Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Anastasia Alekseevna Martsun (hereinafter — the Operator).
1.1. The Operator’s primary objective and essential condition for carrying out its activities is to ensure the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family confidentiality.
1.2. This Operator’s Personal Data Processing Policy (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://martsun.tech.
2. Key Terms Used in the Policy
2.1. Automated personal data processing — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is required to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://martsun.tech.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means used for their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another personal data subject.
2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without automation tools on 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 state authority, municipal authority, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://martsun.tech.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://martsun.tech.
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 making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or granting access to personal data in any other manner.
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 irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or destroying physical media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain reliable information and/or documents containing personal data from the personal data subject;
— in the event that the personal data subject withdraws consent to the processing of personal data, or submits a request to terminate such processing, continue processing personal data without the consent of the personal data subject if there are legal grounds specified in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations предусмотренных 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.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information relating to the processing of their personal data;
— organize personal data processing 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 within 10 days from the date of receipt of such 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, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, unless there are lawful 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, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purposes of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate such processing;
— appeal unlawful actions or inaction of the Operator in connection with the processing of their personal data to the authorized body for the protection of personal data subjects’ rights or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification (update, modification) 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 consent of such subject shall bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The consolidation of databases containing personal data processed for purposes incompatible with one another is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required to achieve the purposes of personal data processing, unless a longer retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or if the need to achieve such purposes is no longer applicable, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending electronic messages and making telephone calls.
Personal data: phone numbers.
Legal grounds: Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies, and Information Protection”.
Types of personal data processing: sending informational messages via Telegram and making telephone calls.
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject.
7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to fulfill the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a court decision, or execution of an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out for personal data made publicly available by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
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 applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases required by applicable law or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law agreement.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@martsun.tech
with the subject line “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by an agreement or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email to info@martsun.tech
with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for reviewing these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), processing, or conditions of processing (except for granting access) of personal data permitted for dissemination shall not apply in cases of personal data processing carried out in state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required to achieve the purposes of personal data processing, unless a longer retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of processing, expiration of the consent validity period, withdrawal of consent by the personal data subject, submission of a request to terminate processing, or identification of unlawful personal data processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such transfer.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities related to the 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 such transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain relevant information from the authorities of a 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 or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at info@martsun.tech.
12.2. Any amendments to the Operator’s personal data processing policy shall be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://martsun.tech/privacypolicy/en.
This Personal Data Processing Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Anastasia Alekseevna Martsun (hereinafter — the Operator).
1.1. The Operator’s primary objective and essential condition for carrying out its activities is to ensure the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family confidentiality.
1.2. This Operator’s Personal Data Processing Policy (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://martsun.tech.
2. Key Terms Used in the Policy
2.1. Automated personal data processing — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is required to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://martsun.tech.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means used for their processing.
2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another personal data subject.
2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without automation tools on 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 state authority, municipal authority, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://martsun.tech.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://martsun.tech.
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 making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or granting access to personal data in any other manner.
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 irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or destroying physical media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain reliable information and/or documents containing personal data from the personal data subject;
— in the event that the personal data subject withdraws consent to the processing of personal data, or submits a request to terminate such processing, continue processing personal data without the consent of the personal data subject if there are legal grounds specified in the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations предусмотренных 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.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information relating to the processing of their personal data;
— organize personal data processing 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 within 10 days from the date of receipt of such 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, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, unless there are lawful 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, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purposes of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate such processing;
— appeal unlawful actions or inaction of the Operator in connection with the processing of their personal data to the authorized body for the protection of personal data subjects’ rights or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification (update, modification) 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 consent of such subject shall bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The consolidation of databases containing personal data processed for purposes incompatible with one another is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identification of the personal data subject for no longer than required to achieve the purposes of personal data processing, unless a longer retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or if the need to achieve such purposes is no longer applicable, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending electronic messages and making telephone calls.
Personal data: phone numbers.
Legal grounds: Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies, and Information Protection”.
Types of personal data processing: sending informational messages via Telegram and making telephone calls.
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject.
7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, and to fulfill the functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a court decision, or execution of an act of another authority or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out for personal data made publicly available by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
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 applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases required by applicable law or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law agreement.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@martsun.tech
with the subject line “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by an agreement or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email to info@martsun.tech
with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for reviewing these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), processing, or conditions of processing (except for granting access) of personal data permitted for dissemination shall not apply in cases of personal data processing carried out in state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required to achieve the purposes of personal data processing, unless a longer retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of processing, expiration of the consent validity period, withdrawal of consent by the personal data subject, submission of a request to terminate processing, or identification of unlawful personal data processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such transfer.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing activities related to the 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 such transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain relevant information from the authorities of a 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 or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at info@martsun.tech.
12.2. Any amendments to the Operator’s personal data processing policy shall be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://martsun.tech/privacypolicy/en.
ИНН 550517560364
