Personal data processing policy

1. General terms

This Personal data processing policy is prepared in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter the "Personal Data Law") and determines the personal data processing procedure and the measures taken to ensure the security of personal data, undertaken by Zavyalova Margarita Borisovna (hereinafter the "Operator").

1.1. The Operator's most important objective and condition for implementation of activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family confidentiality.

1.2. This Operator's Personal data processing policy (the "Policy") applies to all information that the Operator may receive about visitors to the website https://mzavyalova.com .

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data by means of computer technology.

2.2. Locking of personal data - temporary suspension of processing of personal data (unless the processing is necessary to clarify the personal data).

2.3. A website - a collection of graphic and informational content, as well as computer programs and databases, making them available on the Internet at a network address https://mzavyalova.com .

2.4. Personal data information system - a set of personal data contained in databases of personal data, and information technology and technical means ensuring its processing.

2.5. Depersonalisation of personal data - actions that make it impossible to determine, without the use of additional information, whether the personal data belongs to a specific user or another subject of personal data.

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

2.7. An operator – a state body, municipal authority, legal entity or individual who arranges and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, composition of personal data to be processed, actions (operations) performed with personal data on his/her own or jointly with other persons.

2.8. Personal data – any information relating directly or indirectly to an identified or identifiable user of the website https://mzavyalova.com .

2.9. Personal data permitted to be distributed by the data subject - personal data to which (unrestricted) access has been granted by the Subject of personal data by giving consent to the processing of personal data authorized by the Subject of personal data for dissemination in the manner prescribed by the Personal Data Act (hereinafter personal data authorized for dissemination).

2.10. A user – any visitor to the website https://mzavyalova.com .

2.11. Providing 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 disclosure of personal data to an indefinite number of persons (transfer of personal data) or to make personal data available to an unlimited number of persons, including the publication of personal data in the media, posting on 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 a foreign country to a foreign authority, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data – actions, as a result of which personal data is destroyed irretrievably, making it impossible to further restore the content of personal data in the personal data information system and (or) material media of personal data is destroyed.

3. Fundamental Rights and Obligations of the Operator

3.1. The Operator has the right to:

– receive accurate information and/or documents containing personal data from the Subject of personal data;

– (if the Subject of personal data has withdrawn his or her consent to the processing of personal data) continue processing personal data without the consent of the Subject of personal data on the grounds set out in the Personal Data Act;

– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under 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 Subject of personal data, at his or her request, with information relating to the processing of his or her personal data;

– organize the processing of personal data in accordance with the procedure laid down in the applicable legislation of the Russian Federation;

– respond to requests and enquiries from the Subject of personal data and his/her legal representatives in accordance with the requirements of the Personal Data Law;

– provide the competent authority for the protection of the Subject of personal data with the necessary information on request from that authority within 30 days of receiving such a request;

– publish or otherwise provide unrestricted access to this Personal data processing policy;

– take legal, organizational and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as against other unlawful acts related to personal data;

– stop the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for in the Personal Data Act;

– perform other obligations as set out in the Personal Data Act.

4. Basic rights and obligations of subjects of personal data

4.1. The Subject of personal data has the right to:

– receive information concerning the processing of his/her personal data, except in cases prescribed by federal laws. Information is provided to the Subject of personal data by the Operator in an accessible form and must not contain personal data relating to other Subjects of personal data, unless there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is set out in the Personal Data Act;

– demand that the Operator clarify, lock or destroy personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and to take statutory measures to protect their rights;

– condition prior consent when processing personal data for the purpose of promoting goods, works and services;

– to withdraw consent to the processing of personal data;

– appeal to the competent authority for the protection of the rights of Subjects of personal data or to a court against illegal actions or omissions of the Operator in the processing of his/her 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 information about himself/herself;

– notify the Operator of updates/changes to his/her personal data.

4.3. An individual who provided the Operator with false information about himself/herself or information about another Subject of personal data without his/her consent shall be liable in accordance with the law of the Russian Federation.

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

5.1. First name, last name, father's name.

5.2. E-mail address.

5.3. Telephone numbers.

5.4. Date and place of birth.

5.5. Photographs.

5.6. Personal data.

5.7. The website also collects and processes anonymised visitor data (including cookies) using internet statistics services (Yandex Metrika, Google Analytics and others).

5.8. All the above-mentioned data hereinafter are referred to as "Personal data".

5.9. The Operator does not process special categories of personal data relating to race, ethnicity, political opinions, religious or philosophical beliefs or intimate life.

5.10. The processing of personal data, authorized for dissemination, from the special categories of personal data specified in Article 10.1 of the Personal Data Law shall be permitted if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are complied with.

5.11. The User's consent to the processing of personal data authorized for dissemination shall be formalized separately from other consents to the processing of his/her personal data. The conditions stipulated, in particular, in Article 10.1 of the Personal Data Act shall be complied with. The requirements for the content of such consent shall be established by the competent authority for the protection of the Subject of personal data rights.

5.11.1 Consent to the processing of personal data authorized for dissemination is given by the User directly to the Operator.

5.11.2 The Operator is obliged, within three working days of receiving the above-mentioned consent from the User, to publish information about the processing conditions, prohibitions and conditions on the processing of personal data allowed for distribution to an unlimited number of persons.

5.11.3 The transfer (dissemination, provision, access) of personal data authorized by the Subject of personal data for dissemination must be stopped at any time at the request of the Subject of personal data. This requirement must include first name, last name, father's name (if available), contact information (telephone number, e-mail address or postal address) of the Subject of personal data, as well as a list of personal data processing of which is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is sent.

5.11.4 Consent to the processing of personal data authorized for dissemination shall terminate upon receipt by the Operator of the request referred to in Paragraph 5.11.3 of this Personal data processing policy.

6. Principles of personal data processing

6.1. Personal data processing is carried out on a legitimate and equitable basis.

6.2. Personal data processing is limited to achieving specific, predetermined and legitimate objectives. Processing of personal data that is incompatible with the purpose of personal data collection is not permitted.

6.3. Databases containing personal data processing of which is incompatible with one another may not be merged.

6.4. Only personal data that meet the purposes of processing shall be processed.

6.5. The content and scope of personal data processed corresponds to the stated processing purposes. Personal data processed shall not be excessive in relation to the stated processing purposes.

6.6. When processing personal data, it is ensured that the personal data is accurate, sufficient and, where necessary, up-to-date in relation to the purposes of personal data processing. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.

6.7. Personal data shall be stored in a form that makes it possible to identify the Subject of personal data for no longer than the purpose of personal data processing requires, unless the storage period of personal data is established by federal law, an agreement to which the Subject of personal data is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalized when the purposes of processing have been achieved or when it is no longer necessary to achieve those purposes, unless otherwise provided for by federal law.

7. Purposes of personal data processing

7.1. Purpose of personal data processing:

– informing the User by sending emails;

– the conclusion, performance and termination of civil law contracts;

– providing the User with access to the services, information and/or materials contained on the website https://mzavyalova.com .

7.2. The Operator is also entitled to send the User notifications of new products and services, special offers and various events. The User can always opt out of receiving information messages by sending an email marked "Opt-out of notifications of new products, services and special offers" to the Operator (mz@ib.msk.ru ).

7.3. The anonymised User data collected through Internet statistical services is used to collect information about Users' activities on the website and to improve the quality of the website and its content.

8. Legal basis for personal data processing

8.1. The legal basis for the processing of personal data by the Operator is:

– contracts concluded between the Operator and the Subject of personal data;

– federal laws and other regulations on personal data protection;

– Users' consent to the processing of their personal data, to the processing of personal data authorized for dissemination.

8.2. The Operator only processes the User's personal data if they are filled in and/or submitted by the user via special forms on the website https://mzavyalova.com or sent to the Operator by email. By completing 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 anonymised data about the User if the User's browser settings allow it (cookie saving and the use of JavaScript technology are enabled).

8.4. The Subject of personal data decides for himself/herself to provide his/her personal data and gives consent freely, of his/her own free will and in his/her own interest.

9. Terms and conditions for the processing of personal data

9.1. Processing of personal data is subject to the Subject of personal data consent to the processing of his/her personal data.

9.2. The processing of personal data is necessary in order to achieve the purposes set out in an international treaty of the Russian Federation or by law, to carry out the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.

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

9.4. The processing of personal data is necessary in order to fulfill an agreement to which the Subject of personal data is a party or a beneficiary or guarantor, as well as to conclude an agreement at the initiative of the Subject of personal data or an agreement under which the Subject of personal data will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and lawful interests of the Operator or third parties or to achieve socially important objectives, provided that the rights and freedoms of the Subject of personal data are not infringed thereby.

9.6. Personal data to which the Subject of personal data has granted access to an unlimited number of persons or at his or her request has been made available (hereinafter, "publicly accessible personal data") shall be processed.

9.7. Personal data that is subject to publication or compulsory disclosure under federal law is processed.

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

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

10.1. The Operator ensures the security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

10.2. The personal data of the User will never, under any circumstances, be disclosed to third parties, except in cases related to the implementation of current legislation or if the Subject of personal data has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.

10.3. If inaccuracies in the personal data are identified, the User can update the personal data by sending a notification marked "Update of personal data" to the Operator's email address: mz@ib.msk.ru .

10.4. The time period for processing personal data is determined by achieving the purposes for which the personal data were collected, unless a different time period is stipulated by contract or applicable law.

The User may withdraw his or her consent to the processing of personal data at any time by sending the Operator an e-mail-notification marked "Withdrawal of consent to the processing of personal data" to the Operator's email address: mz@ib.msk.ru .

10.5. All information collected by third party services, including payment systems, communication facilities and other service providers, is stored and processed by these parties (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 these documents in a timely manner. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.

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

10.7. The Operator ensures the confidentiality of personal data when processing personal data.

10.8. The Operator shall store personal data in a form that makes it possible to identify the Subject of personal data no longer than the purposes of personal data processing require, unless the period of storage of personal data is established by federal law, an agreement to which the Subject of personal data is a party, a beneficiary or a guarantor.

10.9. A condition for the termination of personal data processing may be the achievement of the personal data processing objectives, the expiry of the Subject of personal data consent or withdrawal of consent by the Subject of personal data, as well as the discovery of illegitimate personal data processing.

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

11.1. The Operator collects, records, systematize, collects, stores, clarifies (updates, changes), extracts, uses, transmits (distributes, provides, access), anonymises, blocks, deletes and destroys personal data.

11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunication networks.

12. Cross-border transfer of personal data

12.1. Before cross-border transfer of personal data, the Operator must ensure that the foreign country to whose territory the transfer of personal data is to take place provides adequate protection of the rights of the Subject of personal data.

12.2. The cross-border transfer of personal data to foreign countries that do not meet the above-mentioned requirements may only be carried out with the written consent of the Subject of personal data for the cross-border transfer of his/her personal data and/or the performance of the agreement to which the Subject of personal data is a party.

13. Privacy of personal data

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

14. Concluding provisions

14.1. The User can obtain any clarification of questions regarding the processing of their personal data by contacting the Operator by email: mz@ib.msk.ru .

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

14.3. The current version of the Policy is freely available on the Internet at: https://mzavyalova.com.