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PERSONAL DATA PROCESSING POLICY

1. GENERAL PROVISIONS

1.1. This personal data processing policy (hereinafter referred to as the Policy) has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ «On Personal Data» and determines the procedure for processing personal data and measures to ensure the security of personal data received by Valeria Chechetkina, [1] INN 667005356103 (hereinafter referred to as the Operator).

The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. Key concepts used in the Policy:

Personal data is any information related to a directly or indirectly identified or identifiable individual (subject of personal data). 

User is an individual, the subject of personal data. 

Cookies are small pieces of data related to personal data that are stored in the browser of a computer, mobile phone or other device after the User visits the Site;

Automated processing of personal data is the processing of personal data using computer technology; 

Blocking of personal data is the temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data); 

Website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address izmaphotos.ru

Personal data information system is a set of personal data contained in databases and the information technologies and technical means that ensure their processing; 

Depersonalization of personal data is an action that makes it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data;

Processing of personal data is any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such 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;

Provision of personal data — actions aimed at disclosing personal data to a specific person or an indefinite number of persons; 

Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, posting on information and telecommunications networks or providing access to personal data in any other way;

Destruction of personal data — any actions as a result of which personal data are irrevocably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) as a result of which the tangible media of personal data are destroyed.

1.3. The subjects of personal data whose personal data is processed by the Operator, in accordance with this Policy, include: 

1) clients and counterparties of the Operator (individuals) 

2) representatives/employees of clients and counterparties of the Operator (legal entities) 

3) website visitors.


2. PURPOSES AND CONDITIONS OF PERSONAL DATA PROCESSING AND THE CORRESPONDING LISTS OF PROCESSED PERSONAL DATA

2.1. Personal data permitted for processing within the framework of this Policy are provided by the User voluntarily by filling out the User data form on the Website or by submitting information personally to the Operator via electronic correspondence.

2.2. The personal data of the persons specified in subparagraphs 1-2 of paragraph 1.3 of the Policy are processed for the following purposes: 

● identification of the party within the framework of agreements and contracts concluded with the Operator; 

● provision of services to the User, access to the Site, services; 

● communication with the User, sending letters to the User at the time of receiving payment from the User, sending notifications and requests to the User;

● mutual settlements with the User within the framework of the agreements concluded with him; 

● transfer of the results of the execution of the agreement — photographs and/or other works created within the framework of the agreements concluded between the user and the Operators.

2.3. For the purposes specified in paragraph 2.2 of the Policy, the following personal data of persons specified in subparagraphs 1-2 of paragraph 1.3 of the Policy are processed: 

1) last name, first name, patronymic (if any); 

2) contact telephone number; 

3) email address [2]

 4) residential address; 

6) date of birth

2.4. The processing of personal data specified in paragraph 2.3 of the Policy is carried out with the consent of the subject of personal data to the processing of his personal data, with the exception of cases when the processing of personal data is necessary for the performance of an agreement to which the User is a party, beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the User or an agreement under which the User will be a beneficiary or guarantor, as well as in the event that the processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or the law, for the implementation and performance of the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.

2.5. The processing of personal data of persons specified in subparagraph 3 of paragraph 1.3 of this Policy (Website visitors) is carried out for the following purposes:

● organizing access to information about the Operator’s activities posted on the Internet information and telecommunications network; 

● communicating with the User, sending letters to the User upon registration on the website; 

● promoting the Operator’s services and informing new clients about the quality of services — providing information about previous work experience when the User publishes a review on the Website about working with the Operator. 

● researching and analyzing data to support and improve the services and sections of the Website, as well as developing new services and sections of the Website;

● Conducting statistical and other studies based on anonymized data.

2.6. For the purposes specified in paragraph 2.5 of this Policy, the following personal data of persons specified in subparagraph 3 of paragraph 1.3 of this Policy are processed:

1) Last name, first name; 

2) Email address; 

3) Telephone number; 

4) Cookies. The collection and processing of cookies is regulated by Section 7 of this Policy.

2.7. The processing of personal data specified in paragraph 

2.6 of the Policy is carried out with the consent of the subject of personal data to the processing of his personal data. 

2.8. Consent to the processing of Personal Data is the User’s action by placing a flag (tick) next to the column «I give my consent to the processing of my personal data in accordance with the Personal Data Processing Policy».

2.9. Consent to the processing of Personal data, including Cookies, for Users using the Site to obtain information about the Operator's activities is provided by using the Site and clicking the «okay» button or a similar button on the notification about the collection of Cookies in accordance with this Privacy Policy. 

2.10. The personal data specified in paragraphs 2.3, 2.6 of this Policy are hereinafter combined under the general concept of Personal data. 

2.11. Special categories of personal data are not processed.


3. PROCEDURE FOR PROCESSING PERSONAL DATA

3.1. Personal data may be processed with or without the use of automation tools. Personal data may be processed without the use of automation tools in the form of paper documents and in electronic form (files, databases) on electronic storage media. 

3.2. The operator does not carry out cross-border transfer of personal data. 

3.3. The operator does not transfer personal data to third parties, with the exception of:

● cases where the transfer is necessary for the performance of an agreement with the subject; 

● cases provided for by law (at the request of government agencies, the court, inquiry and investigation bodies, and other authorized bodies on the grounds provided for by the current legislation of the Russian Federation).

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

3.5. The Operator has the right to store (archive storage) and assemble documents and personal data. 

3.6. The processing period of personal data is until the purposes of processing the personal data are achieved. The User may revoke their consent to the processing of personal data at any time by sending a notice to the Operator via e-mail to the Operator's e-mail address ler4iz@yamdex.ru [3] with the note «Revocation of consent to the processing of personal data».

3.7. The operator is obliged to stop processing personal data: 

● in the event of detection of illegal processing of personal data carried out by the operator within a period not exceeding three working days from the date of such detection; 

● in the event of withdrawal by the subject of personal data of consent to the processing of his personal data;

● If the purpose of processing personal data is achieved, destroy the personal data within a period not exceeding thirty days from the date of achieving the purpose of processing the personal data. If it is not possible to destroy the personal data within the specified period, the operator blocks such personal data and ensures the destruction of the personal data within a period not exceeding six months, unless another period is established by federal laws.

4. RIGHTS AND RESPONSIBILITIES OF THE PARTIES. 

4.1. The Operator has the right to: 

● receive reliable information containing personal data from the User; 

4.2. The Operator is obliged to: 

● process personal data in the manner prescribed by the current legislation of the Russian Federation; 

● consider the User’s requests regarding the processing of personal data and provide reasoned responses;

● Take measures to clarify and destroy the User’s personal data in connection with his (his legal representative’s) appeal with legal and reasonable demands; 

● Organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation.

4.3. The User has the right:

 ● to receive full information about his personal data processed by the Operator; 

● to clarify his personal data, block it or destroy it in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;

● to revoke consent to the processing of personal data; 

● if the User believes that the Operator is processing his personal data in violation of the requirements of current legislation or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal the actions or inactions of the Operator to the authorized body for the protection of the rights of subjects of personal data or in court.

● The user has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damages in court. 

● To exercise other rights provided for by the legislation of the Russian Federation.

4.4. The User is obliged to: 

● Provide the Operator with only reliable information about himself

5. PROCEDURE FOR PROCESSING APPEALS FROM 

PERSONAL DATA SUBJECTS

5.1. The persons specified in paragraph 1.3 of this Policy have the right to receive information regarding the processing of their personal data, including: 

1) confirmation of the fact of processing of personal data by the Operator; 

2) legal grounds and purposes of processing of personal data; 

3) purposes and methods of processing of personal data applied by the Operator; 

4) processed personal data related to the relevant subject of personal data, the source of their receipt;

5) the terms of processing personal data, including the terms of their storage; 

6) information on the methods of fulfilling the Operator’s obligations established by Article 18.1 of the Federal Law «On Personal Data»; 

7) other information provided for by the Federal Law «On Personal Data» or other federal laws.

The Operator is obliged to provide the subject of personal data or his representative with the opportunity to become familiar with the personal data related to this subject of personal data free of charge. 

5.2. The persons specified in paragraph 1.3 of this Policy have the right to demand from the Operator clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also to take measures provided by law to protect their rights.

5.3. The information specified in paragraph 5.1 of this Policy must be provided to the personal data subject by the Operator in an accessible form, and must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosure of such personal data.

5.4. The information specified in paragraph 5.1 of this Policy shall be provided to the personal data subject or their representative within ten business days from the date of the request or receipt by the Operator of the personal data subject's or their representative's request. The request must contain:

1) the number of the main document certifying the identity of the personal data subject or his representative, information on the date of issue of the said document and the issuing authority; 

2) information confirming the participation of the personal data subject in relations with the operator (contract number, date of conclusion of the contract, conventional verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by the operator.

3) the signature of the personal data subject or their representative. The request may be sent in electronic form and signed with an electronic signature in accordance with Russian Federation law.

5.5. If any inaccuracies are discovered in personal data, the User may update them independently by sending a notification to the Operator's email address ler4iz@yandex.ru with the subject «Updating personal data». The Operator is obliged to make the necessary changes to the personal data within seven business days from the date the personal data subject or their representative provides information confirming that the personal data is incomplete, inaccurate, or outdated.

5.6. Within a period not exceeding seven business days from the date the personal data subject or their representative provides information confirming that such personal data was obtained illegally or is not necessary for the stated purpose of processing, the operator is obliged to destroy such personal data. The operator is obliged to notify the personal data subject or their representative of the changes made and the measures taken.

6. MEASURES TO ENSURE THE SECURITY OF PERSONAL DATA

 DURING ITS PROCESSING

6.1. 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 current legislation in the field of personal data protection. Such protective measures include, in particular: 

● use of anti-virus information protection tools; 

● identification and authentication of the user when logging into the information system using a password; 

● restriction of access of unauthorized persons to premises intended for processing personal data;

● Storing personal data on secure media; 

● Detecting instances of unauthorized access to personal data and taking measures, including measures to detect, prevent and eliminate the consequences of computer attacks on personal data information systems and to respond to computer incidents in them; 

● Restoring personal data modified or destroyed as a result of unauthorized access to them.

6.2. The operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

7. COOKIES

7.1. The following cookies are collected on the Website: 

7.1.1. Technical cookies — the collection of these files cannot be disabled during your visit, as they are necessary for the correct operation and provision of full functionality of the Website;


7.2. The purposes of collecting cookies: 

— authentication of Users of the Site; 

— as an element of security measures used to protect user accounts, including preventing fraudulent use of login credentials, as well as to protect the Site as a whole;

7.3. How to disable the collection of cookies on the website: 

7.3.1. If the User does not want cookies stored on their device, they can disable this option in their browser settings. Saved cookies can also be deleted at any time in the browser's system settings. The User can change their browser settings to accept or reject all cookies or cookies from the Website by default.

7.3.2. PLEASE NOTE THAT BY DISABLING COOKIES, THE USER WILL NOT BE ABLE TO USE CERTAIN FUNCTIONS AND TOOLS OF THE SITE. 

Cookies are processed for statistical or other research purposes, subject to the mandatory anonymization of personal data.

8. FINAL PROVISIONS


The User may obtain any clarification on any questions of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at ler4iz@yamdex.ru [4] 

This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version. 

The current version of the Policy is publicly available on the Internet at izmaphotos.ru