Политика конфиденциальности

1. General

This Personal Data Processing Policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 ‘On Personal Data’ (hereinafter the “Personal Data Law”) and defines the procedure for processing personal data and personal data safeguards taken by Elena Aleksandrovna Bunkova, Sole Proprietor (hereinafter the “Processor”).

1.1. The Processor sets as its primary goal and terms to carry out its activities the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Processor’s personal data policy (hereinafter the “Policy”) shall apply to all information that the Processor can obtain about the visitors to https://noborderstranslator.com/.

2. Basic Terms Used in the Policy

2.1. Automated data processing shall mean processing of personal data using computer technology.
2.2. Data blocking shall mean temporary suspension of personal data processing (except in cases where processing is required to clarify personal data).
2.3. Website shall mean a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability online at https://noborderstranslator.com/.
2.4. Personal data information system shall mean a set of personal data contained in databases and information technology and technical means that ensure personal data processing.
2.5. Data depersonalization shall mean actions as a result of which it is impossible to determine, without using additional information, whether certain personal data belongs to a specific User or other data subject.
2.6. Personal data processing shall mean any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including personal data collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.
2.7. Processor shall mean a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or processing personal data, as well as determining the objectives of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data shall mean any information related directly or indirectly to a specific or identifiable User of https://noborderstranslator.com/.
2.9. Personal data authorized by data subject for dissemination shall mean personal data, access to which is provided to the public at large by the data subject by giving consent to the processing of personal data authorized by the data subject to be disseminated in accordance with the procedure provided for by the Personal Data Law (hereinafter “personal data authorized for dissemination”).
2.10. User shall mean any visitor to https://noborderstranslator.com/.
2.11. Data provision shall mean actions aimed at disclosing personal data to a certain person or a certain circle of people.
2.12. Data dissemination shall mean any action aimed at disclosing personal data to an indefinite circle of people (transfer of personal data) or familiarization of the public at large with personal data, including the publication of personal data in the media, posting online or providing access to personal data in any other way.
2.13. Cross-border data transfer shall mean the transfer of personal data to the territory of a foreign state to a foreign state public authority, a foreign individual or a foreign legal entity.
2.14. Data destruction shall mean any action as a result of which personal data is destroyed permanently with the inability to further restore the content of personal data in the personal data information system and/or physical media of personal data are destroyed.

3. Basic Rights and Obligations of the Processor

3.1. The Processor may:

—Receive reliable information and/or documents containing personal data from the data subject;

—In case the data subject withdraws consent to the processing of personal data, as well as sends a request to terminate the processing of personal data, the Processor may continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;

—Independently determine the composition and list of measures required and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Processor shall:

—Provide the data subject, at their request, with information concerning the processing of their personal data;

—Organize the processing of personal data in accordance with the procedure established by the laws of the Russian Federation currently in force;

—Respond to requests and queries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

—Report to the Data Subject Right Protection Authority, at its request, the necessary information within 10 days from the date of receipt of such a request;

—Publish or otherwise provide unrestricted access to this Personal Data Processing Policy;

—Take legal, managerial, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other illegal actions in relation to personal data;

—Stop the personal data transfer (distribution, provision, access), stop processing and destroy personal data as and where stipulated by the Personal Data Law;

—Perform other duties provided for by the Personal Data Law.

4. Basic Rights and Obligations of Data Subject

4.1. The data subjects may:

—Obtain information regarding the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to a data subject simply stated by the Processor, and it shall not contain personal data related to other data subjects, except in cases where there are legitimate grounds for such personal data disclosure. The list of information and the procedure for obtaining it is established by the Personal Data Law;

—Require the Processor to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated objective of processing, as well as take measures provided for by law to protect their rights;

—Put forward a condition of prior consent when processing personal data in order to promote goods, work or services in the market;

—Withdraw consent to the processing of their personal data, as well as to send a request to terminate the processing of their personal data;

—Appeal to the Data Subject Right Protection Authority or in court against the Processor’s illegal actions or omissions during the processing of their personal data;

—Exercise other rights provided for by the laws of the Russian Federation.

4.2. Data subjects shall:

—Provide the Processor with reliable data about themselves;

—Notify the Processor about clarification (update, change) of their personal data.

4.3. Persons who provided the Processor with false information about themselves or information about another data subject without the consent of the latter shall be held liable in accordance with the laws of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed in a lawful and equitable way.

5.2. Processing of personal data shall be limited to the achievement of specific, predetermined and legitimate objectives. Processing of personal data incompatible with the objectives of personal data collection is not allowed.

5.3. It is not allowed to merge databases containing personal data being processed for incompatible objectives.

5.4. Only personal data that meets the objectives of its processing shall be processed.

5.5. The content and scope of personal data being processed shall correspond to the stated objectives of processing. Redundancy of the personal data being processed in relation to the stated objectives of its processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, its sufficiency and, where necessary, relevance in relation to the personal data processing objectives shall be ensured. The Processor shall take the measures required (and/or have the measures taken) to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than required by the objectives of personal data processing, unless the period of personal data storage is established by federal law, an agreement to which the data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the objectives of processing or in case of loss of necessity to achieve those objectives, unless otherwise provided for by federal law.

6. Objectives of Personal Data Processing

Objective of processing	To inform the User by sending e-mails
Personal data	Name, patronymic, surname E-mail address
Legal grounds	Agreements entered into by and between the Processor and the data subject Federal Law ‘On Information, Information Technology and Information Protection’ No. 149-FZ dated July 27, 2006
Types of personal data processing	Transfer of personal data

7. Terms of Personal Data Processing

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

7.2. Processing of personal data is required to achieve the objectives provided for by an international treaty of the Russian Federation or by law, to fulfill the functions, powers, and duties assigned to the Processor by the laws of the Russian Federation.

7.3. Processing of personal data is required to administer justice, enforce a judicial act, act of another body or official subject to enforcement in accordance with the laws of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is required to perform a contract to which the data subject is a party or beneficiary or guarantor, as well as to enter into a contract at the initiative of the data subject or a contract whereunder the data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is required to exercise the Processor’s or third parties’ rights and legitimate interests or for the achievement of public objectives, provided that the rights and freedoms of the data subject are not violated.

7.6. We process personal data to which the public at large have access granted by the data subject, or to which the access has been granted at the data subject’ request (hereinafter “publicly available personal data”).

7.7. We process personal data that is subject to publication or mandatory disclosure in accordance with federal law.

8. Personal Data Collection, Storage, Transfer and Other Types of Personal Data Processing

Protection of personal data being processed by the Processor shall be maintained by implementing legal, managerial and technical measures required to fully comply with the requirements of personal data protection laws currently in force.

8.1. The Processor shall maintain personal data protection and take all reasonable safeguards aimed at preventing unauthorized access thereto.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of laws currently in force or if the data subject has given consent to the Processor to transfer data to a third party in order to fulfill their obligations under a civil contract.

8.3. In case of identifying inaccuracies in personal data, the User may update it by himself/herself by sending a notice to the Processor to the Processor’s e-mail address at info@elena-a-bunkova.com marked as “Personal Data Update”.

8.4. The period of personal data processing shall be determined by the achievement of the objectives for which the personal data was collected, unless another period is stipulated by the agreement or applicable law.
The User may withdraw their consent to the processing of their personal data at any time by sending a notice to the Processor to the Processor’s e-mail address at info@elena-a-bunkova.com marked as “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, shall be stored and processed by those persons (Processors) in accordance with their User Agreement and Privacy Policy.The data subject and/or User shall familiarize themselves with the said documents in a timely manner. The Processor shall not be liable for the actions of third parties, including the service providers mentioned in this clause.

8.6. The prohibitions established by the data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of their personal data authorized for dissemination shall not apply in cases of processing personal data in the state, public, and other public interest as defined by the laws of the Russian Federation.

8.7. When processing personal data, the Processor shall keep such personal data confidential.

8.8. Personal data shall be stored by the Processor in a form that allows identification of the data subject for no longer than required by the objectives of personal data processing, unless the period of personal data storage is established by federal law, an agreement to which the data subject is a party, beneficiary or guarantor.

8.9. The condition for the termination of personal data processing may be the achievement of the objectives of personal data processing, expiration of the data subject’s consent, withdrawal of consent by the data subject or requirement to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Processor with the Personal Data Obtained

9.1. The Processor may collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete, and destroy personal data.

9.2. The Processor shall perform automated processing of personal data with or without receiving and/or transmitting the obtained information via telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. The Processor shall notify the Data Subject Right Protection Authority of its intention to perform cross-border transfer of personal data (such notification shall be sent separately from the notification on the intention to perform personal data processing) prior to the commencement thereof.

10.2. Prior to submitting the above-mentioned notification, the Processor shall obtain relevant information from the foreign state public authorities, foreign individuals, foreign legal entities to whom the personal data is expected to be transferred.

11. Confidentiality of Personal Data

The Processor and other persons who have access to personal data shall not disclose and not disseminate personal data to third parties without the consent of data subject, unless otherwise provided for by federal law.

12. Miscellaneous

12.1. The User may obtain any clarification on issues of interest regarding the processing of their personal data by contacting the Processor via e-mail at info@elena-a-bunkova.com.

12.2. This document will be updated as per any possible amendment to the Processor’s Personal Data Processing Policy. The Policy shall be in effect indefinitely until it is replaced by its new version.

12.3. The latest Policy version is freely available online at https://noborderstranslator.com/privacy-policy/.