Personal data processing policy
1. General Provisions
This personal data processing policy has been developed in accordance with the requirements of the Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and establishes the procedure for processing personal data and measures to ensure the security of personal data applied by Evgeny Valerievich Ivanov, INN 402572025582 (hereinafter referred to as the Operator).
1.1. The Operator considers its priority task and the main condition for carrying out its activities to be the observance of human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal, and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://egodfather.app/.
2. Basic Concepts 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 (unless the processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://egodfather.app/.
2.4. Personal data information system — a set of personal data contained in databases, and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data — actions as a result of which it becomes impossible to determine, without using additional information, the ownership of personal data by 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 with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual, 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 relating directly or indirectly to a specific or identifiable User of the website https://egodfather.app/.
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which access is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://egodfather.app/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person.
2.12. Distribution 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 number of persons with personal data, including the publication of personal data in the media, placement 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 an 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 destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and/or as a result of which material carriers of personal data are destroyed.
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;
- in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sends a request to stop processing 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 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 subject of personal data, upon their request, with information relating to the processing of their personal data;
- organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- report the necessary information to the authorized body for the protection of the rights of personal data subjects upon 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 regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- fulfill other obligations provided for by the Personal Data Law;
- in the event of establishing the fact of unlawful or accidental transfer (provision, distribution, access) of personal data that has led to a violation of the rights of Users, notify the authorized body of the incident within 24 hours from the moment such an incident is discovered, and also take other measures in connection with the identified incident within the time limits established by law.
4. Basic 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 as provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where 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;
- require the operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights;
- put forward a condition of prior consent when processing personal data in order to promote goods, works, and services on the market;
- withdraw consent to the processing of personal data, as well as 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 reliable data about themselves;
- inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have transferred to the Operator false information about themselves, or information 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. 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 legitimate purposes. Processing of personal data 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 are subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. Redundancy of the 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, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing personal data, unless the period of storage of personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing goals or in case of loss of necessity in achieving these goals, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of processing: conclusion, execution, and termination of civil law contracts | |
|---|---|
| Personal data |
|
| Legal basis |
|
| Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data |
| Categories of users whose data is processed | individuals (buyers, customers) who have concluded or intend to conclude a civil law contract for the sale of goods (services) presented on the Website with the Operator. |
| Methods of personal data processing | mixed processing of personal data (non-automated and using automation tools, with or without transmission of the received information over a network). |
| Terms of processing and storage of personal data | from the date of provision of personal data by Users with their consent (if applicable) until the goal of processing personal data is achieved or until the User withdraws their consent to the processing of personal data/the Operator receives a request to stop processing personal data, unless another period is provided by the contract or current legislation. |
| Storage of personal data | on physical media in special places excluding unauthorized access. On electronic media — using software tools to restrict data access. |
| Achievement of personal data processing goals | Upon achievement of personal data processing goals or occurrence of other grounds for termination of personal data processing, physical media of personal data are destroyed, personal data are deleted from electronic media without the possibility of their recovery. |
| Purpose of processing: collection of statistical information about User actions on the Website, improving the quality of the Website and its content using the Yandex Metrica web analytics service | |
|---|---|
| Personal data | cookie files |
| Categories of users whose data is processed | Website visitors |
| Legal basis |
|
| Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction of personal data, transfer of personal data with the User’s consent |
| Methods of personal data processing | mixed processing of personal data (non-automated and using automation tools, with or without transmission of the received information over a network). |
| Terms of processing and storage of personal data | from the date of provision of personal data by Users with their consent (if applicable) until the goal of processing personal data is achieved or until the User withdraws their consent to the processing of personal data/the Operator receives a request to stop processing personal data, unless another period is provided by the contract or current legislation. |
| Storage of personal data | on physical media in special places excluding unauthorized access. On electronic media — using software tools to restrict data access. |
| Achievement of personal data processing goals | Upon achievement of personal data processing goals or occurrence of other grounds for termination of personal data processing, physical media of personal data are destroyed, personal data are deleted from electronic media without the possibility of their recovery. |
7. Conditions for Processing Personal Data
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 goals stipulated by an international treaty of the Russian Federation or law, to carry out the functions, powers, and duties assigned to 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 an official 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 a contract to which the subject of personal data is a party or a beneficiary or guarantor, 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 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, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out of personal data, access to an unlimited number of persons to which is provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
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 the 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 preclude access to personal data by unauthorized persons.
8.2. If you have given your consent to the collection of cookies using the Yandex.Metrica web analytics service, this means that you have also given your consent to the transfer of said data to Yandex (Yandex LLC; OGRN 1027700229193, 119021, Russia, Moscow, Lev Tolstoy St., 16) for processing data about you by Yandex in the manner and for the purposes specified below. Cookies are small text files placed on your computer to analyze your user activity. The information collected using cookies cannot identify you, but it can help us improve the functioning of the website. Information about your use of the website collected by cookies will be transferred to Yandex and stored on Yandex’s servers in the EU and the Russian Federation. Yandex will process this information to evaluate your use of the website, compile reports on website activity for us, and provide other services. Yandex processes this information in the manner established in the terms of use of the Yandex Metrica service. You can refuse the use of cookies by selecting the appropriate settings in your browser. You can also use the tool — https://yandex.ru/support/metrika/general/opt-out.html. However, this may affect the functioning of certain site features.
8.3. In case of revealing inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s email address support@egodfather.app marked “Updating personal data”.
8.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another term is stipulated by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address support@egodfather.app marked “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. 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 personal data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for gaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the 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 personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The 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 personal data subject, the withdrawal of consent by the personal data subject, or a request to terminate the processing of personal data, as well as the discovery of unlawful 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), anonymizes, 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 received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Prior to the start of cross-border 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 cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border 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 personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarification on issues of interest regarding the processing of their personal data by contacting the Operator via email at support@egodfather.app.
12.2. This document will reflect any changes to the personal data processing policy by the Operator. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at .