Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by Sokolova Alexandra Alexandrovna (hereinafter referred to as the "Operator").
1.1. The Operator considers the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.
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://Adaptly.org.
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 cessation of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website – a collection of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://Adaptly.org.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means enabling their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility of determining, without additional information, the affiliation of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual, independently or jointly with others, 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 directly or indirectly related to a specific or identifiable User of the website https://Adaptly.org.
2.9. Personal data permitted for dissemination – personal data to which an unlimited number of persons have access, granted by the subject of personal data by consenting to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any visitor to the website https://Adaptly.org.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including publishing personal data in the media, posting on 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 a foreign authority, 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 physical media containing personal data.
3. Key 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 or submits a request to cease processing personal data, the Operator may continue processing personal data without the subject’s consent if there are grounds specified in the Personal Data Law;
– Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and relevant regulatory legal acts, 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 request, with information regarding the processing of their personal data;
– Organize the processing of personal data in accordance with the current 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;
– Notify the authorized body for the protection of personal data subjects’ rights, upon request, of the necessary information within 10 days from the date of receiving such a request;
– Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
– Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, or other unlawful actions regarding personal data;
– Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
– Fulfill other obligations stipulated by the Personal Data Law.
4. Key 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 by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other subjects, except when 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;
– Require the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, as well as take legal measures to protect their rights;
– Impose a condition of prior consent when processing personal data for marketing goods, works, or services;
– Withdraw consent to the processing of personal data and submit a request to cease processing personal data;
– Appeal to the authorized body for the protection of personal data subjects’ rights or in court against unlawful actions or inaction of the Operator regarding the processing of their personal data;
– Exercise other rights provided 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 updates or changes to 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 bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing personal data incompatible with the purposes of collection is not permitted.
5.3. Merging databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the purposes of processing is subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data relative to the stated purposes is not permitted.
5.6. The processing of personal data ensures accuracy, sufficiency, and, where necessary, relevance to the purposes of processing. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form allowing identification of the subject for no longer than required by the processing purposes, unless the storage period is established by federal law, a contract, or if the subject is a beneficiary or guarantor under such a contract. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or when the necessity for achieving these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Informing the User via email.
Personal data:
– Last name, first name, patronymic;
– Email address;
– Phone numbers;
– City/University.
Legal basis: Federal Law No. 152 "On Personal Data."
Types of personal data processing:
– Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data;
– 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 subject to the processing of their personal data.
7.2. Processing is necessary to achieve the purposes stipulated by an international treaty or law, to perform functions, powers, or duties imposed on the Operator by Russian legislation.
7.3. Processing is necessary for the administration of justice, execution of a judicial act, or an act of another authority subject to execution under Russian legislation on enforcement proceedings.
7.4. Processing is necessary to perform a contract where the subject is a party, beneficiary, or guarantor, or to conclude a contract initiated by the subject or where the subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and lawful interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject are not violated.
7.6. Processing involves personal data made publicly available by the subject or at their request (hereinafter referred to as "publicly available personal data").
7.7. Processing involves personal data subject to publication or mandatory disclosure under federal law.
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 legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on 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. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases required by law or when the subject has consented to the transfer to a third party to fulfill obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by notifying the Operator via email at potapova.alx@gmail.com with the subject line "Updating Personal Data."
8.4. The processing period for personal data is determined by the achievement of the purposes for which the data was collected, unless otherwise stipulated by contract or law.
The User may withdraw consent to the processing of personal data at any time by notifying the Operator via email at potapova.alx@gmail.com with the 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 these parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for reviewing these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6. Prohibitions imposed by the personal data subject on the transfer (except for granting access) or processing (except for obtaining access) of personal data permitted for dissemination do not apply in cases of processing in state, public, or other public interests as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form allowing identification of the subject for no longer than required by the processing purposes, unless the storage period is established by federal law or a contract where the subject is a party, beneficiary, or guarantor.
8.9. The cessation of personal data processing may occur upon achieving the processing purposes, expiration of the subject’s consent, withdrawal of consent, a request to cease processing, or the identification of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, 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 obtained information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intent to perform such transfer (this notification is submitted separately from any notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator must obtain relevant information from the foreign authorities, individuals, or legal entities to whom the cross-border transfer is planned.
11. Confidentiality 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 subject’s consent, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at potapova.alx@gmail.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy remains valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://Adaptly.org/privacy-en.