Privacy Policy Regarding the Processing of Personal Data

1. General Provisions
This personal data processing policy has been prepared 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 defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Kirill Alekseevich Nikitin (hereinafter referred to as the Operator).

1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets, as one of the most important goals and conditions of its activities.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website http://nikitin-design.com/.

2. Key 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 personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at http://nikitin-design.com/.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility of identifying 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 body, municipal body, legal or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines 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 relating directly or indirectly to a specific or identifiable User of the website http://nikitin-design.com/.
2.9. Personal data permitted by the personal data subject for distribution – personal data access to which is granted to an unlimited number of persons by the subject of personal data by giving consent for the processing of such data as specified by the Personal Data Law (hereinafter – data permitted for distribution).
2.10. User – any visitor to the website http://nikitin-design.com/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific 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 at familiarizing an unlimited number of persons with personal data, including publishing personal data in mass media, placing them in 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 a foreign government body, 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 recovery of the content of personal data in the personal data information system and/or destruction of tangible media of personal data.

3. Main 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, as well as sending a request to stop the processing of personal data, continue processing 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 stipulated by the Personal Data Law and adopted regulatory legal acts 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 regarding 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 inquiries and requests from personal data subjects 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 upon request within 10 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, distribution, as well as from other unlawful actions in relation to personal data;

cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided by the Personal Data Law;

fulfill other obligations stipulated 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 by federal laws. The information is provided by the Operator to the personal data subject in an accessible form and should not contain personal data relating to other personal data subjects unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

demand from the Operator the clarification of their personal data, blocking or destruction if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and take legal measures to protect their rights;

set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;

withdraw consent to the processing of personal data, and send a request to stop processing 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 when processing their personal data;

exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

provide the Operator with accurate information about themselves;

notify the Operator about the clarification (update, change) of their personal data.

4.3. Persons who provided the Operator with inaccurate information about themselves or about 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 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, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. It is not permitted to combine databases containing personal data processed for incompatible purposes.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
5.6. During the processing of personal data, the accuracy of personal data, its sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the personal data subject no longer than the purposes of personal data processing require, unless the retention period is established by federal law, contract, in which the subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of processing goals or in case of loss of the necessity to achieve these goals, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
Informing the User by sending emails.
Personal data:
Email address, phone numbers.
Legal basis:
Federal Law “On Information, Information Technologies and Protection of Information” No. 149-FZ dated July 27, 2006.
Types of personal data processing:
Transfer of personal data.

7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, to carry out functions, powers, and responsibilities 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 judicial act, or an act of another authority or official subject to execution under the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the subject will be the beneficiary or guarantor.
7.5. 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, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out of personal data made publicly available by the personal data subject or at their request (hereinafter – publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure under federal law.

8. Procedure for Collection, Storage, Transfer, 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 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 unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address at n.design.order@outlook.com with the subject “Updating Personal Data.”
8.4. The duration of personal data processing is determined by achieving the purposes for which the personal data were collected, unless another period is stipulated by contract or applicable law.
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 n.design.order@outlook.com with the subject “Withdrawal of Consent to Personal Data Processing.”
8.5. 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 User Agreements and Privacy Policies. The personal data subject must familiarize themselves with those documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Any restrictions imposed by the personal data subject on the transfer (excluding access), as well as on the processing or conditions of processing (excluding access) of personal data authorized for distribution, do not apply in cases of personal data processing in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required by the purposes of processing personal data, unless a different period is established by federal law or a contract to which the subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achieving the purposes of personal data processing, expiration of the subject’s consent, withdrawal of consent by the subject, or a legal request to stop processing, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such transfer.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing any activity related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such a transfer (this notification is submitted separately from the general notification of personal data processing).
10.2. Before submitting the aforementioned notification, the Operator is obligated to obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the personal data is intended to be transferred.

11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data must not disclose or distribute such data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may contact the Operator for any clarifications regarding the processing of their personal data by sending an inquiry to the Operator’s email: n.design.order@outlook.com.
12.2. Any changes to the Operator’s policy on personal data processing will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the internet at: http://nikitin-design.com/policy