Policy on the Processing of Personal Data
1 General Provisions

1. This Policy on the Processing of Personal Data is formulated in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Artur Horkh (hereinafter referred to as the Operator).
2. 1.1. The Operator sets as its main objective and condition for conducting its activities the respect for the rights and freedoms of individuals when processing their personal data, including the protection of rights to inviolability of private life, personal and family secrets.
3. 1.2. This Operator’s Policy on the Processing of Personal Data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about the visitors of the website https://agency228.com/en.

2 Main 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 cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website - a combination of graphic and informational materials, as well as computer software and databases, ensuring their availability on the Internet at the network address https://agency228.com/en.
2.4. Personal data information system - a combination of personal data contained in databases and providing their processing with information technologies and technical means.
2.5. Anonymization of personal data - actions as a result of which it is impossible to determine without using additional information the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or physical person, 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, 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://agency228.com/en.
2.9. Personal data allowed by the subject of personal data for dissemination - personal data, access to which is granted to an unlimited circle of people by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner provided for by the Law on Personal Data (hereinafter - personal data allowed for dissemination).
2.10. User - any visitor to the website https://agency228.com/en.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including disclosure of personal data in the media, posting on information and telecommunication 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 the authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data are irretrievably 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 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 the subject of personal data withdraws consent to the processing of personal data, as well as sends a request to cease the processing of personal data, the Operator has the right to 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 regulatory 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, at his request, with information concerning the processing of his personal data;
• organize the processing of personal data in the manner established by the current 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 personal data subjects with the necessary information at the request of this body within 10 days from the date of receipt of such a request;
• publish or otherwise provide unrestricted access to this Policy on 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, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
• stop the transfer (dissemination, provision, access) of personal data, stop the 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 Main 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. The information is provided by the Operator to the subject of personal data in an accessible form and should not contain personal data related to other subjects of personal data, unless there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• demand from the operator to clarify their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the declared purpose of processing, as well as take measures provided for by law to protect their rights;
• impose a condition of prior consent when processing personal data for the purposes of marketing goods, works and services;
• to withdraw consent to the processing of personal data, and also, to send a demand to stop the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court the unlawful actions or inaction of the Operator when processing their personal data;
• exercise other rights provided by Russian law.

4.2. Personal data subjects are obliged to:

• provide the Operator with reliable information about themselves;
• notify the Operator about the specification (update, change) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another subject of personal data without the latter's consent, are liable in accordance with Russian law.

5 Principles of personal data processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and volume of the processed personal data correspond to the declared purposes of processing. The redundancy of processed personal data in relation to the declared purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their adequacy, and in necessary cases, relevance to the purposes of personal data processing is ensured. The operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of personal data processing, if the period of storage of personal data is not established by federal law, a contract, a party to which, the beneficiary, or the guarantor under which is the subject of personal data. The processed personal data is destroyed or anonymized upon reaching the purposes of processing or in case of losing the need to achieve these purposes unless otherwise provided by federal law.
Purposes of personal data processing
The purpose of processing is to inform the User by sending electronic mails. Personal data: surname, name, patronymic, email address, phone numbers.
Legal basis: Federal law "On information, information technologies and information protection" dated 27.07.2006 N 149-FZ.
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
Conditions of personal data processing
7.1. The processing of personal data is carried out with the consent of the subject of personal data to process his personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or the law, for the performance of the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a court act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract, a party to which or a beneficiary or guarantor under which is the subject of personal data, as well as for the conclusion of 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. Processing of personal data 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 this does not violate the rights and freedoms of the subject of personal data.
7.6. Processing of personal data is carried out, access to which is provided to an unlimited circle of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for the collection, storage, transfer 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 prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the implementation of current legislation, or if the subject of personal data has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address slashstudio.by@gmail.com marked "Personal data update".
8.4. The term of personal data processing is determined by the achievement of the purposes for which personal data were collected, unless another term is provided for by the contract or current legislation.
The User can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator by email to the email address of the Operator slashstudio.by@gmail.com marked "Withdrawal of consent to the processing of personal data".
8.5. All information that is collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the subject of personal data on the transfer (except for providing access), as well as on processing or conditions of processing (except for receiving access) personal data allowed for distribution, are not valid 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 when processing them.
8.8. The Operator stores personal data in a form that allows the identification of the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, a contract, a party to which, the beneficiary or guarantor of which is the subject of personal data.
8.9. The condition for termination of personal data processing can be the achievement of the purposes of personal data processing, the expiration of the subject's personal data consent, the withdrawal of consent by the subject of personal data or the requirement to stop processing personal data, as well as the identification of unlawful personal data processing.

1. List of actions performed by the Operator with received personal data
2. 9.1. The Operator carries out collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
3. 9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of received information via information and telecommunication networks or without such.
4. Cross-border transfer of personal data
5. 10.1. The Operator, before starting to carry out activities related to the cross-border transfer of personal data, must notify the authorized body for the protection of personal data subjects about its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
6. 10.2. Before submitting the above notification, the Operator must obtain from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
7. Confidentiality of personal data
8. The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
9. Final provisions
10. 12.1. The User can receive any clarifications on questions of interest related to the processing of his personal data by contacting the Operator via email at slashstudio.by@gmail.com.
11. 12.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is in effect indefinitely until it is replaced by a new version.
12. 12.3. The current version of the Policy is freely available on the Internet at https://agency228.com/privacy_policy.