Personal Data Processing Policy

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1. Personal Data Processing Policy
General Provisions

This personal data processing policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Sole Proprietor NICHOLAS NIKOLAEVICH VASILKOV (hereinafter — the Operator).
1.1. The Operator sets the protection of the rights and freedoms of individuals and citizens in the processing of their personal data as its most important goal and condition in carrying out its activities, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding personal data processing (hereinafter — the Policy) applies to all information the Operator may receive about visitors to https://vasilkov.digital.


2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data — processing 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 graphic and informational materials, as well as software and databases available on the internet at https://vasilkov.digital.
2.4. Personal data information system — a set of personal data contained in databases and the processing of such data using information technologies and technical means.
2.5. Depersonalization of personal data — actions that make it impossible to determine without additional information the affiliation of personal data to a specific user or other personal data subject.
2.6. Processing of personal data — any action or set of actions performed with or without automation concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
2.7. Operator — a government body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or performing the processing of personal data, as well as determining the purposes of processing, the scope of personal data, and the actions performed.
2.8. Personal data — any information related directly or indirectly to an identified or identifiable User of the website https://vasilkov.digital.
2.9. Personal data authorized by the subject for distribution — personal data to which an unlimited number of persons have access granted by the subject’s consent for processing as stipulated by the Law (hereinafter - data authorized for distribution).
2.10. User — any visitor of https://vasilkov.digital.
2.11. Provision of personal data — actions aimed at disclosing data to a particular person or group.
2.12. Distribution of personal data — any actions aimed at disclosing data to an indefinite range of people or making personal data available via any means.
2.13. Cross-border transfer of personal data — transfer to a foreign state, authority, individual, or legal entity.
2.14. Destruction of personal data — actions rendering personal data irretrievable and impossible to restore.


3. Main Rights and Obligations of the Operator

3.1. The operator has the right:
To receive reliable information and/or documents containing personal data from the subject;
To continue processing data without the subject’s consent if legal grounds exist;
To determine sufficient measures for fulfilling obligations under the Law unless otherwise provided by law.
3.2. Operator obligations:
To provide information processing details to the subject;
To process data according to current legislation;
To respond to requests and handle queries under the Law;
To report to the authorized body for data protection at their request;
To publish or otherwise ensure access to the Policy;
To take legal, organizational, and technical measures to protect personal data;
To cease distribution and destroy personal data in cases stipulated by the Law;
To fulfill other obligations under the Law.


4. Rights and Obligations of Personal Data Subjects

4.1. Rights:
To obtain information about the processing of their data (with conditions set by federal law);
To demand data clarification, blocking, or destruction if data are incomplete, outdated, incorrect, illegally obtained, or unnecessary;
To require prior consent for data processing for marketing;
To withdraw consent for processing;
To appeal against unlawful actions of the Operator;
To exercise other rights provided by Russian law.
4.2. Obligations:
To provide accurate information about oneself;
To notify the Operator of updates or changes.
4.3. Persons who provide inaccurate data, or information about others without consent, are liable under Russian law.


5. Operator May Process the Following User Data

5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. Collection and processing of anonymized visitor data (including cookies) through internet statistics services (Yandex Metrika, Google Analytics, etc.)
5.5. The above data are collectively referred to as Personal Data.
5.6. Special categories of personal data (racial, national, political, religious, or philosophical beliefs, intimate life) are not processed by the Operator.
5.7. Processing of special category data authorized for distribution is allowed if conditions set out in the Law are met.
5.8. Consent to the processing of data authorized for distribution is provided separately. Content requirements for such consent are set by the authorized body.
5.8.1. Consent is given directly to the Operator.
5.8.2. The Operator must publish information about processing conditions within three business days of receiving consent.
5.8.3. Distribution of such data must stop at any time at the subject’s request (the request must include name and contact details and a list of data to stop processing).
5.8.4. Consent expires upon receipt of a withdrawal request.


6. Principles of Personal Data Processing

6.1. Data must be processed lawfully and fairly.
6.2. Processing is limited to specific, legitimate goals.
6.3. Data bases for purposes incompatible with one another must not be joined.
6.4. Only relevant data are processed.
6.5. Data quantity and content must not be excessive for the stated purposes.
6.6. Data must be accurate, up-to-date, and sufficient for the purposes.
6.7. Data must not be stored longer than necessary for the purpose, unless stated by law or contract. Data are destroyed or depersonalized when the goal is fulfilled.


7. Purposes of Data Processing

7.1. To inform users via email;
To provide access to services, information, and materials on the website.
7.2. The Operator may send notifications of new products/services, special offers, and events. Users can opt out by email at hello@vasilkov.digital with “Opt-out of notifications” in the subject line.
7.3. Anonymous user data collected via internet statistics are used to improve site quality.


8. Legal Grounds for Data Processing

8.1. Legal grounds include charter documents, laws, user consent.
8.2. Personal data are processed upon collection or submission via forms or email. By submitting data, the User agrees to this Policy.
8.3. Anonymous data are processed if browser settings allow cookies and JavaScript.
8.4. Data subjects decide freely to provide data and consent.


9. Conditions for Data Processing

9.1. Data processing with subject’s consent.
9.2. Processing is necessary under law or for Operator’s legal duties.
9.3. Processing is required for justice or execution of court decisions.
9.4. Processing is needed for contract performance or conclusion.
9.5. Processing is necessary for Operator’s or third parties’ rights and legitimate interests, respecting subject’s rights/freedoms.
9.6. Processing of public data (available to an unlimited circle).
9.7. Processing of data intended for publication/disclosure, as required by law.


10. Procedure for Collecting, Storing, Transferring, and Other Types of Data Processing

Security is ensured by legal, organizational, and technical measures in full compliance with data protection law.
10.1. The Operator ensures the safety of personal data and takes measures to prevent unauthorized access.
10.2. Data will never be transferred to third parties except as required by law or if the subject has consented to third-party transfer for contract fulfillment.
10.3. In case of data inaccuracies, the User may update data by emailing hello@vasilkov.digital with “Personal data update” in the subject line.
10.4. The processing period is determined by the purpose, unless a contract or law stipulates otherwise. Consent can be withdrawn at any time by emailing hello@vasilkov.digital with “Withdrawal of consent” in the subject line.
10.5. Information collected by third-party services, including payment systems and communication tools, is stored and processed by those parties according to their user agreements and privacy policies. The Operator is not responsible for third-party actions.
10.6. Restrictions on transfer (except providing access) and conditions on processing authorized for distribution do not apply to processing in state, public, or other public interests outlined by Russian law.
10.7. The Operator guarantees confidentiality.
10.8. The Operator stores data no longer than necessary for the purposes unless otherwise set by law or contract.
10.9. Data processing is terminated upon fulfillment of the purpose, consent expiration or withdrawal, or identification of unlawful processing.


11. List of Actions Carried Out by the Operator

11.1. Collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction.
11.2. Automated data processing with transmission over networks or without.


12. Cross-border Personal Data Transfer

12.1. Before cross-border transfer, the Operator ensures reliable protection of rights by the foreign state.
12.2. Transfer to countries not meeting these requirements can be done only with written consent or contract participation.


13. Confidentiality

The Operator and anyone with access must not disclose or distribute data without the subject’s consent unless federal law provides otherwise.


14. Final Provisions

14.1. The User may obtain clarification regarding personal data processing by emailing hello@vasilkov.digital.
14.2. Any changes to the Policy will be reflected in this document. The Policy is in force indefinitely until replaced.
14.3. The current version is freely accessible online at https://vasilkov.digital/privacy.
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