PRIVACY POLICY

1. GENERAL PROVISIONS

This Personal Data Processing Policy has been drafted 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 establishes the procedure for processing personal data and measures to ensure the security of personal data undertaken by Yulia Alekseevna Timofeeva (hereinafter referred to as the "Operator").
1.1. The Operator's paramount goal and condition for carrying out its activities is the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Operator's Policy 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://esc-moscow.ru.

2. BASIC TERMS USED IN THE POLICY

2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of 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 programs and databases, ensuring their availability on the internet at the network address https://esc-moscow.ru.
2.4. Personal data information system – a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and 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 carrying out the processing of personal data, as well as determining the purposes of processing personal data, 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 a specific or identifiable User of the website https://esc-moscow.ru.
2.9. Personal data permitted for distribution by the subject of personal data – personal data to which an unlimited circle of persons has been granted access by the subject of personal data by giving consent to the processing of personal data permitted for distribution by the subject of personal data in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").
2.10. User – any visitor to the website https://esc-moscow.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including publishing personal data in the media, posting them in information and telecommunications 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 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 are irrevocably destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.

3. MAIN RIGHTS AND OBLIGATIONS OF THE OPERATOR

3.1. The Operator has the right:

• to receive from the subject of personal data accurate information and/or documents containing personal data;
• if the subject of personal data withdraws consent to the processing of personal data, as well as upon receiving a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
• to 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 regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged:

• to provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
• to organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• to respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
• to notify the authorized body for the protection of the rights of subjects of personal data, upon request of that body, of the necessary information within 10 days from the date of receipt of such request;
• to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, 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 for by the Personal Data Law;
• to perform other duties provided for by the Personal Data Law.

4. MAIN RIGHTS AND OBLIGATIONS OF SUBJECTS OF PERSONAL DATA

4.1. Subjects of personal data have the right:

• to receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, 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 require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
• to impose a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services;
• to withdraw consent to the processing of personal data, as well as to submit a request to cease processing of personal data;
• to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when processing their personal data;
• to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged:

• to provide the Operator with accurate data about themselves;
• to inform the Operator of the clarification (updating, change) of their personal data.

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

5. PRINCIPLES OF PERSONAL DATA PROCESSING

5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data that are processed for purposes incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of their processing may be processed.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the subject of personal data for no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or in the event of the loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. PURPOSES OF PERSONAL DATA PROCESSING


7. CONDITIONS FOR PROCESSING PERSONAL DATA

7.1. Processing of personal data is carried out with the consent of the subject of personal data 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, 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, the execution of a judicial act, 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 subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data 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 subject of personal data are not violated.
7.6. Processing of personal data to which access by an unlimited circle of persons is provided by the subject of personal data 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 PROCESSING OF PERSONAL DATA

8.1. The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.2. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.3. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or where the subject of personal data has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.4. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator's email address pinklark@mail.ru marked "Updating Personal Data."
8.5. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or current legislation. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at pinklark@mail.ru marked "Withdrawal of Consent to Processing of Personal Data."
8.6. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data shall familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.7. Prohibitions established by the subject of personal data 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.
8.8. When processing personal data, the Operator ensures the confidentiality of personal data.
8.9. The Operator stores personal data in a form that allows the identification of the subject of personal data for no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.10. Grounds for terminating the processing of personal data may include the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a request to cease processing personal data, as well as the detection of unlawful processing of personal data.

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

9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, 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 the obtained information via information and telecommunications networks.

10. CROSS-BORDER TRANSFER OF PERSONAL DATA

10.1. Before commencing activities on the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.

11. CONFIDENTIALITY OF PERSONAL DATA

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

12. FINAL PROVISIONS

12.1. The User may obtain any clarification on questions regarding the processing of their personal data by contacting the Operator via email at pinklark@mail.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 replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at: esc-moscow.ru.НЫХ