Data Processing Policy
1. General Provisions
This personal data processing policy is formulated 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 defines the procedure for processing personal data and the measures for ensuring the security of personal data undertaken by Svet Alexandr (hereinafter referred to as the Operator).
1.1. The Operator sets compliance with the rights and freedoms of individuals as its paramount goal and condition for carrying out its activities in processing their personal data, including protecting 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 svet.pl/.
2. Key Concepts 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 the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, providing their availability on the Internet at the network address svet.pl/.
2.4. Personal data information system — a set of personal data contained in databases and providing their processing using information technology and technical means.
2.5. Depersonalization of personal data — actions resulting in the impossibility of identifying the belonging of personal data to a specific User or other personal data subject without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person, 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 subject to processing, actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to a specific or determinable User of the website svet.pl/.
2.9. Personal data permitted for distribution by the personal data subject — personal data access to which is provided by the personal data subject to an unlimited circle of persons by giving consent to the processing of personal data permitted for distribution by the personal data subject in the manner provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website svet.pl/.
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 acquainting an unlimited number of persons with personal data, including the disclosure of personal data in the media, placement in 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 the authority of a foreign state, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
3. Main Rights and Duties of the Operator
3.1. The Operator has the right to:
— Receive accurate information and/or documents containing personal data from the data subject;
— In case of withdrawal by the data subject of consent to the processing of personal data, as well as the submission of a request to cease the processing of personal data, the Operator may continue processing personal data without the consent of the data subject if there are grounds specified in the Law on Personal Data;
— Independently determine the composition and list of measures necessary and sufficient to ensure the performance of duties provided for by the Law on Personal Data and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator shall:
— Provide the data subject, upon his request, with information regarding the processing of his personal data;
— Organize the processing of personal data in accordance with the legislation of the Russian Federation;
— Respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— Provide the necessary information to the authorized body for the protection of the rights of data subjects upon the request of this body within 10 days from the date of receiving such request;
— Publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions with respect to personal data;
— Terminate the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided by the Law on Personal Data;
— Fulfill other obligations provided by the Law on Personal Data.
4. Main Rights and Duties of Data Subjects
4.1. Data subjects have the right to:
— Receive information regarding the processing of their personal data, except as provided by federal laws. Information is provided to the data subject by the Operator in an accessible form, and it should not contain personal data related to other data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Law on Personal Data;
— Demand from the operator clarification of his personal data, their blocking, or destruction in case the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— Require the operator to obtain 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 cease the processing of personal data;
— Appeal to the authorized body for the protection of the rights of data subjects or in court the illegal actions or inaction of the Operator in the processing of his personal data;
— Exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects shall:
— Provide the Operator with accurate information about themselves;
— Inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who provide the Operator with false information about themselves, or information about another data subject without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a legal and fair basis.
5.2. Processing of personal data is limited to achieving specific, pre-defined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of its processing are subject to processing.
5.5. The content and volume 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 allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the data subject, no longer than is required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, a contract, the party to which, the beneficiary, or the guarantor of which is the data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Personal data processing objectives
Processing purpose: informing the User by sending emails
Personal data:
— Last name, first name, patronymic (if applicable)
— Email address
— Phone numbers
Legal grounds:
Contracts concluded between the controller and the personal data subject
Types of personal data processing:
Sending informational emails to the email address
7. Conditions for processing personal data
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or the law, for the performance of the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority or official that must be enforced 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, where the personal data subject, the beneficiary, or the guarantor is a party to the contract, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract where the personal data subject will be the beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out for personal data that are publicly available, with unrestricted access granted by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure is carried out in accordance with federal law.
8. Procedure for collecting, storing, transmitting, and other types of processing of personal data
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 the current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. User’s personal data will never be transferred to third parties under any circumstances, except in cases related to the performance of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address alexandr.svet.pl@gmail.com with the subject "Updating personal data."
8.4. The processing period of personal data is determined by the achievement of the purposes for which personal data were collected unless another period is provided by the contract or applicable law.
The user can revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address alexandr.svet.pl@gmail.com with the subject "Revocation of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Prohibitions on the transfer (except for providing access), processing, or processing conditions (except for obtaining access) of personal data, permitted for dissemination, do not apply in cases of processing personal data in the interests of the state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, or by a party to the contract, the beneficiary, or guarantor of which is the personal data subject.
8.9. The termination of processing personal data may occur upon the achievement of the purposes of processing personal data, expiration of the consent period of the personal data subject, revocation of consent by the personal data subject, or upon the request to terminate the processing of personal data, as well as upon the detection of unlawful processing of personal data.
9. List of actions performed by the Operator with the personal data received
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without them.
10. Cross-border transfer of personal data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from the authorities of the foreign state, 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 access to personal data are obliged not to disclose personal data 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 explanations on issues of interest related to the processing of their personal data by contacting the Operator via email at alexandr.svet.pl@gmail.com.
12.2. Any changes to the policy of processing personal data by the Operator 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 https://svet.pl/privacy/.