Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken by Individual Entrepreneur Denis Vladimirovich Novikov (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality, to be one of the most important objectives and prerequisites of its activities.
1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://melomama.ru.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except where processing is necessary to clarify or update personal data).
2.3. Website means a collection of graphic and informational materials, as well as computer software and databases, ensuring their availability on the Internet at https://melomama.ru.
2.4. Personal data information system means a collection of personal data contained in databases, together with the information technologies and technical means used to process such data.
2.5. Anonymisation of personal data means actions resulting in the impossibility of determining, without the use of additional information, whether personal data relates to a particular User or other personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data, whether by automated means or without the use of such means, including collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision or access), anonymisation, blocking, deletion and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with other persons, organises and/or carries out the processing of personal data and determines the purposes of personal data processing, the categories of personal data to be processed and the actions (operations) to be performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://melomama.ru.
2.9. Personal data authorised by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data authorised by the personal data subject for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorised for distribution”).
2.10. User means any visitor to the website https://melomama.ru.
2.11. Provision of personal data means actions aimed at disclosing personal data to a particular person or a particular group of persons.
2.12. Distribution of personal data means 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 number of persons, including publication of personal data in the mass media, posting such data on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed, making it impossible to restore the contents of such personal data in the personal data information system, and/or as a result of which physical media containing personal data is destroyed.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain from the personal data subject accurate information and/or documents containing personal data;
— where the personal data subject withdraws consent to the processing of personal data and/or submits a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject where grounds for such processing are provided for by 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 regulatory legal acts adopted pursuant thereto, unless otherwise provided for by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information concerning the processing of his or her personal data;
— organise the processing of personal data in accordance with the applicable legislation of the Russian Federation;
— respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorised body responsible for protecting the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or distribution, as well as against other unlawful actions involving personal data;
— cease the transfer (distribution, provision or access) of personal data, cease processing and destroy personal data in the manner and circumstances prescribed by the Personal Data Law;
— perform 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:
— obtain information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information to be provided and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block or destroy their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, as well as to take measures prescribed by law to protect their rights;
— require prior consent as a condition for processing personal data for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
— lodge a complaint with the authorised body responsible for protecting the rights of personal data subjects or bring legal proceedings against unlawful actions or omissions of the Operator in connection with 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 information about themselves;
— notify the Operator of any clarification (update or change) to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data processing shall be limited to the achievement of specific, predetermined and legitimate purposes. Personal data may not be processed in a manner incompatible with the purposes for which it was collected.
5.3. Databases containing personal data processed for mutually incompatible purposes may not be combined.
5.4. Only personal data that is relevant to the purposes of processing shall be processed.
5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of processing is not permitted.
5.6. When processing personal data, the accuracy and sufficiency of such data and, where necessary, its relevance to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that permits identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a personal data retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Personal data being processed shall be destroyed or anonymised upon achievement of the purposes of processing or where there is no longer a need to achieve such purposes, unless otherwise provided for by federal law.
6. Purposes of Personal Data Processing
Purpose of processing
Informing the User by sending emails.
Personal data
— surname, first name and patronymic;
— email address;
— telephone numbers.
Legal grounds
— the Operator’s charter and/or constituent documents;
— agreements entered into between the Operator and the personal data subject.
Types of personal data processing
— collection, recording, systematisation, accumulation, storage, destruction and anonymisation of personal data;
— sending informational emails to the User’s email address.
7. Conditions for Personal Data Processing
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his or her personal data.
7.2. Personal data may be processed where such processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or for the exercise of functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data may be processed where such processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data may be processed where such processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data may be processed where such processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. Personal data may be processed where access to such data by an unlimited number of persons has been granted by the personal data subject or at his or her request (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data
The security of personal data processed by the Operator shall be ensured through the implementation of legal, organisational and technical measures necessary for full compliance with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator shall ensure the security and integrity of personal data and take all possible measures to prevent unauthorised persons from gaining access to personal data.
8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except where such transfer is required for compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the purpose of fulfilling obligations under a civil-law agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data by sending a notification to the Operator at eco+1925892@melomama.ru with the subject line “Personal Data Update”.
8.4. The period for which personal data is processed shall be determined by the achievement of the purposes for which the personal data was collected, unless another period is stipulated by an agreement or applicable law.
The User may withdraw his or her consent to the processing of personal data at any time by sending the Operator a notification by email to eco+1925892@melomama.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communications providers and other service providers, shall be stored and processed by such persons (Operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject and/or [shall familiarise themselves] with the aforementioned documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer (other than provision of access), as well as on the processing or conditions of processing (other than obtaining access), of personal data authorised for distribution shall not apply where personal data is processed in the state, public or other public interests specified by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data when processing such data.
8.8. The Operator shall store personal data in a form that permits identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a personal data retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. Personal data processing may be terminated upon achievement of the purposes of processing, expiry of the personal data subject’s consent, withdrawal of consent by the personal data subject, receipt of a request to terminate the processing of personal data, or identification of unlawful processing of personal data.
9. Actions Performed by the Operator with the Personal Data Obtained
9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (distributes, provides or grants access to), anonymises, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorised body responsible for protecting the rights of personal data subjects of its intention to carry out cross-border transfers of personal data. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the aforementioned notification, the Operator shall obtain the 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 intended to be made.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data shall not disclose such personal data to third parties or distribute it without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain clarification on any matters concerning the processing of his or her personal data by contacting the Operator by email at eco+1925892@melomama.ru.
12.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in force indefinitely until replaced by a new version.
12.3. The current version of this Policy is publicly available on the Internet at https://melomama.ru/policy.
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken by Individual Entrepreneur Denis Vladimirovich Novikov (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality, to be one of the most important objectives and prerequisites of its activities.
1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://melomama.ru.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except where processing is necessary to clarify or update personal data).
2.3. Website means a collection of graphic and informational materials, as well as computer software and databases, ensuring their availability on the Internet at https://melomama.ru.
2.4. Personal data information system means a collection of personal data contained in databases, together with the information technologies and technical means used to process such data.
2.5. Anonymisation of personal data means actions resulting in the impossibility of determining, without the use of additional information, whether personal data relates to a particular User or other personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data, whether by automated means or without the use of such means, including collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision or access), anonymisation, blocking, deletion and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with other persons, organises and/or carries out the processing of personal data and determines the purposes of personal data processing, the categories of personal data to be processed and the actions (operations) to be performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://melomama.ru.
2.9. Personal data authorised by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data authorised by the personal data subject for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorised for distribution”).
2.10. User means any visitor to the website https://melomama.ru.
2.11. Provision of personal data means actions aimed at disclosing personal data to a particular person or a particular group of persons.
2.12. Distribution of personal data means 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 number of persons, including publication of personal data in the mass media, posting such data on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed, making it impossible to restore the contents of such personal data in the personal data information system, and/or as a result of which physical media containing personal data is destroyed.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain from the personal data subject accurate information and/or documents containing personal data;
— where the personal data subject withdraws consent to the processing of personal data and/or submits a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject where grounds for such processing are provided for by 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 regulatory legal acts adopted pursuant thereto, unless otherwise provided for by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information concerning the processing of his or her personal data;
— organise the processing of personal data in accordance with the applicable legislation of the Russian Federation;
— respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorised body responsible for protecting the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or distribution, as well as against other unlawful actions involving personal data;
— cease the transfer (distribution, provision or access) of personal data, cease processing and destroy personal data in the manner and circumstances prescribed by the Personal Data Law;
— perform 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:
— obtain information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information to be provided and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block or destroy their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, as well as to take measures prescribed by law to protect their rights;
— require prior consent as a condition for processing personal data for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
— lodge a complaint with the authorised body responsible for protecting the rights of personal data subjects or bring legal proceedings against unlawful actions or omissions of the Operator in connection with 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 information about themselves;
— notify the Operator of any clarification (update or change) to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data processing shall be limited to the achievement of specific, predetermined and legitimate purposes. Personal data may not be processed in a manner incompatible with the purposes for which it was collected.
5.3. Databases containing personal data processed for mutually incompatible purposes may not be combined.
5.4. Only personal data that is relevant to the purposes of processing shall be processed.
5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of processing is not permitted.
5.6. When processing personal data, the accuracy and sufficiency of such data and, where necessary, its relevance to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that permits identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a personal data retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Personal data being processed shall be destroyed or anonymised upon achievement of the purposes of processing or where there is no longer a need to achieve such purposes, unless otherwise provided for by federal law.
6. Purposes of Personal Data Processing
Purpose of processing
Informing the User by sending emails.
Personal data
— surname, first name and patronymic;
— email address;
— telephone numbers.
Legal grounds
— the Operator’s charter and/or constituent documents;
— agreements entered into between the Operator and the personal data subject.
Types of personal data processing
— collection, recording, systematisation, accumulation, storage, destruction and anonymisation of personal data;
— sending informational emails to the User’s email address.
7. Conditions for Personal Data Processing
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his or her personal data.
7.2. Personal data may be processed where such processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or for the exercise of functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data may be processed where such processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data may be processed where such processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data may be processed where such processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby violated.
7.6. Personal data may be processed where access to such data by an unlimited number of persons has been granted by the personal data subject or at his or her request (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data
The security of personal data processed by the Operator shall be ensured through the implementation of legal, organisational and technical measures necessary for full compliance with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator shall ensure the security and integrity of personal data and take all possible measures to prevent unauthorised persons from gaining access to personal data.
8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except where such transfer is required for compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the purpose of fulfilling obligations under a civil-law agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data by sending a notification to the Operator at eco+1925892@melomama.ru with the subject line “Personal Data Update”.
8.4. The period for which personal data is processed shall be determined by the achievement of the purposes for which the personal data was collected, unless another period is stipulated by an agreement or applicable law.
The User may withdraw his or her consent to the processing of personal data at any time by sending the Operator a notification by email to eco+1925892@melomama.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communications providers and other service providers, shall be stored and processed by such persons (Operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject and/or [shall familiarise themselves] with the aforementioned documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer (other than provision of access), as well as on the processing or conditions of processing (other than obtaining access), of personal data authorised for distribution shall not apply where personal data is processed in the state, public or other public interests specified by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data when processing such data.
8.8. The Operator shall store personal data in a form that permits identification of the personal data subject for no longer than is necessary for the purposes of processing, unless a personal data retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. Personal data processing may be terminated upon achievement of the purposes of processing, expiry of the personal data subject’s consent, withdrawal of consent by the personal data subject, receipt of a request to terminate the processing of personal data, or identification of unlawful processing of personal data.
9. Actions Performed by the Operator with the Personal Data Obtained
9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (distributes, provides or grants access to), anonymises, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorised body responsible for protecting the rights of personal data subjects of its intention to carry out cross-border transfers of personal data. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the aforementioned notification, the Operator shall obtain the 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 intended to be made.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data shall not disclose such personal data to third parties or distribute it without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final Provisions
12.1. The User may obtain clarification on any matters concerning the processing of his or her personal data by contacting the Operator by email at eco+1925892@melomama.ru.
12.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in force indefinitely until replaced by a new version.
12.3. The current version of this Policy is publicly available on the Internet at https://melomama.ru/policy.
