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 referred to as the Personal Data Law) and establishes the procedure for processing personal data and measures to ensure the security of personal data taken by Danis Nailevich Garifullin (hereinafter referred to as the Operator).
1.1. The Operator's most important goal and condition for carrying out its activities is to ensure the rights and freedoms of individuals during the processing of their personal data, including the protection of rights related to privacy, personal, and family secrets.
1.2. This Operator's policy concerning personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://lagomcg.com.
2. Key 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 suspension of personal data processing (except when 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://lagomcg.com.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions resulting in the inability to determine, without using additional information, the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with personal data using automation tools or without them, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a government body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, and also 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 directly or indirectly related to a specific or identifiable User of the website https://lagomcg.com.
2.9. Personal data permitted by the subject of personal data for distribution — personal data for which access is granted to an unlimited number of persons by the subject of personal data by giving consent for the processing of personal data permitted by the subject of personal data for distribution in the manner provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://lagomcg.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or to familiarizing an unlimited number of persons with personal data, including publication of personal data in mass media, placement on information and telecommunications networks, or granting 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 government body of a foreign state, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of physical media of personal data.
3. Main 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 of withdrawal of consent by the subject of personal data for processing their data, as well as for submitting a request for stopping the processing of personal data, the Operator has the right to continue processing personal data without consent from the subject of personal data if there are grounds stipulated in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the 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 subject of personal data, at their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedures 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;
— inform the authorized body for the protection of the rights of subjects of personal data upon request of this body of the necessary information within 10 days from the date of receipt of 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 of personal data, as well as from other unlawful actions concerning personal data;
— cease the transfer (distribution, provision, access) of personal data, stop the processing and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. Main Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data related to other subjects of personal data unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block, or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— impose a condition for prior consent when processing personal data for the purposes of promoting goods, work, and services in the market;
— withdraw consent for processing personal data, as well as submit a request to stop processing 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 during the processing of their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable data about themselves;
— notify the Operator of any changes (updating, modifying) of their personal data.
4.3. Individuals who have provided the Operator with false information about themselves or about another subject of personal data without the latter's consent shall bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a legal and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the processing objectives shall be processed.
5.5. The content and scope of processed personal data conform to the declared processing purposes. The collection of personal data that exceeds the declared processing objectives is not allowed.
5.6. During the processing of personal data, accuracy, adequacy, and relevance concerning the processing objectives shall be ensured. The Operator takes the necessary measures and/or ensures the acceptance of measures regarding the removal or clarification of incomplete or inaccurate data.
5.7. Personal data storage is carried out in a form that allows the identification of the subject of personal data for no longer than required by the processing objectives unless the storage period of personal data is established by federal law, a contract, where the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized once the processing objectives are achieved or if the necessity to achieve these objectives ceases unless otherwise provided by federal law.
6. Objectives of Personal Data Processing
The purpose of processing User personal data includes:
— providing access to services, information, and/or materials contained on the website https://lagomcg.com;
— processing incoming requests and communication with Users;
— informational support, including the distribution of advertising and informational materials;
— conducting marketing, statistical, and other research.
Personal data includes:
— name;
— contact phone.
Legal basis: Federal Law on Information, Information Technologies, and Protection of Information dated July 27, 2006 N 149-FZ.
Types of processing personal data include: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
7. Conditions for Personal Data Processing
7.1. Personal data processing is performed with the consent of the subject of personal data to process their personal data.
7.2. Personal data processing is necessary to achieve objectives provided by an international treaty of the Russian Federation or law, to carry out the functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. Personal data processing is necessary to administer justice, execute a court ruling, act of another authority, or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract where the subject of personal data is a party, beneficiary, or guarantor, and for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
7.5. Personal data processing is necessary for pursuing 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 subject of personal data are not violated.
7.6. Processing of personal data may be conducted, the access to which has been granted by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data that must be published or disclosed in accordance with federal law is conducted.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the area of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never be disclosed to third parties under any circumstances, except in cases related to compliance with applicable laws or if the subject of personal data consents to the Operator transferring data to a third party for fulfilling obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the email address lagomcgstudio@gmail.com with the subject "Updating Personal Data".
8.4. The period for processing personal data is determined by the achievement of the objectives for which the personal data was collected unless a different period is provided by the contract or current legislation. The User can withdraw their consent for the processing of personal data at any time by sending the Operator a notification via email to lagomcgstudio@gmail.com with the subject "Withdrawal of Consent for Processing Personal Data".
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers is stored and processed by specified parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the indicated documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Restrictions imposed by the personal data subject on the transfer (except for providing access) and on processing or conditions for processing (except for obtaining access) of personal data permitted for distribution shall 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 during the processing of personal data.
8.8. The Operator stores personal data in a form allowing the identification of the subject of personal data no longer than required by the processing objectives unless the storage period of personal data is established by federal law, a contract, where the subject of personal data is a party, beneficiary, or guarantor.
8.9. Conditions for ceasing personal data processing may include achieving the processing objectives, expiration of the subject of personal data's consent, withdrawal of consent by the subject of personal data, or request for cessation of personal data processing, as well as identifying unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data Received
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of obtained information through information and telecommunications networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before the commencement of cross-border transfer of personal data, the Operator must 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 (this 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 from the authorities of the foreign state, foreign individuals, and legal entities to which the cross-border transfer of personal data is planned, the corresponding information.
11. Confidentiality of Personal Data
The Operator and other individuals who have access to personal data are required 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 may receive any clarifications on issues related to the processing of their personal data by contacting the Operator via email at lagomcgstudio@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 freely available on the Internet at https://lagomcg.com/policy.