This is an English translation of the Russian version of this policy: fotograf-alanya.ru/policy.1. General provisionsThis personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the Personal Data Law) and sets out the procedure for processing personal data and the measures to ensure the security of personal data taken by FOTOGRAF ALANYA (hereinafter, the Operator).
1.1. The Operator’s most important goal and condition for carrying out its activities is respect for human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and to personal and family secrets.
1.2. This Operator’s policy on personal data processing (hereinafter, the Policy) applies to all information that the Operator may receive about visitors to the website https://fotograf-alanya.ru/.
2. Basic terms used in the Policy2.1. 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 set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the internet at https://fotograf-alanya.ru/.
2.4. Personal data information system — a set of personal data contained in databases, together with the information technologies and technical means ensuring their processing.
2.5. Depersonalisation of personal data — actions as a result of which it is impossible, without using additional information, to determine whether personal data belong to a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with other persons, organises and/or carries out the processing of personal data and determines the purposes of processing, the composition of the 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://fotograf-alanya.ru/.
2.9. Personal data permitted by the data subject for distribution — personal data to which the data subject has given access to an unlimited number of persons by consenting to the processing of personal data permitted for distribution in the manner provided for by the Personal Data Law (hereinafter, personal data permitted for distribution).
2.10. User — any visitor to the website https://fotograf-alanya.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in the media, posting 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 state, to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, with no possibility of restoring the content of the personal data in the personal data information system, and/or the material media of the personal data are destroyed.
3. Basic rights and obligations of the Operator3.1. The Operator has the right:
— to receive reliable information and/or documents containing personal data from the personal data subject;
— if the data subject withdraws consent to the processing of personal data or sends a request to stop processing personal data, to continue processing personal data without the consent of the data subject where there are grounds specified in the Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged:
— to provide the personal data subject, at their request, with information concerning the processing of their personal data;
— to organise the processing of personal data in the manner established by the current legislation of the Russian Federation;
— to respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to provide the authorised body for the protection of the rights of personal data subjects, at its request, with the necessary information within 10 days of receiving such a request;
— to publish or otherwise ensure unrestricted access to this Policy on personal data processing;
— to take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision or distribution, as well as from other unlawful actions in relation to personal data;
— to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to fulfil other obligations provided for by the Personal Data Law.
4. Basic rights and obligations of personal data subjects4.1. Personal 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 is provided to the data subject by the Operator in an accessible form and must 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;
— to demand that the Operator clarify, block or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
— to require prior consent when personal data are processed for the purpose of promoting goods, works and services on the market;
— to withdraw consent to the processing of personal data and to send a request to stop processing personal data;
— to appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorised body for the protection of the rights of personal data subjects or in court;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
— to provide the Operator with reliable information about themselves;
— to inform the Operator about the clarification (updating, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing5.1. Personal data are processed on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Processed personal data must not be excessive in relation to the stated purposes of their processing.
5.6. When processing personal data, the accuracy and sufficiency of the personal data and, where necessary, their relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalised once the purposes of processing have been achieved or if there is no longer a need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of personal data processingPurpose of processing: informing the User by sending emails
Personal data: phone numbers, name
Legal grounds: contracts concluded between the Operator and the personal data subject
Types of personal data processing: collection, recording, systematisation, accumulation, storage, destruction and depersonalisation of personal data
7. Conditions for processing personal data7.1. Personal data are 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 imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice and the execution of a judicial act or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation 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 concluding 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 to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data are processed to which the data subject has given access to an unlimited number of persons, or at their request (hereinafter, publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.
8. Procedure for collection, storage, transfer and other types of personal data processingThe security of personal data processed by the Operator is ensured through legal, organisational and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of current legislation or where the data subject has consented to the Operator transferring the data to a third party in order to fulfil obligations under a civil law contract.
8.3. If inaccuracies are found in the personal data, the User can update them by sending a notice to the Operator’s email address info@fotograf-alanya.ru marked “Updating personal data”.
8.4. 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 provided for by a contract or current legislation.
The User may withdraw consent to the processing of personal data at any time by sending a notice by email to the Operator’s email address info@fotograf-alanya.ru marked “Withdrawal of consent to the processing of personal data”.
8.5. All information 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 Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public and other public interests determined 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 the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.
8.9. Processing of personal data may be terminated when the purposes of processing have been achieved, the data subject’s consent has expired, consent has been withdrawn by the data subject or a request to stop processing has been received, or unlawful processing of personal data has been identified.
9. List of actions performed by the Operator with the personal data received9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, gives access to), depersonalises, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the information obtained via information and telecommunication networks.
10. Cross-border transfer of personal data10.1. Before starting cross-border transfers of personal data, the Operator is obliged to notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data (such notice is sent separately from the notice of intention to process personal data).
10.2. Before submitting the above notice, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal dataThe Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties or distribute them without the consent of the data subject, unless otherwise provided by federal law.
12. Final provisions12.1. The User can obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator by email at info@fotograf-alanya.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://fotograf-alanya.ru/policy (in Russian); this English translation is available at https://fotograf-alanya.ru/en-privacy.