Privacy Policy

1. General Provisions

This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006, «On Personal Data» (hereinafter referred to as the Personal Data Law). It defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Aparin Vladislav Yurievich (hereinafter referred to as the Operator).

1.1. The Operator’s primary goal and condition for conducting its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including protecting the right to privacy, personal and family secrets.

1.2. This Operator’s Policy concerning personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website masterchar.com.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data means processing personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing (except where processing is necessary to clarify personal data).

2.3. Website refers to the collection of graphical and informational materials, as well as software and databases, which provide accessibility on the internet at the network address masterchar.com.

2.4. An information system of personal data is the collection of personal data contained in databases and the information technologies and technical means that enable its processing.

2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine the ownership of personal data by a specific User or another subject of personal data.

2.6. Processing of personal data means any action (operation) or series of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. The Operator is a state authority, municipal authority, legal or natural person, independently or jointly with other persons organizing and/or conducting the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data refers to any information relating directly or indirectly to an identified or identifiable User of the website masterchar.com.

2.9. Personal data permitted by the subject of personal data for dissemination means personal data to which an unlimited number of persons is granted access by the personal data subject giving consent for the processing of personal data permitted by the subject for dissemination, in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).

2.10. User means any visitor to the website masterchar.com.

2.11. Provision of personal data refers to actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data refers to any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data refers to any actions that irretrievably destroy personal data, making it impossible to further restore the personal data in an information system of personal data and/or destroy the physical carriers of personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

— request from the personal data subject accurate information and/or documents containing personal data;

— in the event the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, the Operator is entitled to continue processing 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 compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted pursuant thereto, 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 his/her personal data;

— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

— respond to inquiries and requests from personal data subjects and their authorized representatives in accordance with the requirements of the Personal Data Law;

— submit the necessary information to the authorized body for the protection of the rights of personal data subjects upon that body’s request, within 10 days from the date of receiving such a request;

— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

— implement legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions related to personal data;

— terminate 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. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— obtain information relating to the processing of his/her personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator to the personal data subject in an accessible form, and it shall not contain personal data relating to other subjects of personal data, except where 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;

— request that the operator update, block, or destroy his/her personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not required for the stated purpose of processing, and also take the measures provided for by law to protect his/her rights;

— require prior consent when processing personal data for the purpose of marketing goods, works, and services;

— withdraw consent to the processing of personal data, and also submit a demand to cease processing personal data;

— appeal to the authorized body for the protection of personal data subjects’ rights or to the courts against unlawful actions or inaction of the Operator in processing his/her personal data;

— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects shall:

— provide the Operator with accurate data about themselves;

— inform the Operator about updates (revisions, changes) to their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without

that subject’s consent shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, pre-determined, and lawful purposes. Personal data processing that is incompatible with the purpose of personal data collection is not permitted.

5.3. It is not permitted to combine databases containing personal data that are processed for purposes incompatible with each other.

5.4. Only personal data that meets the purposes of its processing shall be subject to processing.

5.5. The content and scope of the personal data being processed shall correspond to the stated processing purposes. Excessive personal data in relation to the stated processing purposes is not permitted.

5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of personal data processing shall be ensured. The Operator takes the necessary measures and/or ensures their implementation to delete or update incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the identification of the personal data subject, no longer than is required by the purposes of personal data processing, unless a longer retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.

Any personal data processed shall be destroyed or depersonalized upon achieving the purposes of processing or when it is no longer necessary to achieve these purposes, unless otherwise provided for by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: Processing orders and providing services, user support, improving the website’s operation

Personal data: first name, last name, email address, and, if provided, the password used for registration.

Legal basis: Federal Law «On Information, Information Technologies, and Information Protection» No. 149-FZ dated 27.07.2006

Types of processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

7. Conditions for Personal Data Processing

7.1. Personal data is processed with the consent of the personal data subject for the processing of his/her personal data.

7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or a law, for the Operator to perform the functions, powers, and responsibilities assigned to it by the legislation of the Russian Federation.

7.3. Personal data processing is necessary to administer justice, enforce a judicial act, or an act of another body or official that is subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary to fulfill a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract on the personal data subject’s initiative or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary to exercise the Operator’s or third parties’ rights and lawful interests or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. The processing of personal data is carried out with an unlimited number of persons having access to it, which was provided by the personal data subject or at the subject’s request (hereinafter referred to as publicly available personal data).

7.7. The processing of personal data that must be published or mandatorily disclosed under federal law is carried out.

8. Procedure for Collecting, Storing, Transferring, 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 current legislation in the field of personal data protection.

8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given the Operator consent to transfer data to a third party for the performance of obligations under a civil contract.

8.3. If inaccuracies in the personal data are detected, the User may update them independently by sending the Operator a notice to the Operator’s email address [email protected] with the note «Updating personal data.»

8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is stipulated by a contract or current legislation.

The User may revoke his/her consent to the processing of personal data at any time by sending the Operator a notice to the Operator’s email address [email protected] with the note «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, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or is provided with those documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. Restrictions set by the personal data subject on transfer (other than granting access) and on processing or conditions for processing (other than gaining access) personal data permitted for dissemination do not apply in cases of personal data processing in the government, public, or other public interest as determined by Russian Federation law.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows determining the personal data subject, no longer than is necessary for the purposes of processing, unless a longer storage period is provided by federal law or a contract in which the personal data subject is a party, beneficiary, or guarantor.

8.9. A condition for terminating personal data processing may be the achievement of the purposes of personal data processing, the expiration of the personal data subject’s consent, the personal data subject’s withdrawal of consent or a demand to cease processing, as well as detection of unlawful processing.

9. List of Actions Carried Out by the Operator with the Obtained Personal Data

9.1. The Operator collects, records, systematizes, accumulates, stores, updates (modifies), retrieves, uses, transfers (disseminates, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator carries out automated processing of personal data, obtaining and/or transferring the received information via information and telecommunication networks or otherwise.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing cross-border personal data transfer, the Operator shall notify the authorized body for the protection of personal data subjects' rights of its intention to perform such cross-border data transfer (this notification is submitted separately from the notice of intent to process personal data).

10.2. Before submitting the aforementioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

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11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by federal law.

11. Confidentiality of Personal Data

12.1. The User may request any clarifications regarding questions related to the processing of his/her personal data by contacting the Operator via email at [email protected].

12.2. This document will reflect any changes in the Operator’s personal data processing policy. The Policy remains in effect indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the internet at https://masterchar.com/en/privacy-policy.