Personal Data Processing Policy

1. General ProvisionsThis Personal Data Processing Policy (hereinafter referred to as the "Policy") is developed in accordance with the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Sole Proprietor Alexey Alexandrovich Zinchenko (hereinafter referred to as the "Operator").
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 secrets, as the most important goal and condition for carrying out its activities.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://handpan.kosmosky.com.
2. Basic Concepts 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 cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website: A set of graphic and information materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://handpan.kosmosky.com.
2.4. Information system of personal data: A set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data: Actions resulting in the impossibility of determining the ownership of personal data to a specific User or other subject of personal data without the use of additional information.
2.6. Processing of personal data: Any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator: A state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, 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://handpan.kosmosky.com.
2.9. Personal data permitted by the subject of personal data for dissemination: Personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law.
2.10. User: Any visitor to the website https://handpan.kosmosky.com
2.11. Provision of personal data: Actions aimed at disclosing personal data to a certain person or a certain 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 familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data: Transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data: Any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the information system of personal data and/or resulting in the destruction of material carriers of personal data.
3. Basic Rights and Obligations of the Operator3.1. The Operator has the right to:
  • Receive from the subject of personal data reliable information and/or documents containing personal data;
  • In case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request to stop processing personal data, the Operator has the right to 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 adopted in accordance with it regulatory legal acts, 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 his request, with information regarding the processing of his personal data;
  • Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • Respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
  • Notify the authorized body for the protection of the rights of subjects of personal data upon request of this body with the necessary information within 10 days from the date of receipt of such a request;
  • Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
  • Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
  • Stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
  • Fulfill other obligations provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects4.1. 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 is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, 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 their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
  • Set 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 send a request to stop processing personal data;
  • Appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when 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 reliable data about themselves;
  • Inform 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 subject of personal data without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, unless the period for storing personal data is established by federal law, a contract, a party to which, the beneficiary or guarantor of which is the subject of personal data. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: Informing the User by sending emails.
Personal data:
  • Last name, first name, patronymic;
  • Email address;
  • Phone numbers.
Legal grounds: Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 No. 149-FZ.
Types of personal data processing: Sending informational emails to the email address.
7. Conditions for Personal Data Processing7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
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 subject of personal data is a party or beneficiary or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data 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 this does not violate the rights and freedoms of the subject of personal data.
7.6. Personal data is processed when it is accessible to an unlimited number of persons and provided by the subject of personal data (hereinafter — publicly available personal data).
7.7. Personal data is processed, subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data ProcessingThe 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 access to personal data by unauthorized persons.
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 if the subject of personal data has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address info@kosmosky.com with the note “Updating personal data”.
8.4. The period for processing personal data is unlimited. The User can at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at info@kosmosky.com with the note “Withdrawal of consent to the processing of personal data”.
9. Cross-Border Transfer of Personal Data9.1. Before the start of cross-border transfer of personal data, the Operator is obliged to make sure that the foreign country to whose territory it is supposed to transfer personal data provides reliable protection of the rights of personal data subjects.
9.2. Cross-border transfer of personal data to the territory of foreign countries that do not meet the above requirements may be carried out only with the written consent of the personal data subject to the cross-border transfer of their personal data and/or for the execution of an agreement to which the subject of personal data is a party.
10. Final Provisions10.1. The User can receive any clarifications regarding the processing of their personal data by contacting the Operator via email at info@kosmosky.com.
10.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
10.3. The current version of the Policy is freely available on the Internet at the address: https://handpan.kosmosky.com/privacy-policy
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