Privacy Policy
1. General Provisions
This Privacy Policy is drafted in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by Maria Aleksandrovna Samokhvalova (the “Operator”) to ensure the security of personal data.
1.1. The Operator’s primary goal and condition for conducting its activities is to respect human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy applies to all information that the Operator may obtain about visitors of the website https://askcloser.com/.
2. Key Terms Used in This Policy
2.1. Automated processing of personal data — processing using computer technology.
2.2. Blocking of personal data — temporary suspension of processing (except 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 that make them available on the Internet at https://askcloser.com/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without additional information, whether the personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions performed with or without automation, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state or municipal authority, legal entity or individual that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing, the scope of personal data to be processed, and the actions performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://askcloser.com/.
2.9. Personal data made public by the data subject — personal data to which an unlimited number of persons are granted access by the data subject by giving consent in accordance with the Personal Data Law (hereinafter “personal data allowed for distribution”).
2.10. User — any visitor of the website https://askcloser.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) or at making personal data available to an indefinite circle of persons, including publication in the media, posting in information and telecommunication networks, or providing access 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 state authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration in the personal data information system and/or in the destruction of the physical media containing personal data.
3. Operator’s Rights and Obligations
3.1. The Operator has the right to: — receive accurate information and/or documents containing personal data from the data subject;
— continue processing personal data without the data subject’s consent if such grounds are provided by the Personal Data Law, including if the data subject withdraws consent or requests cessation of processing;
— independently determine the scope of measures sufficient to fulfill obligations under the Personal Data Law and related regulations, unless otherwise provided by law.
3.2. The Operator must: — provide the data subject, upon request, with information regarding the processing of his/her personal data;
— organize processing in accordance with applicable law of the Russian Federation;
— respond to requests from data subjects and their legal representatives in accordance with the Personal Data Law;
— provide the authorized supervisory body, upon request, with necessary information within 10 days of receiving such request;
— publish and/or otherwise ensure unrestricted access to this Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions;
— cease transfer (distribution, provision, access), stop processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to: — receive information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided in an accessible form and must not include personal data of other subjects unless there are lawful grounds for disclosure. The list and procedure are established by the Personal Data Law;
— demand that the Operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purposes, and take other measures to protect their rights;
— require prior consent for processing for the purposes of marketing goods, works, and services;
— withdraw consent to processing and/or demand cessation of processing;
— appeal unlawful actions or inaction of the Operator to the supervisory authority or in court;
— exercise other rights provided by the laws of the Russian Federation.
4.2. Data subjects must: — provide accurate information about themselves;
— notify the Operator of updates (changes) to their personal data.
4.3. Persons who provide inaccurate information about themselves or personal data of another subject without that subject’s consent are liable in accordance with Russian law.
5. Principles of Personal Data Processing
5.1. Processing is carried out on a lawful and fair basis.
5.2. Processing is limited to achieving specific, predetermined, and lawful purposes; processing incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meet the purposes of processing are processed.
5.5. The content and volume of processed personal data correspond to the stated purposes; excessive processing is not allowed.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identification of the data subject no longer than required by the purposes of processing unless a different storage period is provided by federal law or contract. Personal data are destroyed or depersonalized upon achievement of processing purposes or when such purposes no longer apply, unless otherwise provided by federal law.
6. Purposes of Processing
Purpose: informing the User by sending emails.
Personal data processed: data necessary to send emails to the User.
Legal basis: Federal Law No. 149-FZ of July 27, 2006.
Types of processing: transfer (provision) of personal data.
7. Conditions for Processing Personal Data
7.1. Processing is carried out with the data subject’s consent.
7.2. Processing is necessary to achieve purposes provided by an international treaty or law, and to perform functions, powers, and duties imposed on the Operator by law.
7.3. Processing is necessary for the administration of justice or execution of judicial acts or acts of other bodies or officials subject to enforcement.
7.4. Processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, or to conclude a contract at the data subject’s initiative.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out for personal data made publicly available by the data subject or at the data subject’s request.
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collection, Storage, Transfer, and Other Processing
The security of personal data processed by the Operator is ensured by legal, organizational, and technical measures required to fully comply with applicable legislation.
8.1. The Operator ensures the safekeeping of personal data and undertakes all possible measures to prevent unauthorized access.
8.2. Personal data will not be transferred to third parties under any circumstances except as required by law or with the data subject’s consent for the performance of a civil-law contract.
8.3. If inaccuracies are found, the User may update personal data by emailing the Operator at [email protected] with the subject “Personal data update”.
8.4. The processing period is determined by the purposes for which the data were collected unless otherwise provided by contract or law. The User may withdraw consent at any time by emailing [email protected] with the subject “Withdrawal of consent to process personal data”.
8.5. Any information collected by third-party services (including payment systems, communication services, and other providers) is stored and processed by such parties under their own Terms and Privacy Policies. The Operator is not responsible for the actions of such third parties.
8.6. Restrictions set by the data subject on transfer (except access), processing, or conditions of processing of personal data allowed for distribution do not apply where processing is carried out in state, public, or other public interests established by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. Personal data are stored in a form allowing identification of the data subject no longer than required by the purposes of processing unless a different period is set by law or contract.
8.9. Processing may be terminated upon achievement of the purposes, expiration or withdrawal of consent, a demand to cease processing, or upon identification of unlawful processing.
9. Actions Performed with Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes, and destroys personal data.
9.2. Automated processing may be carried out with transmission over information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Prior to cross-border transfer, the Operator must notify the authorized supervisory body of its intention to transfer personal data across borders (this notice is separate from the notice of intent to process personal data).
10.2. Before submitting such notice, the Operator must obtain relevant information from the foreign authorities, individuals, or legal entities to whom the personal data are planned to be transferred.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data must not disclose or distribute such data to third parties without the data subject’s consent unless otherwise provided by federal law.
12. Final Provisions
12.1. Users may obtain any clarifications regarding the processing of their personal data by emailing [email protected].
12.2. Any changes to this Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version is publicly available at https://askcloser.com/.