Privacy Policy (Personal Data Processing Policy)1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006 (hereinafter, the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by PATU 11/08 LLC (hereinafter, the “Operator”).
1.1. Respecting the rights and freedoms of individuals and citizens when processing their personal data — including protecting the right to privacy and to personal and family confidentiality — is the Operator's foremost objective and a fundamental condition for carrying out its activities.
1.2. This Operator's personal data processing policy (hereinafter, the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://patu1108.ru/.
2. Key Terms Used in this Policy
2.1. Automated processing of personal data — the processing of personal data by means of computer technology.
2.2. Blocking of personal data — the temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — the collection of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the internet at the network address https://patu1108.ru/.
2.4. Personal data information system — a collection of personal data contained in databases, together with the information technologies and technical means that ensure their processing.
2.5. De-identification of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine that particular personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not using automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating, amendment), extraction, use, transfer (dissemination, provision, access), de-identification, blocking, deletion and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or natural person that, independently or jointly with other persons, organises and/or carries out the processing of personal data, and that determines the purposes of personal data processing, the composition of the 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://patu1108.ru/.
2.9. Personal data permitted by the data subject for dissemination — personal data to which access by an unlimited number of persons has been granted by the data subject through consent to the processing of personal data permitted for dissemination, given in the manner prescribed by the Personal Data Law (hereinafter, “personal data permitted for dissemination”).
2.10. User — any visitor to the website https://patu1108.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 group of persons (transfer of personal data) or at allowing an unlimited number of persons to become acquainted with personal data, including the publication of personal data in the media, its posting on information and telecommunications networks, or the provision of access to personal data by any other means.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed, such that the content of the personal data can no longer be restored within the personal data information system, and/or the physical media containing the personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the data subject reliable information and/or documents containing personal data;
— in the event that the data subject withdraws consent to the processing of personal data, or submits a request to cease the processing of personal data, continue processing the personal data without the data subject's consent where grounds for doing so are set out in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations set out in the Personal Data Law and in regulatory legal acts adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the data subject, at their request, with information relating to the processing of their personal data;
— organise the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
— respond to requests and enquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorised body for the protection of the rights of personal data subjects, at that body's request, any necessary information within 10 days of receiving such a request;
— publish, or otherwise ensure unrestricted access to, this Personal Data Processing Policy;
— take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and from other unlawful actions in relation to personal data;
— cease the transfer (dissemination, provision, access), processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform such other duties as are provided for by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
— receive information relating to the processing of their personal data, except in cases provided for by federal laws. This information shall be provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such 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, to block it or to destroy it where the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, and to take other measures provided for by law to protect their rights;
— set the condition of prior consent when personal data are processed for the purpose of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data, and submit a request for the processing of personal data to cease;
— lodge a complaint against unlawful actions or omissions by the Operator in relation to the processing of their personal data with the authorised body for the protection of the rights of personal data subjects, or through the courts;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— provide the Operator with reliable information about themselves;
— notify the Operator of any clarification (update, amendment) of their personal data.
4.3. Persons who provide the Operator with false information about themselves, or information about another data subject without that subject'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 is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data were collected is not permitted.
5.3. The combining of databases containing personal data that are processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of the personal data, their sufficiency and, where necessary, their relevance to the purposes of processing shall be ensured. The Operator takes the necessary measures and/or ensures that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows the data subject to be identified for no longer than is required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, or by an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or de-identified upon achievement of the purposes of processing, or in the event that achieving those purposes is no longer necessary, 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 data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to enable the Operator to exercise functions, powers and duties vested in it by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, or for 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 an agreement to which the data subject is a party, beneficiary or guarantor, and also for concluding an agreement at the initiative of the data subject, or an agreement under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and lawful interests of the Operator or of third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the data subject are not thereby violated.
7.6. The processing is carried out of personal data to which access by an unlimited number of persons has been granted by the data subject or at the data subject's request (hereinafter, “publicly available personal data”).
7.7. The processing is carried out of personal data that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organisational and technical measures necessary to fully meet the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except where required by applicable legislation, or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law agreement.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator's email address, patu11081108@gmail.com, marked “Personal Data Update”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by an agreement or by applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via email to patu11081108@gmail.com, marked “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 those persons (Operators) in accordance with their own User Agreement and Privacy Policy. The data subject should familiarise themselves with such documents independently. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions established by a data subject on the transfer (other than the granting of access) of personal data permitted for dissemination, or on their processing or the conditions of their processing (other than the granting of access), do not apply in cases where personal data are processed in the state, public or other public interest as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the data subject to be identified for no longer than is required by the purposes of personal data processing, unless the storage period is established by federal law, or by an agreement to which the data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of processing, the expiry of the data subject's consent, withdrawal of consent by the data subject, a request to cease processing, or the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator carries out the collection, recording, systematisation, accumulation, storage, clarification (updating, amendment), extraction, use, transfer (dissemination, provision, access), de-identification, blocking, deletion and destruction of 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 any activity involving the cross-border transfer of personal data, the Operator must notify the authorised body for the protection of the rights of personal data subjects of its intention to carry out such a transfer (such notice being submitted separately from the notice of intention to process personal data).
10.2. Before submitting the above-mentioned notice, the Operator must obtain the relevant information from the foreign state authorities, foreign natural persons or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and any other persons who have gained access to personal data are obliged not to disclose such data to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarification on matters relating to the processing of their personal data by contacting the Operator via email at patu11081108@gmail.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://patu1108.ru/policy.