PANARCTIC STAR LLC
Personal Data Processing Policy
1. General Provisions.
This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by Limited Liability Company “Panarctic Star” (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the right to privacy, personal and family confidentiality, to be a primary objective and essential condition 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 https://neralah.ru/.
1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the right to privacy, personal and family confidentiality, to be a primary objective and essential condition 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 https://neralah.ru/.
2. Basic 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 graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://neralah.ru/.
2.4. Personal data information system — 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 make it impossible to determine, without additional information, whether personal data belongs to a specific User or another subject of personal data.
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, and destruction of personal data.
2.7. Operator — a government authority, 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, and actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly relating to an identified or identifiable User of the website https://neralah.ru/.
2.9. Personal data allowed by the personal data subject for dissemination — personal data to which the subject has granted access to an unlimited number of persons by giving consent to process such data in the manner provided by the Personal Data Law (hereinafter referred to as “personal data allowed for dissemination”).
2.10. User — any visitor to the website https://neralah.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunications networks, or otherwise providing access to personal data.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irrevocable destruction of personal data with no possibility of restoring the content of personal data in the personal data information system and/or the destruction of tangible media containing personal data.
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 graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://neralah.ru/.
2.4. Personal data information system — 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 make it impossible to determine, without additional information, whether personal data belongs to a specific User or another subject of personal data.
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, and destruction of personal data.
2.7. Operator — a government authority, 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, and actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly relating to an identified or identifiable User of the website https://neralah.ru/.
2.9. Personal data allowed by the personal data subject for dissemination — personal data to which the subject has granted access to an unlimited number of persons by giving consent to process such data in the manner provided by the Personal Data Law (hereinafter referred to as “personal data allowed for dissemination”).
2.10. User — any visitor to the website https://neralah.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunications networks, or otherwise providing access to personal data.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irrevocable destruction of personal data with no possibility of restoring the content of personal data in the personal data information system and/or the destruction of tangible media containing personal data.
3. Main Rights and Obligations of the Operator.
3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the personal data subject;
— in the event of the personal data subject withdrawing consent to the processing of personal data, continue processing the personal data without the subject’s consent 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 stipulated 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, upon their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to appeals 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 personal data subjects’ rights with necessary information upon its request within 30 days from the date of receiving such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
— cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
— receive accurate information and/or documents containing personal data from the personal data subject;
— in the event of the personal data subject withdrawing consent to the processing of personal data, continue processing the personal data without the subject’s consent 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 stipulated 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, upon their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to appeals 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 personal data subjects’ rights with necessary information upon its request within 30 days from the date of receiving such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
— cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations provided 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 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, except when there are legal grounds for disclosing such personal data; the list of information and the procedure for its receipt are established by the Personal Data Law;
— demand from the Operator the clarification of their personal data, their blocking, or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as take measures prescribed by law to protect their rights;
— impose a condition of prior consent when processing personal data for the purposes of marketing goods, works, and services;
— withdraw consent to the processing of personal data;
— appeal to the authorized body for the protection of personal data subjects’ rights or through the courts against unlawful actions or inaction of the Operator in 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 data about themselves;
— inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who provide the Operator with inaccurate 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.
— receive information concerning the processing of their personal data, except in cases provided 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, except when there are legal grounds for disclosing such personal data; the list of information and the procedure for its receipt are established by the Personal Data Law;
— demand from the Operator the clarification of their personal data, their blocking, or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as take measures prescribed by law to protect their rights;
— impose a condition of prior consent when processing personal data for the purposes of marketing goods, works, and services;
— withdraw consent to the processing of personal data;
— appeal to the authorized body for the protection of personal data subjects’ rights or through the courts against unlawful actions or inaction of the Operator in 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 data about themselves;
— inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who provide the Operator with inaccurate 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. The Operator may process the following personal data of the User.
5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized data about visitors (including cookies) using internet analytics services (“Yandex Metrica,” Google Analytics, etc.).
5.5. The above data are collectively referred to in this Policy as “personal data.”
5.6. The Operator does not process special categories of personal data concerning racial, ethnic origin, political opinions, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data permitted for distribution, among the special categories of personal data listed in part 1 of article 10 of the Personal Data Law, is allowed if the prohibitions and conditions stipulated in article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for distribution is obtained separately from other consents to process their personal data. The conditions stipulated, in particular, by article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of personal data subjects’ rights.
5.8.1. The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
5.8.2. The Operator is obliged to publish information about the processing conditions, prohibitions, and conditions on processing personal data permitted for distribution by an unlimited circle of persons no later than three business days from the date of receiving such consent from the User.
5.8.3. The transfer (distribution, provision, access) of personal data permitted by the data subject for distribution must be stopped at any time upon the data subject’s request. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the data subject, as well as a list of personal data to be ceased from processing. The personal data specified in this request may only be processed by the Operator to whom the request is directed.
5.8.4. The consent to process personal data permitted for distribution terminates upon receipt by the Operator of the request specified in clause 5.8.3 of this Personal Data Processing Policy.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized data about visitors (including cookies) using internet analytics services (“Yandex Metrica,” Google Analytics, etc.).
5.5. The above data are collectively referred to in this Policy as “personal data.”
5.6. The Operator does not process special categories of personal data concerning racial, ethnic origin, political opinions, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data permitted for distribution, among the special categories of personal data listed in part 1 of article 10 of the Personal Data Law, is allowed if the prohibitions and conditions stipulated in article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for distribution is obtained separately from other consents to process their personal data. The conditions stipulated, in particular, by article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of personal data subjects’ rights.
5.8.1. The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
5.8.2. The Operator is obliged to publish information about the processing conditions, prohibitions, and conditions on processing personal data permitted for distribution by an unlimited circle of persons no later than three business days from the date of receiving such consent from the User.
5.8.3. The transfer (distribution, provision, access) of personal data permitted by the data subject for distribution must be stopped at any time upon the data subject’s request. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the data subject, as well as a list of personal data to be ceased from processing. The personal data specified in this request may only be processed by the Operator to whom the request is directed.
5.8.4. The consent to process personal data permitted for distribution terminates upon receipt by the Operator of the request specified in clause 5.8.3 of this Personal Data Processing Policy.
6. Principles of Personal Data Processing.
6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing personal data incompatible with the purposes for which the data was collected is not permitted.
6.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data relevant to the purposes of processing shall be processed.
6.5. The content and volume of processed personal data correspond to the declared purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, when necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than required by the purposes of personal data processing, unless a retention period is established by federal law, contract, or other binding agreement involving the data subject. Processed personal data shall be destroyed or anonymized once the processing purposes are achieved or when the need to achieve those purposes ceases, unless otherwise stipulated by federal law.
6.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing personal data incompatible with the purposes for which the data was collected is not permitted.
6.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data relevant to the purposes of processing shall be processed.
6.5. The content and volume of processed personal data correspond to the declared purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, when necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than required by the purposes of personal data processing, unless a retention period is established by federal law, contract, or other binding agreement involving the data subject. Processed personal data shall be destroyed or anonymized once the processing purposes are achieved or when the need to achieve those purposes ceases, unless otherwise stipulated by federal law.
7. Purposes of Personal Data Processing.
7.1. The purposes of processing the User’s personal data are as follows:
— to inform the User by sending emails;
— to conclude, execute, and terminate civil law contracts;
— to provide the User with access to services, information, and/or materials available on the website https://neralah.ru/.
7.2. The Operator is also entitled to send the User notifications about new products and services, special offers, and various events.
The User may always opt out of receiving informational messages by sending an email to the Operator at neralah@panarcticstar.ru with the subject line "Unsubscribe from notifications about new products, services, and special offers."
7.3. Anonymized User data collected through web analytics services is used to gather information about User actions on the site, in order to improve the quality and content of the website.
— to inform the User by sending emails;
— to conclude, execute, and terminate civil law contracts;
— to provide the User with access to services, information, and/or materials available on the website https://neralah.ru/.
7.2. The Operator is also entitled to send the User notifications about new products and services, special offers, and various events.
The User may always opt out of receiving informational messages by sending an email to the Operator at neralah@panarcticstar.ru with the subject line "Unsubscribe from notifications about new products, services, and special offers."
7.3. Anonymized User data collected through web analytics services is used to gather information about User actions on the site, in order to improve the quality and content of the website.
8. Legal Grounds for Processing Personal Data.
8.1. The legal grounds for the Operator’s processing of personal data include:
— regulatory legal acts governing activities related to your field. For example, if your activity is connected with information technologies, particularly website development, you may cite Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and the Protection of Information”;
— the Operator’s founding documents;
— agreements concluded between the Operator and the subject of personal data;
— federal laws and other regulatory legal acts in the field of personal data protection;
— the Users’ consent to the processing of their personal data, including consent to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User’s personal data only when such data is voluntarily provided by the User by filling out and/or submitting it through special forms on the website https://kitovybereg.ru/ or sent to the Operator by email. By completing these forms and/or sending their personal data to the Operator, the User agrees to this Policy.
8.3. The Operator processes anonymized data about the User if this is enabled in the User’s browser settings (such as allowing cookies and JavaScript technology).
8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.
— regulatory legal acts governing activities related to your field. For example, if your activity is connected with information technologies, particularly website development, you may cite Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and the Protection of Information”;
— the Operator’s founding documents;
— agreements concluded between the Operator and the subject of personal data;
— federal laws and other regulatory legal acts in the field of personal data protection;
— the Users’ consent to the processing of their personal data, including consent to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User’s personal data only when such data is voluntarily provided by the User by filling out and/or submitting it through special forms on the website https://kitovybereg.ru/ or sent to the Operator by email. By completing these forms and/or sending their personal data to the Operator, the User agrees to this Policy.
8.3. The Operator processes anonymized data about the User if this is enabled in the User’s browser settings (such as allowing cookies and JavaScript technology).
8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions for Processing Personal Data.
9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
9.3. The 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 that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, or a 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 personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
9.6. The processing of personal data is carried out when the personal data is made publicly available by the personal data subject or at their request (hereinafter — publicly available personal data).
9.7. The processing of personal data is carried out when such data is subject to publication or mandatory disclosure in accordance with federal law.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
9.3. The 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 that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, or a 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 personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
9.6. The processing of personal data is carried out when the personal data is made publicly available by the personal data subject or at their request (hereinafter — publicly available personal data).
9.7. The processing of personal data is carried out when such data is subject to publication or mandatory disclosure in accordance with federal law.
10. Procedure for the 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.
10.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
10.3. In case of inaccuracies in the personal data, the User may update them independently by sending a notification to the Operator’s email address at neralah@panarcticstar.ru with the subject line “Personal Data Update.”
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless otherwise provided by a contract or current 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 to neralah@panarcticstar.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 User Agreements and Privacy Policies. The data subject and/or User must independently and timely review such documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
10.6. Restrictions set by the data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for access) of personal data allowed for dissemination, do not apply in cases of processing personal data for state, public, and other public interests as defined by Russian legislation.
10.7. When processing personal data, the Operator ensures the confidentiality of the personal data.
10.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than is required by the purposes of processing personal data, unless a longer storage period is required by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. Grounds for termination of personal data processing may include the achievement of the purposes of personal data processing, expiration of the data subject's consent period, withdrawal of consent by the data subject, or identification of unlawful processing of personal data.
10.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
10.3. In case of inaccuracies in the personal data, the User may update them independently by sending a notification to the Operator’s email address at neralah@panarcticstar.ru with the subject line “Personal Data Update.”
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless otherwise provided by a contract or current 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 to neralah@panarcticstar.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 User Agreements and Privacy Policies. The data subject and/or User must independently and timely review such documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
10.6. Restrictions set by the data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for access) of personal data allowed for dissemination, do not apply in cases of processing personal data for state, public, and other public interests as defined by Russian legislation.
10.7. When processing personal data, the Operator ensures the confidentiality of the personal data.
10.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than is required by the purposes of processing personal data, unless a longer storage period is required by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. Grounds for termination of personal data processing may include the achievement of the purposes of personal data processing, expiration of the data subject's consent period, withdrawal of consent by the data subject, or identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Collected Personal Data.
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the obtained information through information and telecommunication networks.
11.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the obtained information through information and telecommunication networks.
12. Cross-border Transfer of Personal Data.
12.1. Before commencing cross-border transfer of personal data, the Operator must ensure that the foreign country to which the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only be carried out with the written consent of the personal data subject for the cross-border transfer of their personal data and/or for the execution of a contract to which the personal data subject is a party.
12.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only be carried out with the written consent of the personal data subject for the cross-border transfer of their personal data and/or for the execution of a contract to which the personal data subject is a party.
13. Confidentiality of Personal Data.
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions.
14.1. The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at neralah@panarcticstar.ru.
14.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available online at https://neralah.ru/privacy-policy.
14.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available online at https://neralah.ru/privacy-policy.