1. General Provisions
This personal data processing policy has been developed in accordance with the requirements of the Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedures for processing personal data and measures to ensure the security of personal information taken by Adinari (hereinafter referred to as "the Operator").
1.1. The Operator's primary goal and condition for its operations is the observance of human and civil rights and freedoms when processing personal data, including protection of privacy, personal, and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as “the Policy”) to all information the Operator may receive about visitors to its website https://adinari.ru.
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 termination of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - the set of graphic and informational materials, as well as computer programs and databases, that ensure their accessibility on the internet at the network address https://adinari.ru.
2.4. Personal Data Information System - the collection of personal data stored in databases and the information technologies and technical means used to process them.
2.5. Depersonalization of Personal Data - actions that make it impossible to identify, without additional information, personal data belonging to a specific User or other personal data subjects.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, or destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity, or individual who, independently or in conjunction with other individuals, organizes and/or processes personal data, and determines the purposes for processing personal data and the composition of data to be processed.
2.8. Personal data - any information directly or indirectly related to a specific identifiable User of the website https://adinari.ru.
2.9. Personal data authorized for disclosure by the data subject - personal data that the data subject has consented to be shared with an unlimited number of people. This Includes personal data that is processed in accordance with the procedures outlined in the Personal Data Law (hereinafter referred to as "personal data authorized for disclosure").
2.10. User - any person who visits the website https://adinari.ru.
2.11. Disclosure of personal data - actions taken to share personal data with a specific person or group of people.
2.12. Disclosure of personal data - any actions aimed at making personal data available to an indefinite number of people(transfer of personal data) or making personal data accessible to an unlimited number of people, including publication of personal data in media, posting on information and communication networks, or providing access to personal data in other ways.
2.13. Transborder Transfer of personal data is the transfer of personal data outside the country to an authority, individual, or legal entity in another country.
2.14. Destruction of personal data means any actions that permanently destroy personal data, making it impossible to recover the content of the data in the information system or the physical media where the data was stored.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the following rights:
— To receive reliable information and/or documents containing personal data from the individual;
— In case of the individual withdrawing their consent to the processing of their personal data, or sending a request to stop the processing of their data, the operator has the right to continue to process the data without the individual's consent if there are specified grounds in the Personal Data Law;
— Independently determine the composition and list of measures needed to fulfill obligations provided by the Personal Data Law and regulatory legal acts, unless otherwise specified by the Personal Data law or other federal laws.
3.2. The Operator is required to:
— provide the subject of personal data with information regarding the processing of their personal data upon their request;
— organize the processing of personal data in accordance with the procedures established by the relevant legislation of the Russian Federation;
— respond to inquiries and requests from individuals whose personal data is processed and their legal representatives, in accordance with the provisions of the Personal Data law;
— inform the relevant authority for the protection of personal data rights upon request, within 10 working days from receipt of such request;
— publish or provide unrestricted access to this policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, provision, and dissemination, as well as other illegal actions related to personal data;
— stop transferring (distributing, providing access to) personal data and stop processing it, and destroy personal data as provided in the Personal Data law;
— other duties provided in the Personal Data law should also be fulfilled.
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 by federal laws. This information should be provided to the Personal Data Subject by the Operator in an accessible format and should not contain any personal data related to other Personal Data Subjects, unless there are legitimate reasons for disclosing such personal data. A list of information and procedures for obtaining this information is established by the Personal Data Law
- require the Operator to clarify their personal data, block or delete it if it is incomplete, out-of-date, inaccurate, obtained illegally, or not necessary for the specified purpose of processing. They also have the right to take measures provided by law to protect their rights
— put forward a condition of prior consent when processing personal data in order to promote goods, works, and services on the market
— revoke consent to the processing of personal data and to send a request to terminate the processing of such data
— appeal to the authorized body for the protection of personal data rights or in court against any illegal actions or omissions of the Operator during the processing of their personal information
— exercise other rights provided by the legislation of the Russian Federation.
4.2. The subjects of personal data must:
— provide the Operator with accurate and reliable information about themselves;
— inform the Operator of any changes or updates to their personal information.
4.3. Persons who provide false information to the Operator or disclose personal information about other individuals without their consent are subject to legal consequences in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Personal data processing is limited to specific, predetermined, and legitimate goals. Unauthorized processing of personal data not compatible with the purpose of collection is prohibited.
5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data relevant to the purposes of its processing is subject to processing.
5.5. The scope and amount of processed personal data corresponds to the stated processing purposes. Redundant personal data with respect to the stated purpose of its processing is not acceptable.
5.6. When processing personal data, we ensure the accuracy, sufficiency, and relevance of the personal data in relation to the purpose of processing. We take the necessary measures to delete or correct incomplete or inaccurate information.
5.7. We store personal data in a format that allows us to identify the individual, for no longer than necessary for the purpose of the processing, unless a federal law or agreement with the individual requires a longer period. We destroy or anonymize the processed data once the goals of the processing have been achieved or the need for further processing has ceased, unless federal law prohibits this.
6. Purpose of Personal Data Processing
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Purpose of Processing
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to inform the User by sending emails
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Personal data
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- the last name, first name, and patronymic
- the email address
- phone numbers
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Legal grounds
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- The Federal Law "On Information, Information Technologies, and Information Protection", dated July 27, 2006, No. 149-FZ
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Types of personal data processing
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- collection, recording, systematization, accumulation, storage, destruction, and depersonalization
- sending information letters via email
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7. Terms of Personal Data Processing
7.1. Personal data processing is carried out with the consent of the individual whose personal data are being processed.
7.2. Personal data processing is necessary to achieve goals provided for in an international agreement of the Russian Federation or under the law, as well as to fulfill the functions, powers, and duties assigned to the operator under the legislation of the Russian Federation.
7.3. Personal data is processed for the purpose of administering justice, executing a judicial act, or an act issued by another body or official that must be executed in accordance with the Russian Federation legislation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of an agreement in which the personal data subject is a party, beneficiary, or guarantor, or for the conclusion of an agreement at the initiative of the personal data subject or under which the personal data subject will become a beneficiary or guarantor.
7.5. Personal data processing is also necessary to protect the rights and interests of the data controller or third parties, or to achieve social goals, provided that the rights and freedoms of the personal data subject are respected.
7.6. Processing of personal data can also be done if it is publicly available, meaning that it is accessible to an unlimited number of people through the personal data subject's website or upon his request (hereinafter referred to as publicly available personal data).
7.7. Personal data that is subject to publication or mandatory disclosure according to federal law may also be processed.
8. The procedure for collecting, storing, transferring and other types of processing personal data
The security of personal data processed by the Operator is ensured by implementing 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 confidentiality of personal data and takes all necessary measures to prevent unauthorized access to personal information.
8.2. The User's personal information will never be shared with third parties under any circumstances unless it is required by law or if the subject has given consent for the Operator to share their data with a third party in order to fulfill obligations under a civil contract.
8.3. In case of any inaccuracies in the personal information, the User has the right to update it independently by contacting the Operator via email adinari.info@gmail.com, marked "Updating of personal data".
8.4. The period of processing of personal data will be determined by the purpose for which the personal data was collected, unless a different period is specified in the contract or applicable law.
The User has the right to withdraw their consent to the processing of their personal data at any time. To do so, they should send a notification to adinari.info@gmail.com, marked "Withdrawal of Consent to Processing of Personal Data".
8.5. All information collected by third-party services, such as payment systems and communication means, is processed by these companies (Operators) in accordance with their own user agreements and privacy policies. The Operator is not responsible for the actions of these third parties.
8.6. The restrictions imposed by the owner of personal data on the transfer (other than granting access) and on the processing or terms of processing (other than obtaining access) to personal data that may be shared, do not apply in cases where personal data are processed for state, public, or other public purposes defined by the laws of the Russian Federation.
8.7. The operator ensures the confidentiality of personal data during the processing of such data.
8.8. Personal data are stored by the operator in a form that allows identifying the individual whose data it is for no longer than is necessary for the purpose of processing, unless a longer period of storage is specified by federal law or an agreement entered into by the individual, beneficiary, or guarantor of the data.
8.9. The conditions for the termination of personal data processing may include the achievement of the purpose of personal data processing, the expiration of the consent given by the individual whose personal data is being processed, the withdrawal of that consent, or a requirement to stop processing the personal data. Additionally, unlawful processing of the personal data may also lead to the termination of processing.
9. List of actions taken by the Operator with personal data received
9.1. The Operator collects, records, organizes, stores, updates, extracts, uses, shares (distributes), accesses, anonymizes, blocks, erases, and destroys personal information.
9.2. The Operator processes personal data automatically, with or without the need for receiving and/or sending information via communication networks.
10. Transborder Transfer of personal data
10.1. Prior to the transfer of personal data across borders, the operator is required to notify the relevant authorities in the country where the data will be transferred.This notification must be sent separately from the initial notification of the intended processing of personal data.
10.2. Before submitting this notification, the operator must obtain relevant information from foreign authorities, individuals, and legal entities regarding the planned transfer of data.
11. Privacy of Personal Data
The operator and others who have access to personal data must not disclose or share the data with third parties without the individual's consent, except as permitted by applicable law.
12. Final provisions
12.1. The User may request any clarifications regarding processing of their personal data by contacting the Operator via email at adinari.info@gmail.com.
12.2. This document will be updated to reflect any changes to the Operator's Personal Data Processing Policy. The Policy will remain in effect until it is superseded by a new edition.
12.3. The current version of this Policy can be accessed freely online at https://adinari.ru/en/privacy/.