Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy is prepared 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 determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Sergey Vladimirovich Avdonin (hereinafter referred to as the "Operator").
1.1. The Operator's most important goal and condition for carrying out its activities is 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.
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://avdonincamerasystems.ru.
2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data – processing of personal data by means of computer technology.
2.2. Blocking of Personal Data – temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website – the totality of graphical and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the web address https://avdonincamerasystems.ru.
2.4. Information System of Personal Data – the totality of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of Personal Data – actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by 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 the use of automation means 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 entity, or individual, independently or jointly with other persons, organizing and/or carrying out the processing of 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://avdonincamerasystems.ru.
2.9. Personal Data Permitted by the Subject of Personal Data for Dissemination – personal data, access to which by an unlimited number of persons has been provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any visitor to the website https://avdonincamerasystems.ru.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of Personal Data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data familiar to an unlimited circle of persons, including the publication of personal data in mass media, posting 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 state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data – any actions as a result of which personal data are destroyed irrevocably, making it impossible to further restore the content of the personal data in the personal data information system and/or the material carriers of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
  • Receive from the subject of personal data reliable information and/or documents containing personal data;
  • In case the subject of personal data withdraws consent to the processing of personal data, as well as submits a request to cease the processing of personal data, the Operator is entitled 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 stipulated by the Personal Data Law and 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 subject of personal data, upon their request, with information concerning the processing of their personal data;
  • Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
  • Respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
  • Communicate to the authorized body for the protection of the rights of subjects of personal data, upon the request of this body, the necessary information within 10 days from the date of receipt of such a request;
  • Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
  • Implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from 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 for by the Personal Data Law;
  • Fulfill other duties stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal Data Subjects have the right to:
  • Receive information relating to the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except in cases where 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, illegally obtained, or not necessary for the stated processing purpose, as well as to take legal measures to protect their rights;
  • Stipulate the condition of prior consent when processing 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 to submit a demand to cease the processing of personal data;
  • Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of their personal data;
  • Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal Data Subjects are obliged to:
  • Provide the Operator with accurate data about themselves;
  • Notify the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, shall be held liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting the personal data is not permitted.
5.3. The combination of databases containing personal data processed for purposes that are incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. During the processing of personal data, the accuracy of the personal data, their sufficiency, and, where necessary, their relevance in relation to the purposes of processing personal data shall be ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows the identification of the personal data subject for no longer than required by the purposes of processing the personal data, unless the period for storage of personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achieving the processing purposes or in the event of the loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or law, for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution 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 to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract initiated by 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 exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out of personal data to which access by an unlimited number of persons has been provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
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. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or when the personal data subject has given consent to the Operator to transfer data 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 sending a notification to the Operator via email at asv73@yandex.ru with the subject line "Update of Personal Data".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at asv73@yandex.ru with the subject line "Withdrawal 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 persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the personal 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 permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator, when processing personal data, ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing the personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. The termination condition for the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the personal data subject's consent, the withdrawal of consent by the personal data subject or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out the 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 carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks, or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its 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 aforementioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, 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 are obliged not to disclose 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 may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at asv73@yandex.ru.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://avdonincamerasystems.ru/privacy-en.