Privacy policy

Personal Data Processing Policy

General Provisions

This Personal Data Processing Policy is developed in accordance with the requirements of the 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 measures to ensure the security of personal data taken by individual entrepreneur Viktoria Borisovna Bukharkina (hereinafter referred to as the Operator).

1.1. The Operator’s most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals during the processing of their personal data, including the protection of the right to privacy, personal, and family secrets.
1.2. This Policy of the Operator 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 http://comsense.tilda.ws.

2. Key Terms Used in the Policy

2.1. Automated Processing of Personal Data – the processing of personal data using computing devices.
2.2. Blocking of Personal Data – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases that ensure their availability on the Internet at the network address http://comsense.tilda.ws.
2.4. Information System of Personal Data – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of Personal Data – actions that make it impossible to determine, without the use of additional information, the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of Personal Data – any action (operation) or set of actions (operations) performed with personal data, using or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a government body, municipal authority, legal or natural person, individually or in collaboration with other persons, organizing and/or carrying out personal data processing, as well as determining the purposes of personal data processing, the content of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal Data – any information related directly or indirectly to a specific or identifiable User of the website http://comsense.tilda.ws.
2.9. Personal Data Permitted by the Data Subject for Distribution – personal data to which access is granted to an unlimited number of individuals by the data subject through consent for the processing of personal data, as permitted by the data subject for distribution in accordance with the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User – any visitor to the website http://comsense.tilda.ws.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific individual or a specific group of individuals.
2.12. Distribution of Personal Data – any actions aimed at disclosing personal data to an undefined number of individuals (transfer of personal data) or making personal data available to an unlimited number of individuals, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border Transfer of Personal Data – the transfer of personal data to the territory of a foreign country to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or destruction of physical carriers of personal data.

3. Key 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 data subject;
— in the event of the data subject withdrawing consent for the processing of personal data, as well as submitting a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the data subject’s consent if there are grounds specified in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and the regulatory legal acts 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 data subject with information regarding the processing of their personal data upon request;
— organize the processing of personal data in accordance with the procedures established by the current legislation of the Russian Federation;
— respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— inform the authorized body for the protection of the rights of data subjects, upon its request, with the necessary information within 10 days from the date of receiving such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions concerning personal data;
— stop the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and in the cases specified in the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.

4. Key Rights and Obligations of Data Subjects

4.1. 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 data subject by the Operator in an accessible form and should not contain personal data related to other data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— request the operator to correct their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— require prior consent for the processing of personal data for the purpose of promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data and submit a request to stop the processing of personal data;
— appeal to the authorized body for the protection of the rights of data subjects or seek judicial review of unlawful actions or inaction by the Operator in processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— notify the Operator about the correction (update, modification) of their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves or about another data subject without their consent are liable 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, predefined, and lawful purposes. The processing of personal data incompatible with the purposes of their collection is not allowed.
5.3. The merging of databases containing personal data, where the processing of data is carried out for incompatible purposes, is prohibited.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of personal data being processed correspond to the stated purposes of processing. The processing of excessive personal data relative to the stated purposes is prohibited.
5.6. When processing personal data, accuracy, adequacy, and, when necessary, relevance to the processing goals are ensured. The Operator takes the necessary measures and/or ensures their implementation for the deletion or clarification of incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the data subject, for no longer than required by the purposes of processing, unless the storage period is determined by federal law, a contract, or other legal documents where the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or when there is no longer a need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: processing of requests and feedback
Personal data: email address, name
Legal basis: Federal Law “On Information, Information Technologies, and Information Protection” dated July 27, 2006, No. 149-FZ
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data

7. Conditions for Personal Data Processing

7.1. Personal data is processed with the consent of the data subject for the processing of their personal data.
7.2. The processing of personal data is necessary for achieving the purposes provided by an international treaty of the Russian Federation or law, for performing functions, powers, and obligations assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for administering justice, executing a judicial act, an act of another body or official that must be enforced in accordance with the Russian Federation’s legislation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract where the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Personal data processing is carried out for personal data to which unrestricted access has been granted by the data subject or at their request (hereinafter — publicly available personal data).
7.7. Personal data processing is carried out that must be published or disclosed in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured by the implementation of 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 safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of applicable legislation or if the data subject has given consent to the Operator to transfer data to a third party for the execution of obligations under a civil law contract.
8.3. If inaccuracies are detected in the personal data, the User can update them independently by sending the Operator a notification to the email address vboukharkina@gmail.com with the subject line “Update of Personal Data.”
8.4. The processing period of personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is specified by the contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to vboukharkina@gmail.com with the subject line “Withdrawal of Consent to Process 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 those entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or these documents apply to the mentioned service providers. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions imposed by the data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of personal data processing for state, public, or other public interests defined by Russian Federation legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows for identifying the data subject no longer than required by the purposes of processing personal data unless the storage period is defined by federal law, contract, or is necessary for the data subject’s role as a party, beneficiary, or guarantor to the contract.
8.9. The processing of personal data may cease upon achieving the purposes of processing, expiration of the consent period, withdrawal of consent by the data subject, or a request to stop processing, as well as the discovery of unlawful processing of personal data.

9. Actions Performed by the Operator with the Obtained Personal Data

9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (dissemination, provision, access), anonymization, 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 obtained information via information and telecommunication networks or without it.

10. Cross-Border Transfer of Personal Data

10.1. Before starting the activity of cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out cross-border transfer of personal data (this notification is sent separately from the notification about the intention to process personal data).
10.2. Before submitting the above-mentioned 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 individuals who have access to personal data must not disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at vboukharkina@gmail.com.
12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy is valid indefinitely until it is replaced with a new version.
12.3. The current version of the Policy is freely available on the internet at the following address: http://comsense.tilda.ws.