Privacy Policy regarding the processing of personal data

1. General Provisions
1.1. This policy (hereinafter – the "Policy") is developed in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter – the Policy, the Personal Data Law) and Federal Law No. 149-FZ of 27.07.2006 "On Information, Information Technologies and Protection of Information" and defines the procedure for processing personal data and measures to ensure the security of personal data carried out by Individual Entrepreneur Ilya Vladimirovich Chirun (TIN 500708593104; OGRNIP 325508100432052; Moscow, ul. Selskokhozyaystvennaya 17 bld. 1; hereinafter – the Operator).

1.2. The Operator’s purpose and condition for its activities is to observe human and civil rights and freedoms when processing their personal data, including protection of the right to privacy, personal and family secrets.

1.3. The Operator’s Policy applies to any information relating to a directly or indirectly identified or identifiable individual (Personal Data Subject, User), which the Operator may obtain about users of the website https://chirungallery.com (hereinafter – the website user, the Website).

1.4. The User expresses and confirms their consent to the Policy, regardless of registration, when obtaining access or using any functions of the Website. Otherwise, the User must immediately stop using the Website.

1.5. The concepts used in the Policy are applied in the meanings defined by the legislation of the Russian Federation on personal data.


2. Purposes of personal data processing 

Purposes

Categories of personal data subjects

List/categories of personal data

Providing website users with access to services, information, and/or materials contained on the website

Website users

- surname, first name, patronymic;

- contact phone number;

- email address.



Requesting data from the browser used on the Website User's computer or mobile device using cookies, which reflect the User's preferences and actions on the Website and allow:


- support the functionality of resources that require the use of information stored on the browser side;

- measure the size of the website's audience;

- determine the statistical information preferences of Users when accessing various pages of the website.

Website users

- IP address; 

- information about the browser and the address of the page (or other program that accesses the Site); 

- access time; 

- referrer (address of the previous page); 

- other information from cookies (depending on the type of cookies listed in section 4 of the Policy). 

Click map: measuring and displaying statistics on clicks on the website

Website users

- information about visits to the site;

- number of views;

- number of clicks

Analysis by the operator of information about the user's experience visiting the website

Website users

- last name, first name, middle name;

- contact phone number;

- email

- accounts on messengers and social networks;

- photo, video image;

- information about the User's experience visiting the website (if such information contains personal data) 

Newsletter

Website users

- last name, first name, middle name;

- contact phone number;

- email address.

- messenger and social media accounts.

Publication of user comments and reviews on the website*



*The website and the Operator also provide the User with the opportunity to post reviews and comments anonymously. 

Website users

- last name, first name, patronymic;

- Nickname;

- contact phone number;

- email address.

- messenger and social media accounts;

- information about your experience using the website (if such information contains personal data)




3. Conditions for processing personal data

3.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data. The form (checkbox) for obtaining consent to the processing of personal data is placed in all forms for collecting such data and meets the following requirements:

- includes full name, list of data, purpose of processing, storage period, right
to withdraw consent;
- includes separate consent to the transfer of data to third parties in cases provided for by applicable law;
- provides for the mandatory activation and storage of log files to prove that consent to the processing of personal data has been obtained.

3.2. Links to consent forms used on the website:
-
-
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3.3. The processing of personal data is limited to the achievement of the legitimate purposes set out in this Policy. The processing of personal data that is incompatible with the specified purposes of collecting personal data is not permitted.

3.4. It is not permitted to combine databases containing personal data that are processed for purposes that are incompatible with each other.
3.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. The processing of personal data shall not be excessive in relation to the stated purposes of processing.
3.6. When processing personal data, the accuracy, adequacy, and, where necessary, relevance of personal data in relation to the purposes of processing personal data shall be ensured. The operator shall take the necessary measures and/or ensure that measures are taken to delete or correct incomplete or inaccurate data.
3.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in the event that the need to achieve these purposes ceases to exist, unless otherwise provided by federal law.


4. Procedure for the collection, storage, transfer, and other types of processing of personal data
4.1. 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. Personal data is stored using databases of the Tilda website builder – AO "Selectel" and OOO "Yandex.Cloud" – located in the Russian Federation. 

4.2. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

4.3. The personal data of the Website User will not be transferred to third parties under any circumstances, except in cases related to the enforcement of applicable law or if the subject of the personal data has given consent to the Operator to transfer the data to a third party in order to fulfill obligations under a civil law contract.

4.4. The website uses the Yandex.Metrica web analytics service provided by Yandex under the following conditions:
4.4.1. The Yandex.Metrica web analytics service uses cookies;
4.4.2. Information about the User's use of the website collected using cookies is subject to transfer to Yandex and is stored on Yandex servers located in the Russian Federation. Yandex processes the information received to evaluate the User's use of the website and compile reports on the website's activity.
4.4.3. Yandex processes the information received in accordance with the procedure established by:
• The cookie policy posted on the Internet at: https://yandex.ru/legal/cookies_policy; 
• The Terms of Use for the Yandex.Metrica service, available on the Internet at: https://yandex.ru/legal/metrica_termsofuse; 
• The Privacy Policy, available on the Internet at: https://yandex.ru/legal/confidential. By continuing to use the website, the User agrees to the processing of data about the User by Yandex in the manner and for the purposes specified in clause 4.4 of the Policy. 

4.5. The cookies used on the website are listed in the table below:

Name and type

Provider

Storage period

Purpose

Ym-uid 

Yandex.Metrica

1 year

User tracking

ym_d

(analytical)

Yandex.Metrica

1 year

First visit tracking

ym_visorc

(analytical)

Yandex.Metrica

30 minutes

Webvisor operation

ym_isad

(analytical)

Yandex.Metrica

1 day

Determining the presence of an ad blocker

Ymex

(analytical)

Yandex.Metrica

1 year

Determining the expiration time of the experiment

Ddg1

(other)

Uteka.ru

1 year

Cookies from the uTeka service. Used for training recommendation algorithms. 

Ddg8

(others)

Uteka.ru

1 day

Cookies from the uTeka service. Used for training recommendation algorithms. 

Ddg9

(others)

Uteka.ru

1 day

Cookies from the uTeka service. Used for training recommendation algorithms. 

Ddg10

(others)

Uteka.ru

1 day

Cookies from the uTeka service. Used for training recommendation algorithms. 

js_cookies

(functional)

JavaScript is a multi-paradigm programming language.

JavaScript is not owned by any organization or company. 

During the session

JavaScript Cookie is a package that provides a JavaScript API for working with cookies. 


4.6. When visiting the website for the first time using a browser or in private browsing mode, a banner is displayed warning the User about the collection of cookies and requesting the User's consent to the processing of their cookies.

By clicking the "Accept" button or continuing to use the website, the User gives their consent to the processing of their cookies and confirms their agreement with the provisions of the Policy. Continued use of the website means that the User clicks on any link posted on the website, clicks on any button on the website, or views content on any page of the website.

The user can refuse to use cookies in their browser settings (this option can be found in the "Help" section of the relevant browser). In this case, the website will only use cookies that are strictly necessary for its functioning and the services it offers. The policy applies only to the website. The operator does not control and is not responsible for third-party websites that the user may access via links available on the website. 

4.7. If inaccuracies are found in personal data, the website User may update them independently by sending a notification to the Operator at the Operator's email address https://chirungallery.com with the subject line "Update of personal data."

4.8. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or applicable law. Website users may 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 https://chirungallery.com with the subject line "Withdrawal of consent to the processing of personal data."

4.9. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the specified persons (operators) in accordance with their user agreement and privacy policy in relation to the subject of personal data and (or) with the specified documents. The operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

4.10. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining 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.

4.11. When processing personal data, the operator shall ensure the confidentiality of personal data.

4.12. The operator shall store personal data in a form that allows the identification of the personal data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.

4.13. The conditions for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to terminate personal data processing, as well as the detection of unlawful personal data processing.



5. Basic rights and obligations of the Operator
5.1. The Operator has the right to:
—receive from the personal data subject reliable information and/or documents containing personal data;
— in the event of withdrawal of consent to the processing of personal data by the personal data subject, as well as the submission of a request to terminate the processing of personal data, the Operator has the right to 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 obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
5.2. The operator is obliged to:
— provide the subject of personal data, at his or her request, with information concerning the processing of his or her personal data;
— organize the processing of personal data in accordance with the procedure 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;
— provide the authorized body for the protection of the rights of personal data subjects with the necessary information at the request of that 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, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— to stop the transfer (distribution, provision, access) of personal data, to stop processing and to destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform other duties stipulated by the Personal Data Act.


6. Basic rights and obligations of personal data subjects (Users)
6.1. Personal data subjects (Users) 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 must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— require the operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
— to set a condition of prior consent for the processing of personal data for the purpose of promoting 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;
— to 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 in the processing of his personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
6.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator about any clarification (update, change) of their personal data.
6.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter's consent shall be liable in accordance with the legislation of the Russian Federation.

7. List of actions performed by the Operator with the personal data received
personal data
7.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

7.2. The Operator performs automated processing of personal data with the receipt and (or) transfer of the received information via information and telecommunications networks or without such.


8. Cross-border transfer of personal data
8.1. Users' personal data is initially collected and stored in databases and on servers located exclusively in the Russian Federation. Cross-border transfer of personal data may only be carried out on the grounds and in the manner provided for by the legislation of the Russian Federation.

8.2. Before commencing 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 shall be sent separately from the notification of the intention to process personal data).

8.3. Before submitting the above notification, the operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.

9. Confidentiality of personal data
9.1. The operator and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by the Personal Data Law.

10. Final provisions
10.1. Website users may obtain any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator at the email address:chirun@mail.ru ; or by calling: +79036885063.

10.2. The current version of the Policy is freely available on the website in the section:


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