1. General regulations

This personal data processing policy was created in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FL “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by the Primakov Center (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen when processing their personal data, including the protection of the rights 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 any information that the Operator can obtain about visitors to the website https://primakovcenter.ru.

2. Basic concepts used in the Policy

2.1 Automated processing of personal data is the processing of personal data using computer technology.

2.2 Blocking of personal data is the temporary termination of the processing of personal data (except for cases where processing is necessary to clarify personal data).

2.3 A website is a set of graphic and informational materials, as well as computer programs and databases, which ensure their availability on the Internet at the network address https://primakovcenter.ru.

2.4 Information system of personal data is a set of personal data contained in databases, and information technologies and technical means which provide the processing of them.

2.5 De-personalization of personal data results in the inability to determine the ownership of personal data of a particular User or other subject of personal data without possessing additional information.

2.6 Processing of personal data is any action (operation), or a set of actions (operations) performed with the application of automation tools or without using such tools towards personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, usage, transfer (distribution, provision, access), de-personalization, blocking, erasure and destruction of personal data.

2.7 The Operator is a state body, municipal body, legal entity or individual, which independently or jointly with other persons organizes and (or) carries 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 is any information that relates directly or indirectly to a specific or identifiable User of the website https://primakovcenter.ru.

2.9 Personal data, permitted by the subject of personal data for distribution, is personal data, an access of an unlimited number of persons to which 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 as stated by the Law on Personal Data (hereinafter – personal data permitted for distribution).

2.10 The User is any visitor to the website https://primakovcenter.ru.

2.11 Provision of personal data is action aimed at disclosing personal data to a certain person or a certain group of persons.

2.12 Distribution of personal data is any action aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks, or granting access to personal data in any other way.

2.13 Cross-border transfer of personal data is the transfer of personal data to the authority of a foreign state, to a foreign individual or foreign legal entity in the territory of a foreign state.

2.14 Destruction of personal data is any action which results in the irrevocable destruction of personal data without the possibility of further restoring the content of personal data in the information system and/or the destruction of material mediums of personal data.

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

– if the subject of personal data withdraws consent for 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 Law on Personal Data

– to determine independently the composition and list of necessary and sufficient measures to ensure the fulfilment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged:

– to provide the subject of personal data with information regarding the processing of their personal data upon their request

– to organize the processing of personal data as stated by the current legislation of the Russian Federation

– to respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data

– to provide the authorized body for the protection of the rights of personal data subjects, at the request of this body, with the necessary information within 30 days from the date of receipt of such a request

– to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data

– to take legal, organizational and technical actions to protect personal data from unauthorized or accidental access to it, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions related to personal data

– to stop the transfer (distribution, provision, access) of personal data, to stop the processing and destroy personal data in the manner and in cases stated by the Law on Personal Data

– to perform other duties provided for by the Law on Personal Data.

4. Basic rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right to:

– to receive information regarding the processing of their personal data, excluding the cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating 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 is established by the Law on Personal Data

– to require the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, obtained illegally or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights

– to put forward a condition of prior consent when processing personal data to promote goods, works and services to the market

– to withdraw consent for the processing of personal data

– to appeal to the authorized body for the protection of the rights of subjects

– of personal data or in court on any illegal actions or inactions of the Operator taken while processing their personal data

– to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged:

– to provide the Operator with reliable data about themselves

– to inform the Operator on the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information on another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of processing personal data

5.1. The processing of personal data is carried out on a legal and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

5.4. Only personal data that meet the purposes of their processing is subject to processing.

5.5. The content and volume of the processed personal data correspond to the stated purposes of the processing. Any excess processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data is ensured, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data. The operator takes the 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 makes it possible to determine the subject of personal data, no longer than the purpose of processing personal data requires, if the storage period for personal data is not established by federal law, an agreement to which the subject of personal data is a beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing purpose or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purpose of processing the User’s personal data

6.1. Processing purposes:

·        to inform the User via email

6.2. Personal data to be processed:

·        last name, first name, middle name

·        email address

·        photos

6.3. The legal grounds for the processing of personal data by the Operator are:

·        statutory (constituent) documents of the Operator

7. Personal data processing conditions

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, is a subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the execution of an agreement, to which the subject of personal data is either a beneficiary or a guarantor, as well as for carrying out an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals if this does not violate the rights and freedoms of the subject of personal data.

7.6. The processing of personal data, access of an unlimited number of persons

to which is provided by the subject of personal data or at their request (hereinafter – publicly available personal data), is carried out.

7.7. Processing of personal data, which is subject to publication or mandatory disclosure in accordance with federal law, is carried out.

8. The procedure for collecting, storing, transferring and other types of processing of personal data

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 the 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 access to personal data by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfil obligations under a civil contract.

8.3. If personal data is inaccurate, the User can update it independently by sending a notification to the Operator using e-mail address primakov-center@yandex.ru with a heading “Updating personal data.”

8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation. The user can at any time revoke their consent to the processing of personal data by sending a notification to the Operator via e-mail to the email address of the Operator primakov-center@yandex.ru with a heading “Withdrawal of consent to the processing of personal data.”

8.5. All information that is collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize themself with these documents in a timely manner. The operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or processing conditions (except for gaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in the state, public and other social interests determined by law of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality

of personal data.

8.8. The operator stores personal data in a form that makes it possible to determine the subject of personal data, no longer than the purpose of processing personal data requires, if the storage period for personal data is not established by federal law or an agreement to which the subject of personal data is a beneficiary or guarantor.

8.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or withdrawal of consent by the subject of personal data, as well as the identification of illegal processing of personal data.

9.List of actions performed by the Operator with the received personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

9.2. The operator carries out automated processing of personal data with the receipt and/or transmission of the information received via information

and telecommunication networks or without it.

10. Transborder transfer of personal data

10.1 Before commencing transborder transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out transborder transfer of personal data (such notification shall be sent separately from the notification on the intention to carry out personal data processing).

10.2 Before submitting the above notification, the Operator shall be obliged to obtain relevant information from foreign authorities, foreign natural persons, foreign legal entities to whom transborder transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged 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 can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via e-mail at primakov-center@yandex.ru.

12.2. This document will reflect any changes in the personal data processing policy made by the Operator. The policy is valid indefinitely until it is replaced with a new version.

12.3. The current version of the Policy is openly available on the Internet at https://primakovcenter.ru.