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Privacy policy
Policy on Personal Data Processing

General Provisions

This policy on personal data processing is developed 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 establishes the procedure for processing personal data and the measures taken to ensure the security of personal data by Stepchenkov Andrey Dmitrievich, ContactON (hereinafter referred to as the "Operator").

1.1. The Operator considers compliance with the rights and freedoms of individuals in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets, as its most important goal and condition for conducting its activities.

1.2. This Operator's policy on the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors of the website https://contacton.space.

Key Definitions Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except in cases where the processing is necessary to clarify the personal data).

2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases that provide their availability on the internet at the network address https://contacton.space.

2.4. Information system of personal data means a combination of databases of personal data contained therein and the information technology and technical means that ensure their processing.

2.5. Depersonalization of personal data means actions that make it impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data means any action (operation) or a combination of actions (operations) performed with or without the use of automation 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 means a government body, municipal body, legal or natural person, either individually or jointly with others, that organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.

2.8. Personal data means any information directly or indirectly related to a specific or identifiable User of the website https://contacton.space.

2.9. Personal data permitted for distribution means personal data to which an unlimited number of persons have access, provided by the subject of personal data through consent to the processing of personal data permitted for distribution, in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").

2.10. User means any visitor to the website https://contacton.space.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transferring personal data) or acquainting an unlimited number of persons with personal data, including publishing personal data in the mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data is irretrievably destroyed, making it impossible to restore the content of personal data in the information system of personal data and/or physical storage media of personal data.


3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

- Obtain accurate information and/or documents containing personal data from the data subject.

- In case the data subject withdraws their consent to the processing of personal data or submits a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law.

- Independently determine the scope and list of measures necessary and sufficient to fulfill the obligations provided by the Personal Data Law and the relevant regulatory legal acts, unless otherwise specified by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

- Provide the data subject, upon request, with information regarding the processing of their personal data.

- Organize the processing of personal data in accordance with the current legislation of the Russian Federation.

- Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.

- Provide the necessary information to the authorized body for the protection of the rights of data subjects within 10 days from the date of receiving such a 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 unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other illegal actions concerning personal data.

- Terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedures and cases specified in the Personal Data Law.

- Fulfill other obligations provided by the Personal Data Law.

4. Main Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:

- Obtain information regarding the processing of their personal data, except for cases provided by federal laws. The information is provided to the data subject by the Operator in an accessible form and should not contain personal data related to other data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are determined by the Personal Data Law.

- Request the Operator to clarify their personal data, block or delete it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purpose of processing. Data subjects also have the right to take measures provided by law to protect their rights.

- Set conditions for obtaining their consent to the processing of personal data for the purpose of promoting goods, works, or services on the market.

- Withdraw their consent to the processing of personal data and submit a request to stop the processing of personal data.

- File a complaint with the authorized body for the protection of the rights of data subjects or take legal action against the unlawful actions or inaction of the Operator in the processing of their personal data.

- Exercise other rights provided by the legislation of the Russian Federation.

4.2. Data subjects are obliged to:

- Provide the Operator with accurate data about themselves.

- Inform the Operator about the clarification (update, change) of their personal data.

4.3. Individuals who provide false information about themselves to the Operator or provide information about another data subject without their consent bear responsibility 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 achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. The combination of databases containing personal data that are processed for incompatible purposes is not allowed.

5.4. Only personal data that is relevant to the purposes of processing should be processed.

5.5. The content and scope of processed personal data should correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes of processing is not allowed.

5.6. When processing personal data, accuracy, sufficiency, and, when necessary, relevance to the purposes of processing should be ensured. The data controller takes necessary measures and/or ensures their adoption to delete or rectify incomplete or inaccurate data.

5.7. Personal data should be stored in a form that allows the identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by a federal law, a contract, or an agreement where the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized when the purposes of processing are achieved or when the need to achieve these purposes is no longer present, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose: Informing the User through the sending of email messages

Personal data: Last name, first name, patronymic (if available), email address, Telegram

Legal grounds: Contracts concluded between the data controller and the data subject

Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data

Sending informational emails to the email address

7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the data subject to process their personal data.

7.2. The processing of personal data is necessary for the purposes stipulated by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed on the data controller by Russian legislation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority or official subject to enforcement under Russian legislation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the protection of the rights and legitimate interests of the data controller or third parties or for achieving socially significant goals, provided that the rights and freedoms of the data subject are not violated.

7.6. Processing of personal data that is made publicly available by the data subject or at their request is carried out.

7.7. The processing of personal data subject to publication or mandatory disclosure is carried out in accordance with federal law.


8. Procedure for Collection, Storage, Transmission, 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 on personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the performance of applicable legislation or if the data subject has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator via email to the Operator's email address hello@contacton.space with the subject line "Updating personal data."

8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless otherwise provided by a contract or applicable legislation. The User can revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address hello@contacton.space with the subject line "Revocation of consent to the processing of personal data."

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their Terms of Service and Privacy Policy. The data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.

8.6. Prohibitions on the transfer (except for providing access) or processing conditions (except for obtaining access) of personal data, which are imposed by the data subject, do not apply in cases of processing personal data in the public interest as defined by Russian legislation.

8.7. The Operator ensures the confidentiality of personal data during its processing.

8.8. The Operator stores personal data in a form that allows the identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by a federal law, a contract, or an agreement where the data subject is a party, beneficiary, or guarantor.

8.9. The cessation of personal data processing may occur upon achieving the purposes of processing personal data, expiration of the consent period provided by the data subject, revocation of consent by the data subject, or a request to cease personal data processing, as well as in case of detecting unlawful processing of personal data.

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

9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with or without the use of information and telecommunication networks.

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 personal data protection of their intention to carry out such transfers (this notification is separate from the notification regarding the intention to process personal data).

10.2. Prior to submitting the aforementioned notification, the Operator must obtain the necessary information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at hello@contacton.space.

12.2. This document reflects any changes to the policy of personal data processing by the Operator. The policy remains in effect indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at the following address: http://contacton.space/privacy-policy.