Privacy Policy

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Tsyganova Anna Fedorovna (hereinafter referred to as the Operator).

• 1.1. The Operator considers compliance with the rights and freedoms of man and citizen in the processing of his personal data, including the protection of the right to privacy, personal and family secrets, as its most important goal and condition for its activities.
• 1.2. This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://tsuna-dev.com.

2. Basic Concepts Used in the Policy

• 2.1. Automated processing of personal data — processing of personal data using computing facilities.
• 2.2. Blocking of personal data — temporary termination of personal data processing (except in cases where processing is necessary to clarify personal data).
• 2.3. Website — a set of graphic and information materials, as well as programs for computers and databases that ensure their availability on the Internet at the network address https://tsuna-dev.com.
• 2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
• 2.5. Anonymization of personal data — actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific User or other personal data subject.
• 2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
• 2.7. Operator — a state body, municipal body, legal or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, 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://tsuna-dev.com.
• 2.9. Personal data permitted by the subject of personal data for distribution — personal data, access of an unlimited circle of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data permitted for distribution).
• 2.10. User — any visitor to the website https://tsuna-dev.com.
• 2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
• 2.12. Distribution 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 circle of persons with personal data, including publicizing personal data in the media, placing 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 the 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 is irreversibly destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

• 3.1. The Operator has the right:
• — to receive reliable information and/or documents containing personal data from the personal data subject;
• — in case of withdrawal by the personal data subject of consent to the processing of personal data, as well as the direction of an appeal with a demand to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
• — independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

• 3.2. The Operator is obliged to:
• — provide the personal data subject, at his request, with information concerning the processing of his personal data;
• — organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
• — respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
• — notify the authorized body for the protection of the rights of personal data subjects, at the request of this body, of the necessary information within 10 days from the date of receipt of such a request;
• — publish or otherwise ensure unlimited access to this Policy on personal data processing;
• — take legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
• — terminate the transfer (distribution, provision, access) of personal data, terminate the processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
• — fulfill other obligations provided for by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects

• 4.1. Personal data subjects have the right to:
• — receive information concerning the processing of his personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should 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 Law on Personal Data;
• — demand from the operator to clarify his personal data, block or destroy them in the event that the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take the measures provided for by law to protect their rights;
• — put forward a condition of preliminary consent when processing personal data for the purpose of promoting goods, works and services on the market;
• — to withdraw consent to the processing of personal data, as well as to send a demand to terminate the processing of personal data;
• — appeal to the authorized body for the protection of the rights of personal data subjects or in court the illegal actions or inaction of the Operator when processing his personal data;
• — to 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;
• — notify the Operator of the clarification (updating, changing) of their personal data.

• 4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the consent of the latter, are responsible in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

• 5.1. Personal data processing is carried out on a lawful and fair basis.
• 5.2. Personal data processing is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
• 5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
• 5.4. Only personal data that meets the purposes of their processing is subject to processing.
• 5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness 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 in relation to the purposes of processing personal data is ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
• 5.7. Personal data is stored in a form that allows the personal data subject to be determined, no longer than the purposes of processing personal data require, unless the period of storage of personal data is established by federal law, a contract, the party, beneficiary or guarantor of which is the personal data subject. Processed personal data is destroyed or anonymized upon the achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Personal Data Processing

• 7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of his personal data.
• 7.2. Personal data processing is necessary to achieve the goals provided for by the international treaty of the Russian Federation or the law, to carry out the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
• 7.3. Personal data processing is necessary for the administration of justice, execution of a court 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. Personal data processing is necessary for the execution of a contract, the party, beneficiary or guarantor of which is the personal data subject, 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 the 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. Processing of personal data, access of an unlimited circle of persons to which is provided by the personal data subject or at his request (hereinafter — publicly available personal data) is carried out.
• 7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

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 the 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 exclude 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 the current legislation, or if the personal data subject has given consent to the Operator to transfer data to a third party for the execution of obligations under a civil law contract.
• 8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notice to the Operator's email address info@tsuna-dev.com with the note "Personal Data Update".
• 8.4. The period of personal data processing is determined by the achievement of the goals for which the personal data was collected, unless a different period is provided for by the contract or current legislation. The User can withdraw his consent to the processing of personal data at any time by sending a notice to the Operator by email to the Operator's email address info@tsuna-dev.com with the note "Withdrawal of consent to the processing of personal data".
• 8.5. All information collected by third-party services, including payment systems, communication means 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 and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
• 8.6. The restrictions established by the personal data subject on the transfer (except for the provision of access), as well as on the processing or conditions of processing (except for receiving access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public and other public interests defined 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 that allows the personal data subject to be determined, no longer than the purposes of processing personal data require, unless the period of storage of personal data is established by federal law, a contract, the party, beneficiary or guarantor of which is the personal data subject.
• 8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or a demand to terminate the processing of personal data, as well as the detection of illegal processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data

• 9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, 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 received information via information and telecommunication networks or without it.

10. Cross-border Transfer of Personal Data

• 10.1. Before starting activities for 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 his intention to carry out cross-border transfer of personal data (such a notification is sent separately from the notification of the intention to carry out personal data processing).
• 10.2. Before submitting the above notification, the Operator is obliged to receive from the authorities of a foreign state, foreign natural persons, foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.

11. Confidentiality of Personal Data

The Operator and other persons who have received 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 can receive any clarifications on issues of interest concerning the processing of his personal data by contacting the Operator via email at info@tsuna-dev.com.
• 12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
• 12.3. The current version of the Policy is freely available on the Internet at https://tsuna-dev.com/privacy.