian Federation or by law, for the exercise of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal Data Processing is necessary for the administration of justice, the enforcement of a judicial act, an act of another body, or an official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal Data Processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding 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.
7.5. Personal Data Processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter referred to as publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by Operatoror is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal Data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of applicable law or if the personal data subject has given consent to the Operator for the transfer of data to a third party for fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the email address info@vitarum.net with the note "Personal Data Update".
8.4. The term of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different term is provided for by a contract or applicable legislation.
The User may withdraw their consent to personal data processing at any time by sending Operatora notification via email to the email address info@vitarum.net with the note "Withdrawal of Consent for Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by said parties (Operatorors) in accordance with their Terms of Service and Privacy Policy. The personal data subject and/or with the specified documents. Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. Operator ensures the confidentiality of personal data during personal data processing.
8.8. Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. A condition for the cessation of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or demand for cessation of personal data processing, as well as identification of unlawful personal data processing.
9. List of actions performed by Operatoror with the obtained personal data
9.1. Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. Operator carries out automated processing of personal data with receipt and/or transfer of obtained information via information and telecommunication networks or without such.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is submitted separately from notification of intention to carry out personal data processing).
10.2. Prior to the submission of the above-mentioned notification, the Operator is required to obtain from the authorities of the foreign state, foreign natural persons, and foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
Operator and other persons who have gained access to personal data are obligated not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on questions regarding the processing of their personal data by contacting the Operator via email at info@vitarum.net.
12.2. This document will reflect any changes to the personal data processing policy of Operatoror. The Policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://guruai.space/privacy.