1. 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 “On Personal Data” (hereinafter — the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Individual Entrepreneur Maksim Petrovich Bradarsky (hereinafter — the “Operator”). 1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy and personal and family secrecy, to be its most important goal and a condition for carrying out its activities. 1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the “Policy”) applies to all information that the Operator may obtain about users of the Operator’s services and visitors of the website https://janraw.com.
2. KEY 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 suspension of personal data processing (except where processing is necessary to clarify personal data). 2.3. Website — a set of graphic and informational materials, as well as software and databases ensuring their availability on the Internet at the following address: https://janraw.com. 2.4. Personal data information system — a set of personal data contained in databases, as well as information technologies and technical means ensuring their processing. 2.5. Anonymization of personal data — actions resulting in the impossibility of determining, without the use of additional information, whether personal data belongs 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 the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data. 2.7. Operator — a legal entity or individual that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the scope 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 an identified or identifiable User of the website https://janraw.com, as well as to a Customer of the Operator’s services. 2.9. Personal data permitted for distribution — personal data to which access is granted to an unlimited number of persons by the Personal Data Subject through consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter — personal data permitted for distribution). 2.10. User — any visitor of the website https://janraw.com. 2.11. Customer — a person who has made a prepayment and/or payment for the Operator’s services. 2.12. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons. 2.13. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access in any other way. 2.14. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual, or foreign legal entity. 2.15. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of their content in the personal data information system and/or destruction of physical media containing personal data.
3. MAIN RIGHTS AND OBLIGATIONS OF THE OPERATOR 3.1. The Operator has the right to:
obtain accurate information and/or documents containing personal data from the Personal Data Subject;
in the event that the Personal Data Subject withdraws consent to the processing of personal data, as well as submits a request to terminate the processing of personal data, continue processing personal data without the consent of the Personal Data Subject if there are legal grounds specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise предусмотрено by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
provide the Personal Data Subject, upon request, with information regarding the processing of their personal data;
organize the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
respond to requests and inquiries from Personal Data Subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
provide the authorized body for the protection of the rights of Personal Data Subjects, upon request, with the necessary information within 30 days from the date of receipt of such request;
publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions with respect to personal data;
terminate the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and in cases предусмотренных by the Personal Data Law;
fulfill other obligations provided for by the Personal Data Law.
4. MAIN RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS 4.1. Personal Data Subjects have the right to:
receive information regarding the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in textual form and must not contain personal data relating to other Personal Data Subjects, except where there are legal grounds for the disclosure of such personal data. The scope of information and the procedure for obtaining it are established by the Personal Data Law;
require the Operator to clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take measures предусмотренные by law to protect their rights;
require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
withdraw consent to the processing of personal data, as well as submit a request to terminate the processing of personal data;
exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal Data Subjects are obliged to:
provide the Operator with accurate information about themselves;
notify the Operator of any clarification (update, modification) of their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another Personal Data Subject 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. Personal data shall be processed on a lawful and fair basis. 5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not permitted. 5.3. The consolidation of databases containing personal data processed for incompatible purposes is not permitted. 5.4. Only personal data that meets the purposes of its processing shall be processed. 5.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted. 5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures, and/or ensure their adoption, to delete or clarify incomplete or inaccurate data. 5.7. Personal data shall be stored in a form that permits identification of the Personal Data Subject for no longer than is required for the purposes of personal data processing, unless the storage period is established by federal law or by a contract to which the Personal Data Subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or in the event that such purposes are no longer required, unless otherwise provided by federal law.
6. PURPOSES OF PERSONAL DATA PROCESSINGPurpose of processing:
conclusion, performance, and termination of civil law contracts;
clarification and discussion of order details.
Personal data processed:
surname, first name, and patronymic;
email address;
phone numbers;
year, month, date, and place of birth;
photographs;
document details;
taxpayer identification number, date of registration, and registration certificate details with the tax authority;
mandatory pension insurance certificate number, registration date in the pension insurance system;
mandatory health insurance policy number.
Legal grounds:
the Operator’s charter (founding) documents;
contracts concluded between the Operator and the Personal Data Subject.
Types of personal data processing:
collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data;
sending informational emails to the email address provided;
carrying out other forms of communication via third-party information resources and systems.
7. CONDITIONS OF PERSONAL DATA PROCESSING 7.1. Personal data processing is considered consented to by the Personal Data Subject and is carried out from the moment the Personal Data Subject submits their personal data for processing. 7.2. The processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or to exercise functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation. 7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or execution of an act by another authority or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings. 7.4. The processing of personal data is necessary for the performance of a contract, including discussion and adjustment of contract execution details by a party, beneficiary, or guarantor to the contract involving the Personal Data Subject, as well as for the conclusion of a contract at the initiative of the Personal Data Subject or a contract in which the Personal Data Subject will be a beneficiary or guarantor. 7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the Personal Data Subject are not violated. 7.6. The processing of personal data is carried out for publicly available personal data, to which unrestricted access has been provided by the Personal Data Subject or at their request. 7.7. The 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 the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection. 8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data. 8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the Personal Data Subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract. 8.3. In the event of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address at mailorefurtune@gmail.com with the mandatory subject line: “Personal Data Update.” 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 by contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator’s email at mailorefurtune@gmail.com with the mandatory subject line: “Withdrawal of Consent to 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 such parties in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause. 8.6. Restrictions established by the Personal Data Subject on the transfer (except for providing access) or processing conditions (except for access) of personal data allowed for dissemination do not apply in cases of processing personal data in the state, public, or other public interests as determined by the legislation of the Russian Federation. 8.7. The Operator ensures the confidentiality of personal data during processing. 8.8. The Operator stores personal data in a form that allows identification of the Personal Data Subject for no longer than is required for the purposes of personal data processing, unless the storage period is established by federal law or by a contract to which the Personal Data Subject is a party, beneficiary, or guarantor. 8.9. The publication and storage of photo and video reports of services provided by the Operator are considered consented to by the Personal Data Subject from the moment of prepayment and/or payment for such services. 8.10. The condition for terminating the processing of personal data is the withdrawal of consent by the Personal Data Subject or a request to terminate personal data processing.
9. LIST OF ACTIONS PERFORMED BY THE OPERATOR WITH RECEIVED PERSONAL DATA9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data. 9.2. The Operator carries out automated processing of personal data, including receiving and/or transmitting the obtained information via information and telecommunication networks or without such networks. 9.3. The Operator informs the audience of the resource https://janraw.com by publishing photo and video materials of the services provided to the Personal Data Subject.
10. CROSS-BORDER TRANSFER OF PERSONAL DATA10.1. Before commencing cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of Personal Data Subjects’ rights of its intention to carry out cross-border transfer of personal data (such notification is submitted separately from the notification of the intention to process personal data). 10.2. Prior to submitting the above notification, the Operator is obliged to obtain from the authorities of a foreign state, foreign individuals, and foreign legal entities, to whom the cross-border transfer of personal data is planned, the relevant information.
11. CONFIDENTIALITY OF PERSONAL DATAThe Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the Personal Data Subject, unless otherwise provided by federal law.
12. FINAL PROVISIONS12.1. The User may obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at mailorefurtune@gmail.com. 12.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version. 12.3. The current version of the Policy is freely available online at the following address: https://janraw.com/pdpp.