Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy (hereinafter referred to as the "Policy") is drafted in compliance 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 the measures taken to ensure the security of personal data by Individual Entrepreneur Dankov Oleg Gennadievich, Taxpayer Identification Number (INN) 781802478146, Primary State Registration Number (OGRNIP) 321784700348670 (hereinafter referred to as the "Operator").
1.1. The Operator considers the observance of human and civil rights and freedoms, including the protection of the rights to privacy, personal, and family secrets, as its highest priority and a fundamental condition for its activities when processing personal data.
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 obtain about visitors to the website https://patron-patent.ru/.
2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data – the processing of personal data using computer technology.
2.2. Blocking of Personal Data – the temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://patron-patent.ru/.
2.4. Personal Data Information System – a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of Personal Data – actions that make it impossible to determine, without the use of 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 set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the 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://patron-patent.ru/.
2.9. Personal Data Permitted for Dissemination – personal data to which access by an unlimited number of persons has been granted by the subject of personal data by providing consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "Personal Data Permitted for Dissemination").
2.10. User – any visitor to the website https://patron-patent.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 group of persons (transfer of personal data) or at familiarizing an unlimited group of persons with personal data, including the publication of personal data in mass 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 - means transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual or foreign legal entity.
2.14 Destruction of personal data - means any actions resulting in the irreversible destruction of personal data with no possibility of further recovery of the personal data content in the personal data information system and/or the physical destruction of storage media containing personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Obtain from the personal data subject accurate information and/or documents containing personal data;
— If the personal data subject withdraws consent to the processing of personal data or submits a request to terminate such processing, the Operator may continue processing the personal data without the subject’s consent if there are lawful grounds specified in the Personal Data Law;
— Independently determine the scope and list of measures necessary and sufficient to ensure compliance with obligations stipulated by the Personal Data Law and related 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, upon request, with information regarding the processing of their personal data;
— Process personal data in accordance with the procedures established by the current legislation of the Russian Federation;
— Respond to inquiries and requests from personal data subjects and their legal representatives in compliance with the requirements of the Personal Data Law;
— Submit the necessary information to the authorized body for the protection of personal data subjects’ rights within 10 (ten) days from the date of receipt of such a request;
— Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— Implement legal, organizational, and technical measures to protect personal data from:
Unauthorized or accidental access,
Destruction, modification, blocking, copying,
Unlawful disclosure or dissemination,
Other unlawful actions in relation to personal data;
— Cease the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal Data Subjects Have the Right to:
— Obtain information regarding the processing of their personal data, except in cases restricted by federal laws. The Operator shall provide such information to the data subject in an accessible format, and it shall not contain personal data related to other data subjects, unless there are lawful grounds for disclosing such data. The scope of information and the procedure for obtaining it are defined by the Personal Data Law;
— Request that the Operator rectify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated processing purposes, as well as to take legal measures to protect their rights;
— Set a prior consent requirement for the processing of personal data for marketing purposes (promotion of goods, services, or works);
— Withdraw consent to the processing of personal data and submit a request to terminate processing;
— File a complaint with the authorized body for the protection of personal data subjects’ rights or initiate legal proceedings against the Operator in case of unlawful actions or inaction in processing their personal data;
— Exercise other rights granted under 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 of any updates, corrections, or changes to their personal data.
4.3. Liability for Inaccurate Information:
Individuals who provide the Operator with inaccurate information about themselves or disclose personal data of another data subject without their consent shall be held liable under the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing shall be conducted on a lawful and fair basis.
5.2. Personal data processing shall be limited to the achievement of specific, predefined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collection is prohibited.
5.3. The merging of databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that is relevant to the purposes of processing shall be processed.
5.5. The content and scope of processed personal data shall correspond to the stated purposes of processing. Processing of excessive personal data beyond what is necessary for the stated purposes is prohibited.
5.6. Accuracy and Relevance of Personal Data:
The processing of personal data shall ensure the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing. The Operator shall take necessary measures and/or ensure the implementation of such measures to delete or rectify incomplete or inaccurate data.
5.7. Storage of Personal Data:
Personal data shall be stored in a form that allows for the identification of the data subject for no longer than required to achieve the purposes of processing, unless the storage period is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or in the event that the necessity for achieving these purposes ceases, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of Processing:

• To inform the User by sending emails.

Personal Data:

• Last name, first name, patronymic (if applicable);
• Email address;
• Phone numbers.

Legal Basis:

• The statutory (foundational) documents of the Operator.

Types of Personal Data Processing:

• Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.

Actions Performed:

• Sending informational emails to the email address.

7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out 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, for the performance of functions, powers, and duties 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, an act of another authority or official, which are subject to execution in accordance with 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 initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. 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 purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out when access to such data is provided to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data is carried out when such data is subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator shall be ensured by implementing the legal, organizational, and technical measures required to fully comply with the requirements of the effective legislation in the field of personal data protection.
8.1. The Operator shall ensure the integrity of personal data and shall take all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the execution of effective legislation or in cases where the data subject has provided consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
8.3. Should inaccuracies in personal data be identified, the User may update them independently by sending a notification to the Operator’s email address patent-patron@yandex.ru marked *"Updating Personal Data"*.
8.4. The period for processing personal data shall be determined by the achievement of the purposes for which the personal data were collected, unless a different period is stipulated by contract or effective legislation.
The User may at any time withdraw consent to the processing of personal data by sending a notification to the Operator’s email address patent-patron@yandex.ru marked *"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, shall be stored and processed by such parties (Operators) in accordance with their Terms of Service and Privacy Policy. The data subject shall familiarize themselves with these documents.
The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the data subject on the transfer (except for granting access) as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, shall not apply in cases of personal data processing in state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during their processing.
8.8. The Operator shall store personal data in a form that allows the identification of the data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, contract, or where the data subject is a party, beneficiary, or guarantor under such contract.
8.9. Grounds for termination of personal data processing may include:
- Achievement of the purposes of personal data processing;
- Expiry of the data subject’s consent;
- Withdrawal of consent by the data subject;
- Receipt of a demand to cease processing personal data;
- Identification of facts of illegal processing of personal data.
9. List of actions performed by the Operator with the personal data received
9.1. 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.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the information obtained via information and telecommunication networks, or without such receipt and/or transmission.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification shall be submitted separately from the notification of the intention to carry out personal data processing).
10.2. Prior to submitting the above notification, the Operator shall obtain from the authorities of the foreign state, and from the foreign individuals and foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data shall be obliged not to disclose such data to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarifications on matters of interest relating to the processing of their personal data by contacting the Operator by email at patent-patron@yandex.ru.
12.2. Any changes to the Operator’s policy on personal data processing shall be reflected in this document. The Policy shall remain in effect for an indefinite period until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://patron-patent.ru/document.