1. General ProvisionsThis Personal Data Processing Policy is developed in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by individual entrepreneur Konstantin Alexandrovich Pirogov (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for conducting its activities is to respect human rights and freedoms when processing personal data, including the protection of rights related to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website
https://kpirogov.ru.
2. Key Concepts Used in the Policy2.1. Automated processing of personal data – processing of personal data with the help of computing devices.
2.2. Blocking of personal data – temporary cessation of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address
https://kpirogov.ru.
2.4. Personal data information system – a set of personal data contained in databases and the technologies and technical means that ensure their processing.
2.5. De-personalization of personal data – actions that result in the impossibility of determining without additional information the ownership of personal data to a specific User or another subject of personal data.
2.6. Personal data processing – any action (operation) or set of actions (operations) performed with personal data using automated or non-automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), de-personalization, blocking, deletion, destruction of personal data.
2.7. Operator – a government authority, municipal authority, legal or natural person, alone or jointly with others, organizing and/or carrying out the processing of personal data, and determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) to be carried out with personal data.
2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the website
https://kpirogov.ru.
2.9. Personal data authorized by the subject of personal data for distribution – personal data to which the subject of personal data has granted unrestricted access by consent for processing and distribution as stipulated by the Personal Data Law (hereinafter referred to as personal data authorized for distribution).
2.10. User – any visitor to the website
https://kpirogov.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or group of people.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an undefined group of people (transmission of personal data) or making personal data accessible to an unrestricted group of people, including publication in the media, placement on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – 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 – any actions that result in the permanent destruction of personal data, making further restoration of the personal data in the information system of personal data impossible, and/or destroying material carriers of personal data.
3. Operator's Rights and Obligations3.1. The Operator has the right to:
- Receive accurate information and/or documents containing personal data from the subject of personal data;
- In case of withdrawal of consent for processing personal data by the subject, continue processing personal data without consent if there are grounds as stated in the Personal Data Law;
- Independently determine the necessary and sufficient measures to fulfill the obligations stipulated by the Personal Data Law, 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 with information regarding the processing of their personal data upon request;
- Organize the processing of personal data in accordance with Russian Federation legislation;
- Respond to requests and inquiries from subjects of personal data and their legal representatives as required by the Personal Data Law;
- Report to the authorized body for the protection of personal data rights within 30 days of receiving a request from this body;
- Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
- Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, or other unlawful actions with personal data;
- Cease the transmission (distribution, provision, access) of personal data, cease processing and destroy personal data as stipulated by the Personal Data Law;
- Fulfill other obligations stipulated by the Personal Data Law..
4. Rights and Obligations of Personal Data Subjects4.1. Subjects of personal data have the right to:
- Receive information about the processing of their personal data, except for cases provided by federal laws. The information is provided by the Operator in an accessible form and must not contain personal data related to other subjects, except when there are legal grounds for disclosing such personal data.
- Request the correction, blocking, or deletion of personal data if they are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and take legal measures to protect their rights.
- Demand prior consent for processing personal data for market promotion purposes.
- Withdraw consent for the processing of personal data.
- Appeal to the authorized body for personal data protection or take legal action in case of unlawful actions or failure to act by the Operator in processing their personal data.
- Exercise other rights provided by Russian Federation legislation.
4.2. Subjects of personal data are obliged to:
- Provide the Operator with accurate data about themselves;
- Inform the Operator about updates (changes) to their personal data.
4.3. Individuals who provide the Operator with false information about themselves or about another subject of personal data without the latter's consent are responsible under Russian Federation law.
5. The Operator may process the following Personal Data of the User:5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. City of residence.
5.5. The website also collects and processes anonymized data about visitors (including "cookie" files) using internet statistics services (Yandex.Metrica, Google Analytics, and others).
5.6. The above-mentioned data is further referred to in this Policy as Personal Data.
5.7. The Operator does not process special categories of personal data related to racial, ethnic origin, political views, religious or philosophical beliefs, intimate life.
5.8. The processing of personal data permitted for dissemination, from the special categories of personal data mentioned in part 1 of Article 10 of the Personal Data Law, is allowed only if the prohibitions and conditions set out in Article 10.1 of the Personal Data Law are followed.
5.9. The User’s consent to the processing of personal data permitted for dissemination is given separately from other consents to the processing of their personal data. At the same time, the conditions specified, in particular, in Article 10.1 of the Personal Data Law, must be observed. The requirements for the content of such consent are established by the authorized body for the protection of personal data subjects' rights.
5.9.1. The User gives the consent for the processing of personal data permitted for dissemination directly to the Operator.
5.9.2. The Operator must publish information about the processing conditions, prohibitions, and conditions for processing personal data permitted for dissemination no later than three working days after receiving the User's consent.
5.9.3. The transmission (dissemination, provision, access) of personal data permitted for dissemination by the data subject may be stopped at any time at the request of the data subject. This request must include the surname, first name, patronymic (if available), contact information (phone number, email address, or postal address) of the data subject, as well as a list of personal data whose processing should be stopped. The personal data mentioned in this request may only be processed by the Operator to whom it was sent.
5.9.4. The consent for processing personal data permitted for dissemination becomes invalid from the moment the Operator receives the request mentioned in p. 5.9.3 of this Policy regarding the processing of personal data.
6. Principles of Personal Data Processing6.1. Personal data is processed legally and fairly.
6.2. Personal data processing is limited to achieving specific, pre-defined, and lawful purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
6.4. Only personal data that is relevant to the purpose of processing is processed.
6.5. The content and volume of processed personal data corresponds to the stated processing purposes. The processing of excessive personal data relative to the stated purposes is not allowed.
6.6. When processing personal data, the accuracy, adequacy, and, where necessary, the relevance of the personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures they are taken to remove or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows the identification of the data subject no longer than necessary to achieve the purposes of processing personal data, unless the retention period of personal data is established by federal law, the agreement, or is determined by the data subject's status. Personal data is destroyed or anonymized once the processing purposes are achieved or if the need for achieving those purposes is lost, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing7.1. The purpose of processing the User’s personal data is: – To inform the User by sending electronic emails;
– To conclude, perform, and terminate civil law agreements;
– To provide the User with access to services, information, and/or materials on the website
https://kpirogov.ru.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always unsubscribe from receiving informational messages by sending a letter to the Operator's email address kpirogov1@gmail.com with the subject “Unsubscribe from notifications about new products, services, and special offers.”
7.3. Anonymized data about Users collected via internet statistics services is used for collecting information about Users’ actions on the site, improving the site’s quality and content.
8. Legal Grounds for Processing Personal Data8.1. The legal grounds for the processing of personal data by the Operator are: – Federal Law "On Information, Information Technologies and Information Protection" dated 27.07.2006 No. 149-FZ;
– Federal laws and other regulatory legal acts in the field of personal data protection;
– The User's consent to the processing of their personal data, to the processing of personal data permitted for dissemination.
8.2. The Operator processes personal data of the User only in the case of their submission and/or sending by the User through special forms located on the website
https://kpirogov.ru or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User agrees with this Policy.
8.3. The Operator processes anonymized data about the User if permitted by the User’s browser settings (if cookies are enabled and JavaScript is used).
8.4. The personal data subject independently decides to provide their personal data and freely gives consent in their interest.
9. Conditions for Personal Data Processing9.1. Personal data is processed with the consent of the data subject.
9.2. The processing of personal data is necessary to achieve the goals set by international agreements of the Russian Federation or laws, for fulfilling the functions, powers, and duties assigned to the Operator by the Russian Federation’s legislation.
9.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official, which must be enforced in accordance with Russian Federation’s legislation on enforcement proceedings.
9.4. Personal data processing is necessary for the execution of a contract, the party to which or the beneficiary or guarantor of which is the data subject, as well as for the conclusion of a contract at the initiative of the data subject or a contract in which the data subject will be a beneficiary or guarantor.
9.5. Personal data processing is necessary for the legitimate interests of the Operator or third parties, or to achieve public interest goals, provided that the rights and freedoms of the data subject are not violated.
9.6. Processing of personal data that has been made publicly available by the data subject or at their request (hereinafter – publicly available personal data) is carried out.
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with the requirements of the applicable law on personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User’s personal data will never be transferred to third parties under any circumstances, except for cases related to compliance with the applicable law or if the data subject has given consent for the Operator to transfer data to a third party for fulfilling obligations under a civil law contract.
10.3. If inaccuracies in personal data are found, the User can update them independently by sending a notification to the Operator’s email kpirogo
wclub.nsk@gmail.comv1@gmail.com with the subject “Update of personal data.”
10.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law.
The User can withdraw their consent for the processing of personal data at any time by sending a notification to the Operator’s email address kpirogov1@gmail.com with the subject “Withdrawal of consent to process personal data.”
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) according to their User Agreement and Privacy Policy. The data subject and/or User is required to independently review these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
10.6. Restrictions imposed by the data subject on the transfer (except for providing access) and on the processing or conditions for processing (except for granting access) of personal data permitted for dissemination do not apply in cases of personal data processing in state, public, and other public interests as defined by Russian Federation law.
10.7. The Operator ensures the confidentiality of personal data during processing.
10.8. The Operator stores personal data in a form that allows the identification of the data subject no longer than necessary for the purposes of personal data processing, unless the retention period is defined by federal law, the agreement, or the data subject’s status.
10.9. The termination of personal data processing may occur upon achieving the processing goals, expiration of the consent, or withdrawal of consent by the data subject, as well as the detection of unlawful processing of personal data.
11. Actions Performed by the Operator with Received Personal Data11.1. The Operator collects, records, organizes, accumulates, stores, updates (amends), extracts, uses, transfers (distributes, provides access), anonymizes, blocks, deletes, and destroys personal data.
11.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information through information and telecommunication networks or without it.
12. Cross-border Transfer of Personal Data12.1. Before initiating a cross-border transfer of personal data, the Operator must ensure that the foreign country to which the personal data is to be transferred provides reliable protection of the rights of the data subjects.
12.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements can only be carried out with the written consent of the data subject for the cross-border transfer of their personal data and/or the execution of a contract, one of the parties to which is the data subject.
13. Confidentiality of Personal DataThe Operator and other persons who have access to personal data are obligated not to disclose or distribute the personal data to third parties without the consent of the data subject unless otherwise required by federal law.
14. Final Provisions14.1. The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at
kpirogov1@gmail.com.
14.2. Any changes to the personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the internet at
https://kpirogov.ru/privacy-en.