Personal Data Processing Policy

1. General Provisions This personal data processing policy 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 determines the procedure for processing personal data and the measures to ensure the security of personal data taken by Lydia Alexandrovna Igolnikova (hereinafter referred to as the Operator). 1.1. The Operator's primary goal and condition for conducting its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal, and family secrets. 1.2. This policy of the Operator 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://handpanschool.ru.
2. Key Terms Used in the Policy 2.1. Automated Processing of Personal Data — processing of personal data using computer technology.
3. 2.2. Blocking of Personal Data — temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
4. 2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their accessibility on the Internet at the network address https://handpanschool.ru.
5. 2.4. Personal Data Information System — a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
6. 2.5. Anonymization of Personal Data — actions resulting in the inability to determine, without additional information, the ownership of personal data to a specific User or another personal data subject.
7. 2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed with or without automation means on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
8. 2.7. Operator — a state body, municipal body, legal entity, or individual organizing and/or performing personal data processing, determining the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
9. 2.8. Personal Data — any information related directly or indirectly to a specific or identifiable User of the website https://handpanschool.ru.
10. 2.9. Personal Data Permitted for Distribution by the Data Subject — personal data made accessible to an unlimited number of people by the personal data subject through consent for processing the personal data permitted for distribution in the manner provided by the Personal Data Law (hereinafter — personal data permitted for distribution).
11. 2.10. User — any visitor to the website https://handpanschool.ru.
12. 2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or group of persons.
13. 2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an undefined group of persons (transmitting personal data) or familiarizing an unlimited group of persons with personal data, including the publication of personal data in mass media, placing it in information and telecommunications networks, or providing access to personal data in any other way.
14. 2.13. Cross-Border Transfer of Personal Data — transferring personal data to the territory of a foreign country to the authority of a foreign country, a foreign individual, or a foreign legal entity.
15. 2.14. Destruction of Personal Data — any actions that result in the irreversible destruction of personal data, preventing the further recovery of personal data content in the personal data information system and/or destruction of physical media of personal data.
16. Operator's Rights and Obligations 3.1. The Operator has the right to:

• Receive accurate information and/or documents containing personal data from the data subject.
• If the data subject withdraws consent for personal data processing or requests the cessation of personal data processing, the Operator may continue to process personal data without the data subject’s consent 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 set forth by the Personal Data Law and regulations adopted in accordance with it, unless otherwise stipulated by the Personal Data Law or other federal laws.

3.2. The Operator is obligated to:

• Provide the data subject with information regarding the processing of their personal data upon request.
• Organize personal data processing in accordance with current Russian Federation legislation.
• Respond to requests and inquiries from data subjects and their legal representatives in compliance with the requirements of the Personal Data Law.
• Provide the authorized body for the protection of personal data subjects' rights with the necessary information within 10 days of receiving such a request.
• Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing.
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions.
• Cease transmission (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases specified in the Personal Data Law.
• Fulfill other obligations stipulated by the Personal Data Law.

1. Personal Data Subjects' Rights and Obligations 4.1. Data subjects have the right to:

• Receive information regarding the processing of their personal data, except in cases provided by federal laws. Information will be provided by the Operator in an accessible form and should not contain personal data of other data subjects, except when there are lawful grounds for disclosing such data. The list of information and the procedure for obtaining it is established by the Personal Data Law.
• Require the Operator to clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take measures to protect their rights as provided by law.
• Demand prior consent for processing personal data for marketing purposes.
• Withdraw consent for personal data processing and submit a request for the cessation of personal data processing.
• Appeal to the authorized body for the protection of personal data subjects' rights or take legal action against unlawful actions or omissions by the Operator in processing personal data.
• Exercise other rights provided by Russian Federation legislation.

4.2. Data subjects are obligated to:

• Provide the Operator with accurate data about themselves.
• Inform the Operator of any updates (changes, corrections) to their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another data subject without the latter's consent are responsible in accordance with Russian Federation legislation.

1. Principles of Personal Data Processing 5.1. Personal data processing is carried out on a lawful and fair basis.
2. 5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing personal data for purposes incompatible with those for which the data was collected is not allowed.
3. 5.3. Combining databases containing personal data, processed for purposes that are incompatible with each other, is prohibited.
4. 5.4. Only personal data necessary for processing purposes should be processed.
5. 5.5. The content and volume of personal data being processed should correspond to the declared purposes of processing. Over-processing of personal data beyond the stated purposes is prohibited.
6. 5.6. When processing personal data, accuracy, adequacy, and, where necessary, relevance to the purposes of processing should be ensured. The Operator takes necessary measures to delete or correct incomplete or inaccurate data.
7. 5.7. Personal data is stored in a form that allows identification of the data subject only for as long as necessary to achieve the purposes of processing, unless the storage period is established by federal law, a contract, or the data subject's participation as a party or beneficiary to the contract. Personal data is destroyed or anonymized once the processing goals are achieved or if it is no longer necessary to achieve these goals, unless otherwise stipulated by federal law.

Purpose of Processing: The ability to contact the User.
6. Personal Data: Last name, first name, patronymic
Email address
Telegram nickname
Legal Grounds: Federal Law "On Information, Information Technologies, and Information Protection" of July 27, 2006, N 149-FZ (latest edition).
Types of Personal Data Processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
Conditions for Processing Personal Data: 7.1. Personal data processing is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes defined by international treaties of the Russian Federation or the law, to carry out the functions, powers, and duties assigned by the legislation of the Russian Federation to the operator.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, an act of another body or official, which is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract where the personal data subject is either a party, a beneficiary, or a guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract where the personal data subject will be a beneficiary or a guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data is processed, which is made accessible to an unlimited number of people by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data is processed, which is subject to publication or mandatory disclosure in accordance with federal law.
Procedure for Collecting, Storing, Transmitting, 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 in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude unauthorized access to personal data.
8.2. Personal data of the User will never be transferred to third parties under any circumstances, except in cases related to the execution of applicable law or if the personal data subject has given the Operator consent to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are found, the User may update them independently by sending a notification to the Operator's email address lidafelt@gmail.com with the subject "Personal Data Update."
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected unless a different period is specified in the contract or by applicable law. The User may withdraw their consent to process personal data at any time by sending a notification to the Operator’s email address lidafelt@gmail.com with the subject "Withdrawal of Consent to Process 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 these entities (Operators) in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties, including those mentioned in this paragraph.
8.6. Restrictions imposed by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions for processing (except for access), of personal data permitted for distribution, do not apply in cases of processing personal data in the interests of the state, public, or other public purposes defined by Russian Federation legislation.
8.7. The Operator ensures confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required for the purposes of processing, unless a storage period is defined by federal law, contract, or by the personal data subject's status as a party, beneficiary, or guarantor under the contract.
8.9. The condition for stopping the processing of personal data may be the achievement of the purposes of processing, the expiration of the personal data subject’s consent, the withdrawal of consent, or a request to stop processing personal data, as well as the detection of unlawful processing.
List of Actions Performed by the Operator with the Collected Personal Data: 9.1. The Operator collects, records, systematizes, accumulates, stores, updates (modifies), extracts, uses, transmits (distributes, provides access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data by receiving and/or transmitting the obtained information over telecommunications networks or without it.
Cross-Border Transfer of Personal Data: 10.1. Before starting cross-border transfer of personal data, the Operator must notify the authorized body for personal data protection of their intention to carry out cross-border personal data transfer (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from foreign authorities, foreign individuals, or foreign legal entities to which the personal data is planned to be transferred.
Confidentiality of Personal Data: The Operator and other individuals who have access to personal data must not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
Final Provisions: 12.1. The User can get any clarifications on issues related to the processing of their personal data by contacting the Operator via email at lidafelt@gmail.com.
12.2. Any changes to the personal data processing policy of the Operator will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at the address: https://handpanschool.ru/privacypolicyenglish.