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Personal Data Processing Policy

1. General Provisions This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter – the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Belyj Veter (hereinafter – the Operator). 1.1. The Operator sets as its most important goal and condition for the performance of its activities the observance of 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 Operator's policy regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors to the website https://belyj-veterstocks.com.
2. Basic Concepts Used in the Policy 2.1. Automated processing of personal data – processing of personal data using computer equipment. 2.2. Blocking of personal data – temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data). 2.3. Website – 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 https://belyj-veterstocks.com. 2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing. 2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, 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, and 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, and 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://belyj-veterstocks.com. 2.9. Personal data permitted by the subject of personal data for distribution – personal data, access to which by an unlimited circle of persons is granted 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 – personal data permitted for distribution). 2.10. User – any visitor to the website https://belyj-veterstocks.com. 2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons. 2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or acquainting an unlimited circle of persons with personal data, including publishing personal data in mass media, posting in information and telecommunications 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 a foreign government authority, a foreign individual, or a foreign legal entity. 2.14. Destruction of personal data – any actions as a result of which personal data is irreversibly destroyed 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 reliable information and/or documents containing personal data from the subject of personal data; – in the event of withdrawal by the subject of personal data of consent to the processing of personal data, 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 normative legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws. 3.2. The Operator is obliged to: – provide the subject of personal data, upon request, with information concerning the processing of their personal data; – organize the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation; – respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law; – provide the authorized body for the protection of the rights of subjects of personal data, upon its request, with the necessary information within 30 days from the date of receipt of such 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 unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions; – cease the transfer (distribution, provision, access) of personal data, stop 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 Personal Data Subjects 4.1. Personal data subjects 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 must not contain personal data relating to other subjects of personal data, unless there are legitimate grounds for disclosing such data. The list of information and the procedure for obtaining it is established by the Personal Data Law; – demand from the Operator the 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, as well as take statutory measures to protect their rights; – set the condition of prior consent when processing personal data in order to promote goods, works, and services on the market; – withdraw consent to the processing of personal data; – appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions 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 obliged to: – provide the Operator with accurate information about themselves; – notify the Operator regarding the clarification (updating, changing) 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. Personal Data Processed by the Operator 5.1. Full name (Surname, first name, patronymic). 5.2. Email address. 5.3. Phone numbers. 5.4. The website also collects and processes depersonalized data about visitors (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others). 5.5. The above data are hereinafter collectively referred to in this Policy as Personal Data. 5.6. The processing of special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, or intimate life is not carried out by the Operator. 5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Personal Data Law are observed. 5.8. The User's consent to the processing of personal data permitted for distribution is executed separately from other consents to the processing of their personal data. In doing so, the conditions provided for in Art. 10.1 of the Personal Data Law must be observed. 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 distribution directly to the Operator. 5.8.2 The Operator is obliged, no later than three working days from the date of receipt of the User's consent, to publish information on processing conditions, the existence of prohibitions, and conditions for processing personal data permitted for distribution by an unlimited circle of persons. 5.8.3 The transfer (distribution, provision, access) of personal data permitted for distribution must be terminated at any time upon request of the subject of personal data. This request must include the full name, contact information (phone number, email address, or postal address) of the subject of personal data, and a list of personal data whose processing must be terminated. The personal data specified in this request can only be processed by the Operator to whom it is sent. 5.8.4 Consent to the processing of personal data permitted for distribution terminates upon receipt by the Operator of the request specified in clause 5.8.3 of this Policy.


6. Principles of Personal Data Processing 6.1. Processing of personal data is carried out on a legal and fair basis. 6.2. Processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted. 6.3. Merging databases containing personal data processed for mutually incompatible purposes is prohibited. 6.4. Only personal data that meets the purposes of processing is subject to processing. 6.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes is not permitted. 6.6. When processing personal data, accuracy, sufficiency, and relevance in relation to the processing purposes are ensured. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data. 6.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data for no longer than required by the processing purposes, unless the storage period is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.


7. Purposes of Personal Data Processing 7.1. The purpose of processing the User's personal data: – informing the User by sending emails; – conclusion, execution, and termination of civil contracts; – providing the User with access to services, information, and/or materials contained on the website https://belyj-veterstocks.com. 7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can opt out of receiving informational messages at any time by sending an email to the Operator at belyj.veterstocks@gmail.com with the subject line "Unsubscribe from notifications of new products, services, and special offers". 7.3. Depersonalized User data collected through internet statistics services is used to collect information about User actions on the website and to improve the quality of the website and its content.


8. Legal Grounds for Personal Data Processing 8.1. The legal grounds for the processing of personal data by the Operator are: – statutory documents of the Operator; – contracts concluded between the Operator and the subject of personal data; – federal laws and other regulatory legal acts in the field of personal data protection; – User consents to the processing of their personal data and to 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 website https://belyj-veterstocks.com or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User agrees to this Policy. 8.3. The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (saving cookies and the use of JavaScript technology are enabled). 8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, voluntarily, and in their own interest.


9. Conditions for Personal Data Processing 9.1. Personal data processing is carried out with the consent of the subject of personal data. 9.2. Processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, and for the implementation of functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation. 9.3. Processing is necessary for the administration of justice or the execution of a judicial act or an act of another authorized body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings. 9.4. Processing is necessary for the execution of a contract to which the subject of personal data is a party, beneficiary, or guarantor, or for concluding a contract at the initiative of the subject of personal data. 9.5. Processing 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. 9.6. Processing is carried out for personal data to which access is provided to an unlimited circle of persons by the subject of personal data or at their request (publicly available personal data). 9.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.


10. Procedure for Collection, Storage, Transfer, and Other Types of Processing The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to comply with the requirements of applicable legislation in the field of personal data protection. 10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access by unauthorized persons. 10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of applicable legislation or if the subject of personal data has given consent to the transfer of data to a third party to fulfill obligations under a civil contract. 10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address belyj.veterstocks@gmail.com with the subject line "Updating personal data". 10.4. The processing period is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending a notification via email to belyj.veterstocks@gmail.com with the subject line "Withdrawal of consent to personal data processing". 10.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or User must familiarize themselves with these documents independently. The Operator is not responsible for the actions of third parties. 10.6. Prohibitions established by the subject of personal data on the transfer (except for providing access) or processing 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. 10.7. The Operator ensures the confidentiality of personal data during processing. 10.8. The Operator stores personal data in a form that permits identification of the subject of personal data for no longer than required by the processing purposes, unless the storage period is established by federal law or contract. 10.9. Termination of personal data processing may occur upon achieving the processing purposes, expiration or withdrawal of consent by the subject of personal data, or upon detecting unlawful processing of personal data.


11. List of Actions Performed by the Operator with Personal Data 11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data. 11.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of received information via information and telecommunications networks or without such transmission.
12. Cross-Border Transfer of Personal Data 12.1. Prior to commencing a cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer is intended ensures reliable protection of the rights of personal data subjects. 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 with the written consent of the subject of personal data to the cross-border transfer and/or execution of a contract to which the subject of personal data is a party.
13. Confidentiality of Personal Data The Operator and other persons who have obtained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final Provisions 14.1. The User can obtain any clarification on issues regarding the processing of their personal data by contacting the Operator via email at belyj.veterstocks@gmail.com. 14.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The 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 https://belyj-veterstocks.com/privacy.