Personal data (ENG)

N.T.STUDIO

CREATIVE ORGANIZATION

MOSCOW, RUSSIA.

© EST. 2020

Policy regarding the processing of personal data

1. General provisions

This policy for the processing of personal data is compiled 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 defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Tymchuk Nikolai Sergeevich (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://ntstudio.co.

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 cessation of processing of personal data (except for cases where 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://ntstudio.co.

2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.

2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://ntstudio.co.

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

2.10. User - any visitor to the website https://ntstudio.co.

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

2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the 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 - transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in case the subject of personal data withdraws consent to the processing of personal data, as well as, submits a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, 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, upon his request, with information regarding the processing of his personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other duties provided for by the Personal Data Law.

4. Basic rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right to:
— receive information regarding the processing of his personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— require the operator to clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take statutory measures to protect their rights;
— impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, services on the market;
— to withdraw consent to the processing of personal data, as well as, to send a request to cease the processing of personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or in court the unlawful actions or inaction of the Operator when processing his personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the latter’s consent, bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of processing personal data

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. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of the processed personal data correspond to the stated purposes of
processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data is ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of processing personal data

Purpose of processing	informing the User by sending emails
Personal data	surname; name; patronymic; email address; phone numbers; information about education, profession, specialty and qualifications, details of education documents
Legal grounds	statutory (constituent) documents of the Operator; contracts concluded between the operator and the subject of personal data
Types of processing of personal data	collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data; sending informational emails to the email address

7. Conditions for processing personal data

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

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

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

7.4. The processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.

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

7.6. The processing of personal data is carried out, access to which is provided to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

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

8. Procedure for collecting, storing, transferring and other types of processing of 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 safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or in case the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill 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’s email address n.t.studio.co@gmail.com with the note "Updating personal data".

8.4. The period for processing personal data is determined by achieving the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation. The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s email address n.t.studio.co@gmail.com with the note "Withdrawal 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 said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Prohibitions established by the subject of personal data on transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing them.

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

8.9. A condition for terminating the processing of personal data may be achieving the purposes of processing personal data, expiration of the subject of personal data’s consent, withdrawal of consent by the subject of personal data or a request to cease processing personal data, as well as detection of unlawful processing of personal data.

9. List of actions performed by the Operator with the received personal data

9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.

10. Cross-border transfer of personal data

10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, 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 gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final provisions

12.1. The User can obtain any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email at n.t.studio.co@gmail.com.

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

12.3. The current version of the Policy is freely available on the Internet at https://ntstudio.co.