Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy is developed in accordance with the requirements of Federal Law No. 152-FZ dated 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 Individual Entrepreneur Anton Nikolaevich Novgorodtsev, TIN: 540697151989, OGRNIP 316547600194368 (hereinafter – the Operator).
1.1. The Operator’s primary goal and condition for conducting its activities is to respect the rights and freedoms of humans and citizens when processing their personal data, including protecting the right to privacy, personal and family secrecy.
1.2. This Operator’s policy on personal data processing (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors to the website https://nova-media.pro/.

2. Key Terms 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 suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphical and informational materials, as well as software for computers and databases, ensuring their accessibility on the internet at the network address https://nova-media.pro/.
2.4. Information system of personal data – a combination of personal data contained in databases and information technologies and technical means providing for their processing.
2.5. Anonymization of personal data – actions resulting in the impossibility of determining without additional information the attribution of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with the use of automation tools or without them regarding personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the website https://nova-media.pro/.
2.9. Personal data permitted by the subject of personal data for dissemination – personal data whose unrestricted access has been provided by the subject of personal data through consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data permitted for dissemination).
2.10. User – any visitor to the website https://nova-media.pro/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publishing personal data in mass media, placing them in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign country 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 without the possibility of further restoration of the content of personal data in the personal data information system and (or) destruction of physical media containing personal data.

3. Main rights and obligations of the Operator

3.1. The Operator has the right to:
– obtain from the subject of personal data accurate information and/or documents containing personal data;
– in case of withdrawal by the subject of personal data of consent to the processing of personal data, the Operator may continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and normative legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
– provide the subject of personal data with information concerning the processing of their personal data upon request;
– 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 Law on Personal Data;
– report to the authorized body for the protection of the rights of subjects of personal data, upon request from this body, the necessary information within 30 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 to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding 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 Law on Personal Data;
– perform other duties provided for by the Law on Personal Data.

4. Main rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right to:
– receive information concerning the processing of their 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 are established by the Law on Personal Data;
– demand from the operator clarification of their personal data, their blocking or destruction in the event that personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
– impose a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services in the market;
– withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in processing their personal data;
– 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 accurate data about themselves;
– inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the latter’s consent, shall bear responsibility in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Surname, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. In addition, the site collects and processes anonymized data about visitors (including “cookie” files) using internet statistics services (Yandex Metrica, Google Analytics and others).
5.5. The above-mentioned data are further referred to in this Policy as Personal Data.
5.6. The Operator does not process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, or information concerning intimate life.
5.7. Processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Article 10.1 of the Law on Personal Data are observed.
5.8. The User’s consent to the processing of personal data permitted for dissemination is obtained separately from other consents to the processing of their personal data. In doing so, the conditions provided for, in particular, by Article 10.1 of the Law on Personal Data must be observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.8.1 The User provides consent to the processing of personal data permitted for dissemination directly to the Operator.
5.8.2 The Operator is obliged within a period of no more than three working days from the moment of receiving the said consent from the User to publish information about the conditions of processing, the presence of prohibitions and conditions for processing by an unlimited circle of persons of personal data permitted for dissemination.
5.8.3 Transfer (dissemination, provision, access) of personal data permitted by the subject of personal data for dissemination must be discontinued at any time upon request by the subject of personal data. This request must include the surname, first name, patronymic (if applicable), contact information (phone number, email address, or postal address) of the subject of personal data, as well as a list of personal data whose processing is to be discontinued. The personal data specified in this request may only be processed by the Operator to whom it was sent.
5.8.4 Consent to the processing of personal data permitted for dissemination ceases to be valid from the moment the Operator receives the request specified in paragraph 5.8.3 of this Personal Data Processing Policy.

6. Principles of personal data processing

6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. Personal data processing is limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. It is not allowed to combine databases containing personal data whose processing is carried out for purposes that are incompatible with each other.
6.4. Only personal data that meet the purposes of their processing shall be processed.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data relative to the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption for the removal or correction of incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identification of the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract, a party to which, beneficiary, or guarantor of which is the subject of personal data. Processed personal data are destroyed or anonymized upon reaching the purposes of processing or in case of loss of need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. Purpose of processing the User’s personal data:
– informing the User by sending emails;
– providing the User with access to services, information and/or materials contained on the website https://nova-media.pro/.
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the Operator at the email address info@nova-media.pro with the subject “Refusal of notifications about new products and services and special offers.”
7.3. Anonymized User data collected using internet statistics services serves to gather information about User actions on the site, improve the quality of the site and its content.

8. Legal grounds for processing personal data

8.1. The legal grounds for the Operator’s processing of personal data are:
– the Operator’s charter (founding) documents;
– federal laws and other regulatory legal acts in the field of personal data protection;
– User consent to the processing of their personal data, including the processing of personal data permitted for distribution.
8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the sitehttps://nova-media.pro/or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is allowed in the User’s browser settings (including saving ‘cookie’ files and using JavaScript technology).
8.4. The subject of personal data independently makes a decision regarding the provision of their personal data and gives consent freely, by their own will, and in their own interest.

9. Terms of personal data processing

9.1. Personal data is processed with the consent of the subject of personal data for the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, execution of a court ruling, or another body or official’s act, which must be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the performance of a contract where the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding a contract initiated by the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
9.5. Processing of personal data is necessary for exercising 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.
9.6. Processing of personal data is carried out if access to them has been made available by the subject of personal data or at their request (hereinafter – publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for collecting, storing, transferring, and other types of personal data processing

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 on personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude unauthorized access to personal data.
10.2. 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 if the subject of personal data has given consent to the Operator to transfer data to a third party for fulfilling obligations under a civil law contract.
10.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the email address info@nova-media.pro with the subject “Update of personal data.”
10.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another term is provided by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s electronic address info@nova-media.pro with the subject line “Withdrawal of Consent to Processing 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 such entities (Operators) in accordance with their User Agreement and Privacy Policy. The Subject of Personal Data and/or the User is obliged to independently and promptly familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
10.6. Prohibitions established by the Subject of Personal Data regarding transfer (except providing access), as well as processing or conditions of processing (except obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by Russian Federation legislation.
10.7. The Operator ensures confidentiality of personal data when processing it.
10.8. The Operator stores personal data in a form that allows identification of the Subject of Personal Data no longer than required for the purposes of processing personal data, unless the storage period is established by federal law, contract, party to which, beneficiary, or guarantor who is the Subject of Personal Data.
10.9. Conditions for termination of personal data processing may include achieving the purposes of processing, expiration of the validity period of the Subject of Personal Data’s consent, withdrawal of consent by the Subject of Personal Data, or detection of unlawful processing of personal data.

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

11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data with receipt and/or transmission of received information via information-telecommunication networks or without them.

12. Cross-border transfer of personal data

12.1. Before initiating cross-border transfer of personal data, the Operator must ensure that the foreign country to whose territory the personal data are intended to be transferred provides reliable protection of the rights of Subjects of Personal Data.
12.2. Cross-border transfer of personal data to territories of foreign states that do not meet the above requirements may only be carried out in the presence of written consent from the Subject of Personal Data for cross-border transfer of their personal data and/or execution of a contract, party to which is the Subject of Personal Data.

13. Confidentiality of personal data

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

14. Final Provisions

14.1. The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at info@nova-media.pro.
14.2. Any changes to the Operator’s policy on processing personal data will be reflected in this document. This policy remains valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at the address https://nova-media.pro/privacy-policy.

See also