Personal data processing policy

1. General Provisions

This personal data processing policy has been 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 taken by Artem Andreevich Zhitnik (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 right to privacy, personal and family secrets.

1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://crowncaps.su.

2. Key Concepts Used in the Policy

2.1. Automated processing of personal data is the processing of personal data using computer technology.

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

2.3. Website is a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://crowncaps.su.

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

2.5. Anonymization of personal data is actions that make it impossible to determine the ownership of personal data to a specific User or another personal data subject without the use of additional information.

2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automated tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.

2.7. Operator — a government agency, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://crowncaps.su.

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

2.10. User — any visitor to the website https://crowncaps.su.

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 number of persons (transfer of personal data) or familiarizing an indefinite number of persons with personal data, including disclosing personal data in the media, posting it on information and telecommunications 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 a foreign government, foreign individual, or foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the contents of the personal data in the personal data information system, and/or the destruction of tangible media containing the personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

  • receive reliable information and/or documents containing personal data from the personal data subject;
  • if the personal data subject revokes consent to the processing of personal data, or submits a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject, provided 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 stipulated 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 personal data subject, upon request, with information regarding the processing of his or her personal data;
  • organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
  • respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
  • notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 10 days from the date of receipt of such request;
  • publish or otherwise ensure 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 illegal actions in relation to personal data;
  • stop the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
  • fulfill other obligations stipulated by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

  • receive information regarding the processing of their personal data, except in cases stipulated by federal laws. Information is 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, unless 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;
  • require the operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
  • condition prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
  • revoke consent to the processing of personal data, as well as request the termination of the processing of personal data;
  • appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing their personal data;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obligated to:

  • provide the Operator with accurate information about themselves;
  • notify the Operator of any clarifications (updates, changes) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with Russian Federation law.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed lawfully and fairly.

5.2. Personal data shall be processed only to achieve specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes for which it was collected is prohibited.

5.3. Combining databases containing personal data processed for incompatible purposes is prohibited.

5.4. Only personal data that is relevant to the purposes for which it is processed will be processed.

5.5. The content and volume of personal data processed correspond to the stated processing purposes. Excessive amounts of personal data in relation to the stated processing purposes are not permitted.

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

5.7. Personal data is stored in a form that allows identification of the data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or if there is no longer a need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: informing the User via email.

Personal data: email address, photographs, last name and first name.

Legal basis: Federal Law "On Information, Information Technologies, and the Protection of Information" dated July 27, 2006, No. 149-FZ.

Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails.

7. Terms of personal data processing

7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, and to exercise the 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, or the 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 performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. Personal data processed by the Operator is accessible to an unlimited number of persons by the data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for collecting, storing, transferring, and otherwise processing 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 on personal data protection.

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

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has consented to the Operator transferring the data to a third party for the fulfillment of obligations under a civil law contract.

8.3. If any inaccuracies in their personal data are discovered, the User may update them independently by sending a notification to the Operator's email address info@crowncaps.su with the subject line "Updating personal data."

8.4. 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 for by the contract or applicable law.

The User may revoke their consent to the processing of their personal data at any time by sending a notification to the Operator via email at info@crowncaps.su with the subject line "Revocation 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 the specified parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or 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 on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, established by the personal data subject, do not apply in cases where personal data is processed in the state, public, or other public interests defined by Russian Federation law.

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

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

8.9. The termination of personal data processing may be conditional upon the achievement of the personal data processing purposes, expiration of the personal data subject's consent, revocation of consent by the personal data subject, or a request to cease processing the personal data, as well as the detection of unlawful processing of personal data.

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

9.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, modify), retrieve, use, transfer (disseminate, provide, access), depersonalize, block, delete, and destroy personal data.

9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

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

10.2. Prior to submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Personal Data Confidentiality

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

12. Final Provisions

12.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator by email at info@crowncaps.su.

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

12.3. The current version of the Policy is publicly available online at https://crowncaps.su/en/documents/privacy-policy/.