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Rules for the use of user data
Personal Data Processing Policy
**Personal Data Processing Policy**
1. **General Provisions**
This personal data processing policy has been developed in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "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 undertaken by the Operator.
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal and family secrets, as its highest priority and a key condition for its activity.
1.2. This policy on personal data processing (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://waluetta.ru/.
2. **Key Terms Used in the Policy**
2.1. **Automated processing of personal data** — processing personal data using computer technology.
2.2. **Blocking of personal data** — temporary suspension of personal data processing (unless processing is necessary to clarify personal data).
2.3. **Website** — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://waluetta.ru/.
2.4. **Personal Data Information System** — a collection of personal data contained in databases, as well as information technologies and technical means ensuring their processing.
2.5. **Depersonalization of personal data** — actions that result in the impossibility of determining, without using additional information, whether personal data belong 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 or without the use of automation tools concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, 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) processing personal data, as well as determining the purposes of personal data processing, the composition 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 a specific or identifiable User of the website https://waluetta.ru/.
2.9. **Personal data allowed for dissemination by the subject of personal data** — personal data made accessible to an unlimited number of persons by the subject of personal data through their consent for processing, provided in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data allowed for dissemination").
2.10. **User** — any visitor to the website https://waluetta.ru/.
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 number of persons (transferring personal data) or making personal data available to an unlimited number of persons, including making personal data public in the media, placing it 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 a foreign governmental body, a foreign natural or legal person.
2.14. **Destruction of personal data** — any actions that result in the permanent destruction of personal data with no possibility of restoring the personal data content in the personal data information system and (or) result in the destruction of physical media on which personal data is stored.
3. **Main Rights and Obligations of the Operator**
3.1. The Operator has the right to:
— receive from the subject of personal data truthful information and/or documents containing personal data;
— in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sends a request to terminate the processing of personal data, the Operator has the right to 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 the fulfillment of obligations under the Personal Data Law and the legal acts adopted in accordance with it unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— provide the subject of personal data, at their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with current Russian Federation legislation;
— respond to requests and inquiries from subjects of personal data and their legal representatives following the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects with necessary information upon request within 10 days 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 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 cases provided by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. **Main Rights and Obligations of Personal Data Subjects**
4.1. Personal data subjects have the right to:
— obtain information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other subjects unless 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 their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— impose the condition of prior consent when processing personal data for the promotion of goods, works, and services in the market;
— withdraw consent to the processing of personal data, as well as send a request to terminate the processing of personal data;
— file a complaint with the authorized body for the protection of the rights of personal data subjects or seek legal action in case of unlawful actions or inaction by the Operator in processing their personal data;
— exercise other rights provided by Russian Federation legislation.
4.2. Personal data subjects are obligated to:
— provide the Operator with accurate data about themselves;
— notify the Operator about any clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent are liable according to Russian Federation law.
5. **Principles of Personal Data Processing**
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, pre-defined, and legitimate purposes. Processing incompatible with the purposes of personal data collection is not allowed.
5.3. The combination of databases containing personal data, processing of which is carried out for purposes incompatible with each other, is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not allowed.
5.6. The accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing are ensured during processing. The Operator takes the necessary measures and/or ensures that incomplete or inaccurate data is deleted or clarified.
5.7. Personal data storage is carried out in a form that allows identifying the personal data subject, no longer than is required for the purposes of personal data processing unless the period for storing personal data is established by federal law, a contract, or a party benefiting from the data, including the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of the loss of necessity in achieving those purposes unless otherwise provided by federal law.
6. **Purposes of Personal Data Processing**
Processing purposes:
— To inform the User via electronic mail.
Personal data:
— Surname, first name, middle name;
— Email address;
— Phone numbers.
Legal basis:
— Federal Law "On Information, Information Technologies, and Information Protection" No. 149-FZ dated July 27, 2006.
Types of personal data processing:
— Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data;
— Sending information emails to the User's email address.
**7. Conditions for Processing Personal Data**
7.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided by international treaties of the Russian Federation or laws, to perform functions, powers, and duties assigned to 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 act of another authority or official that must be enforced 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, one of the parties to which or the beneficiary or guarantor under which is the personal data subject, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the protection of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data is carried out with regard to personal data to which an unlimited circle of people has access as provided by the personal data subject or upon their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data is carried out if publication or mandatory disclosure is required by 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 through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of 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. Personal data of the User will never be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case inaccuracies are found in personal data, the User can update them independently by sending a notification to the Operator’s email address waluetta@gmail.com with the subject “Personal Data Update.”
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is specified by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at waluetta@gmail.com with the subject “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 these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should review these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6. Any restrictions set by the personal data subject on the transfer (except for providing access) and the processing conditions (except for obtaining access) of personal data permitted for dissemination do not apply when processing personal data in state, public, and other public interests as defined by Russian 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 the identification of the personal data subject, no longer than necessary for the purposes of processing personal data, unless the storage period is established by federal law, a contract to which the personal data subject is a party, a beneficiary, or a guarantor.
8.9. The processing of personal data may cease upon achieving the purposes of processing personal data, expiration of the consent given by the personal data subject, withdrawal of consent by the personal data subject, or a request to stop processing personal data, as well as upon detection of unlawful processing of personal data.
**9. Actions Performed by the Operator with the Received Personal Data**
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information through information and telecommunication networks or without such transfer.
**10. Cross-Border Transfer of Personal Data**
10.1. Before starting cross-border transfer activities, the Operator must notify the authorized body for the protection of the rights of personal data subjects of their intention to carry out 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 above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
**11. Confidentiality of Personal Data**
The Operator and other persons who have gained access to personal data must not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
**12. Final Provisions**
12.1. The User can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at waluetta@gmail.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is available online at https://waluetta.ru/datapolicy.
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1. **General Provisions**
This personal data processing policy has been developed in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "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 undertaken by the Operator.
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal and family secrets, as its highest priority and a key condition for its activity.
1.2. This policy on personal data processing (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://waluetta.ru/.
2. **Key Terms Used in the Policy**
2.1. **Automated processing of personal data** — processing personal data using computer technology.
2.2. **Blocking of personal data** — temporary suspension of personal data processing (unless processing is necessary to clarify personal data).
2.3. **Website** — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://waluetta.ru/.
2.4. **Personal Data Information System** — a collection of personal data contained in databases, as well as information technologies and technical means ensuring their processing.
2.5. **Depersonalization of personal data** — actions that result in the impossibility of determining, without using additional information, whether personal data belong 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 or without the use of automation tools concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, 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) processing personal data, as well as determining the purposes of personal data processing, the composition 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 a specific or identifiable User of the website https://waluetta.ru/.
2.9. **Personal data allowed for dissemination by the subject of personal data** — personal data made accessible to an unlimited number of persons by the subject of personal data through their consent for processing, provided in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data allowed for dissemination").
2.10. **User** — any visitor to the website https://waluetta.ru/.
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 number of persons (transferring personal data) or making personal data available to an unlimited number of persons, including making personal data public in the media, placing it 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 a foreign governmental body, a foreign natural or legal person.
2.14. **Destruction of personal data** — any actions that result in the permanent destruction of personal data with no possibility of restoring the personal data content in the personal data information system and (or) result in the destruction of physical media on which personal data is stored.
3. **Main Rights and Obligations of the Operator**
3.1. The Operator has the right to:
— receive from the subject of personal data truthful information and/or documents containing personal data;
— in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sends a request to terminate the processing of personal data, the Operator has the right to 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 the fulfillment of obligations under the Personal Data Law and the legal acts adopted in accordance with it unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— provide the subject of personal data, at their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with current Russian Federation legislation;
— respond to requests and inquiries from subjects of personal data and their legal representatives following the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects with necessary information upon request within 10 days 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 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 cases provided by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. **Main Rights and Obligations of Personal Data Subjects**
4.1. Personal data subjects have the right to:
— obtain information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other subjects unless 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 their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— impose the condition of prior consent when processing personal data for the promotion of goods, works, and services in the market;
— withdraw consent to the processing of personal data, as well as send a request to terminate the processing of personal data;
— file a complaint with the authorized body for the protection of the rights of personal data subjects or seek legal action in case of unlawful actions or inaction by the Operator in processing their personal data;
— exercise other rights provided by Russian Federation legislation.
4.2. Personal data subjects are obligated to:
— provide the Operator with accurate data about themselves;
— notify the Operator about any clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent are liable according to Russian Federation law.
5. **Principles of Personal Data Processing**
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, pre-defined, and legitimate purposes. Processing incompatible with the purposes of personal data collection is not allowed.
5.3. The combination of databases containing personal data, processing of which is carried out for purposes incompatible with each other, is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not allowed.
5.6. The accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing are ensured during processing. The Operator takes the necessary measures and/or ensures that incomplete or inaccurate data is deleted or clarified.
5.7. Personal data storage is carried out in a form that allows identifying the personal data subject, no longer than is required for the purposes of personal data processing unless the period for storing personal data is established by federal law, a contract, or a party benefiting from the data, including the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of the loss of necessity in achieving those purposes unless otherwise provided by federal law.
6. **Purposes of Personal Data Processing**
Processing purposes:
— To inform the User via electronic mail.
Personal data:
— Surname, first name, middle name;
— Email address;
— Phone numbers.
Legal basis:
— Federal Law "On Information, Information Technologies, and Information Protection" No. 149-FZ dated July 27, 2006.
Types of personal data processing:
— Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data;
— Sending information emails to the User's email address.
**7. Conditions for Processing Personal Data**
7.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided by international treaties of the Russian Federation or laws, to perform functions, powers, and duties assigned to 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 act of another authority or official that must be enforced 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, one of the parties to which or the beneficiary or guarantor under which is the personal data subject, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the protection of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data is carried out with regard to personal data to which an unlimited circle of people has access as provided by the personal data subject or upon their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data is carried out if publication or mandatory disclosure is required by 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 through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of 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. Personal data of the User will never be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case inaccuracies are found in personal data, the User can update them independently by sending a notification to the Operator’s email address waluetta@gmail.com with the subject “Personal Data Update.”
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is specified by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at waluetta@gmail.com with the subject “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 these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should review these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6. Any restrictions set by the personal data subject on the transfer (except for providing access) and the processing conditions (except for obtaining access) of personal data permitted for dissemination do not apply when processing personal data in state, public, and other public interests as defined by Russian 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 the identification of the personal data subject, no longer than necessary for the purposes of processing personal data, unless the storage period is established by federal law, a contract to which the personal data subject is a party, a beneficiary, or a guarantor.
8.9. The processing of personal data may cease upon achieving the purposes of processing personal data, expiration of the consent given by the personal data subject, withdrawal of consent by the personal data subject, or a request to stop processing personal data, as well as upon detection of unlawful processing of personal data.
**9. Actions Performed by the Operator with the Received Personal Data**
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information through information and telecommunication networks or without such transfer.
**10. Cross-Border Transfer of Personal Data**
10.1. Before starting cross-border transfer activities, the Operator must notify the authorized body for the protection of the rights of personal data subjects of their intention to carry out 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 above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
**11. Confidentiality of Personal Data**
The Operator and other persons who have gained access to personal data must not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
**12. Final Provisions**
12.1. The User can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at waluetta@gmail.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is available online at https://waluetta.ru/datapolicy.
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