Personal Data Processing Policy1. General Provisions
This personal data processing policy has been drafted in accordance with the requirements of 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 taken by Individual Entrepreneur Vitaliy Sergeyevich Martyanov (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing 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://artplay.studio.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at
https://artplay.studio.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without the use of additional information, whether personal data belongs 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 in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of 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 an identified or identifiable User of the website
https://artplay.studio.
2.9. Personal data authorized by the subject of personal data for dissemination — personal data to which an unlimited number of persons have access by the decision of the subject of personal data through giving consent to the processing of personal data authorized for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).
2.10. User — any visitor to the website
https://artplay.studio.
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 undefined circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publication in mass media, placement in information and telecommunication networks, or granting access to personal data by any other means.
2.13. Cross-border transfer of personal data — 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 — any actions as a result of which personal data are destroyed irreversibly with no possibility of further recovery in the personal data information system and/or material personal data carriers 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 the event of withdrawal by the subject of personal data of consent to the processing of personal data, as well as submission of a request to cease processing of personal data, continue processing personal data without the consent of the subject of personal data 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 provided for by the Personal Data Law and regulatory legal acts adopted in accordance therewith, 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 request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by applicable legislation of the Russian Federation;
— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of personal data subjects, upon request, the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
— 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 regarding personal data;
— cease transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform other duties provided for 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 regarding the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except where there are lawful grounds for disclosure of 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 personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take other measures provided for by law to protect their rights;
— impose a 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 request the cessation of processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in processing 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 personal information about themselves;
— notify the Operator of any clarification (updating, changing) 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, bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data are processed on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.
5.3. Merging databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
5.4. Only personal data that correspond to the purposes of processing are 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 relative to the stated purposes is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form allowing the identification of the subject of personal data for no longer than is required by the purposes of processing, unless the storage period is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in the event of loss of necessity to achieve such purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing personal data: informing the User via email messages.
Personal data:
— surname, first name, patronymic;
— email address;
— phone numbers;
— upload file.
Legal basis: statutory (constituent) documents of the Operator.
Types of personal data processing:
— collection;
— recording;
— systematization;
— accumulation;
— storage;
— destruction;
— depersonalization of personal data;
— sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, an act of another body, or an official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing 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 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. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data are processed that are made available to an unlimited circle of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.
8. Procedure for Collection, Storage, Transfer, 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 safety of personal data and takes all possible measures to prevent unauthorized persons from accessing 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 implementation of applicable law or if the personal data subject has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the Operator’s email address
info@artplay.studio with the note “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by contract or applicable law.
The User may at any time withdraw consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s email address
info@artplay.studio with the note “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer (except for access provision), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, do not apply in cases of personal data processing in the state, public, and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form allowing the identification of the personal data subject for no longer than is required by the purposes of processing personal data, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The conditions for terminating the processing of personal data may include achievement of the purposes of processing personal data, expiration of the consent period of the personal data subject, withdrawal of consent by the personal data subject, a request to cease processing personal data, as well as identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transfer of the received information via information and telecommunication networks or without such transfer.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to 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 intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may receive any clarifications regarding matters related to the processing of their personal data by contacting the Operator via email at
info@artplay.studio.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at
https://artplay.studio/policy/.