Personal data processing policy

1. GENERAL PROVISIONS

1.1. This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data implemented by the organization "NAT" (hereinafter referred to as the Operator).

1.2. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy, personal and family secrets, to be the most important goal and condition for its activities.

1.3. This Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may receive about visitors to the website https://www.novat74.ru (hereinafter – the Website). The Website does not control and is not responsible for third-party websites that the User may access via links available on the Website https://www.novat74.ru.

1.4. The use of the Website's services implies the User's unconditional consent to this Policy and the conditions specified in it for the processing of their personal information. If the User disagrees with these terms, they must refrain from using the services.

2. 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 suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website – a collection of graphical and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://www.novat74.ru.

2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data – actions that result in it being impossible to determine the ownership of personal data by a specific User or other personal data subject without the use of additional information.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – a state or municipal body, legal or natural person, independently or jointly with others organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the Website https://www.novat74.ru.

2.9. Personal data permitted by the subject of personal data for dissemination – personal data to which an unlimited number of persons have access provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data permitted for dissemination).

2.10. User – any visitor to the Website https://www.novat74.ru.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific 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 making personal data known to an unlimited circle of persons, including the publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.

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

2.14. Destruction of personal data – any actions as a result of which personal data are destroyed irretrievably 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. 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 personal data subject;

– in case of withdrawal by the personal data subject of consent to the processing of personal data, continue the processing of personal data without the consent of the personal data subject 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 the obligations provided by the Personal Data Law and the 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 personal data subject with information concerning the processing of their personal data upon request;
• organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• respond to requests and inquiries of personal data subjects 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 personal data subjects upon request of this body with the necessary information within 10 business days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted access to this Policy regarding 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, as well as from other unlawful actions in relation to personal data;
• terminate the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
• fulfill other duties stipulated by the Personal Data Law.

4. BASIC RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS

4.1. Personal data subjects have the right to:

• receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, 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;
• demand the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights;
• set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
• withdraw consent to the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator during the processing of their personal data;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate data about themselves;
• notify the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent bear responsibility in accordance with the legislation of the Russian Federation.

5. PRINCIPLES OF PERSONAL DATA PROCESSING

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

5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not allowed.

5.3. It is not allowed to combine databases containing personal data that are processed for purposes incompatible with each other.

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

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of 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, their sufficiency, and, if necessary, relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if the need to achieve these purposes is no longer relevant, unless otherwise provided by federal law.

6. PURPOSES OF PERSONAL DATA PROCESSING

6.1. The purpose of processing the User’s personal data is to:

• inform the User by sending emails;
• provide the User with access to services, information, and/or materials contained on the website https://ai-potok.ru.

6.2. Additionally, the Operator has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at support@ai-potok.ru with the subject “Unsubscribe from notifications.”

6.3. Depersonalized User data collected through Internet statistics services is used to gather information about Users’ actions on the site, improve the quality of the website and its content.

7. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

7.1. The Operator processes the User’s personal data only if it is filled in and/or sent by the User independently through special forms located on the website https://ai-potok.ru. By filling out these forms and/or sending their personal data to the Operator, the User agrees with this Policy.

7.2. The Operator processes depersonalized data about the User if this is allowed in the User’s browser settings (such as cookie saving and JavaScript usage enabled).

8. PROCEDURE FOR 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 applicable 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 unauthorized access to personal data.

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

8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator at the email address support@ai-potok.ru with the note “Update of personal data.”

8.4. The processing period for personal data is unlimited. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at support@ai-potok.ru with the subject “Withdrawal of consent to personal data processing.”

9. CROSS-BORDER TRANSFER OF PERSONAL DATA

9.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the data is to be transferred provides reliable protection of the rights of data subjects.

9.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only with the written consent of the personal data subject for the cross-border transfer of their personal data and/or the execution of a contract to which the personal data subject is a party.

10. FINAL PROVISIONS

10.1. The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at support@ai-potok.ru.

10.2. This document will reflect any changes in the Operator’s personal data processing policy. The policy remains in effect indefinitely until it is replaced by a new version.

10.3. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or if the personal data subject has given the Operator consent to transfer the data to a third party for the purpose of fulfilling obligations under a civil law contract.

10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless otherwise specified by a contract or applicable legislation.

The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at novat@novat74.ru with the subject line “Withdrawal of consent to personal data processing.”

10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their own User Agreements and Privacy Policies. The personal data subject and/or the User is solely responsible for reviewing such documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

10.6. Restrictions established by the personal data subject on the transfer (excluding access provision), as well as on the processing or conditions of processing (excluding access provision) of personal data authorized for distribution, do not apply in cases of processing personal data for state, public, and other public interests defined by Russian Federation legislation.

10.7. When processing personal data, the Operator ensures the confidentiality of personal data.

10.8. The Operator stores personal data in a form that allows the identification of the personal data subject no longer than required by the purposes of personal data processing, unless a different retention period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.

10.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the data subject's consent, withdrawal of such consent by the data subject, or discovery of unlawful processing of personal data.

11. LIST OF ACTIONS PERFORMED BY THE OPERATOR WITH USERS’ PERSONAL DATA

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.

11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the obtained information via information and telecommunication networks.

12. CROSS-BORDER TRANSFER OF PERSONAL DATA

12.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign country to which the transfer is planned provides reliable protection of the rights of personal data subjects.

12.2. The cross-border transfer of personal data to countries that do not meet the above requirements may only be carried out with the written consent of the personal data subject and/or for the performance of a contract to which the personal data subject is a party.

13. CONFIDENTIALITY OF PERSONAL DATA

13.1. The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate the personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.