Policy on the Processing of Personal Data

This Privacy Policy explains how Evgeny Nikolaevich Orlov (the “Operator”) collects, uses, and protects personal data of visitors to the website https://evgeni-orlov.ru. It describes what information is processed, for what purposes, on what legal grounds, and what rights Users have in relation to their personal data.

1. General Provisions 
This Policy on the Processing of Personal Data has been developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law). It defines the procedures for processing personal data and the measures implemented by Evgeny Nikolaevich Orlov (hereinafter referred to as the Operator) to ensure the security of such data. 

1.1. The Operator’s primary purpose and essential condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of privacy and of personal and family confidentiality. 

1.2. This Policy 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://evgeni-orlov.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 personal data processing (except when processing is necessary to clarify the data). 

2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases, made available on the Internet at [https://evgeni-orlov.ru]. 

2.4. Personal data information system — a set of personal data contained in databases, as well as 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 specific personal data belong to a particular User or other subject of personal data. 

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

2.7. Operator — a state or municipal authority, legal entity, or individual who, independently or jointly with others, organizes and/or performs the processing of personal data, as well as determines the purposes of such processing, the scope of the processed data, and the actions performed with it. 

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable user of the website [https://evgeni-orlov.ru]. 

2.9. Personal data authorized by the subject for distribution — personal data made publicly available by the subject through explicit consent in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data authorized for distribution). 

2.10. User — any visitor to the website [https://evgeni-orlov.ru]. 

2.11. Provision of personal data — actions intended to disclose personal data to a specific person or a defined group of persons. 

2.12. Dissemination of personal data — actions intended to disclose personal data to an indefinite number of persons (transfer of data) or to make such data publicly accessible, including through media publication, placement on information or telecommunication networks, or providing access in any other way. 

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

2.14. Destruction of personal data — actions that result in the irreversible deletion of personal data, making it impossible to restore its content in the personal data information system and/or leading to the physical destruction of media containing such data.

3. Basic Rights and Obligations of the Operator 

3.1. The Operator has the right to:
- request reliable information and/or documents containing personal data from the data subject; 
- continue processing personal data without the consent of the data subject if such grounds are specified in the Personal Data Law, even in cases where the data subject withdraws consent or requests termination of processing; 
- independently determine the range and scope of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and related regulatory acts, unless otherwise required by the Personal Data Law or other federal legislation.

3.2. The Operator is obliged to:  
- provide the data subject, upon request, with information related to the processing of their personal data;
- organize the processing of personal data in accordance with the procedures established by the current legislation of the Russian Federation; 
- respond to requests and inquiries from data subjects or 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 the necessary information upon request, within ten days of receiving such a request; 
- publish or otherwise ensure unrestricted access to this Policy on 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, dissemination, or any other unlawful actions involving personal data; 
- cease the transfer (distribution, provision, access), processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law; 
- fulfill other obligations established by the Personal Data Law. 
Here’s the next part of your policy rewritten with natural, professional phrasing while keeping the legal meaning fully intact. 

 4. Basic 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 law. Such information must be provided by the Operator in an accessible form and must not include personal data relating to other individuals unless there are lawful grounds for disclosure. The scope of information and the procedure for obtaining it are established by the Personal Data Law; 
- request that the Operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the declared purpose of processing, and to take legal measures to protect their rights; 
- set a condition of prior consent for the processing of personal data for purposes related to the marketing and promotion of goods, works, or services; 
- withdraw their consent to the processing of personal data and request that the Operator cease such processing; 
- appeal to the authorized body for the protection of personal data subjects’ rights or file a lawsuit against the Operator’s unlawful actions or omissions related to their personal data;
- exercise other rights granted by the legislation of the Russian Federation. 

4.2. Personal data subjects are obliged to: 
- provide the Operator with accurate and up-to-date personal information; 
- notify the Operator of any clarifications, updates, or changes to their personal data. 

4.3. Individuals who provide the Operator with false information about themselves or with data about another person without that person’s consent shall bear liability in accordance with the legislation of the Russian Federation. 

5. Principles of Personal Data Processing 

5.1. Personal data shall be processed lawfully and fairly. 

5.2. Processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing personal data for purposes incompatible with the original purposes of collection is prohibited. 

5.3. The consolidation of databases containing personal data processed for incompatible purposes is not permitted. 

5.4. Only personal data that serve the purposes of processing shall be processed. 

5.5. The content and volume of processed personal data must correspond to the stated purposes of processing. Processing personal data that is excessive in relation to those purposes is not allowed. 

5.6. When processing personal data, the Operator shall ensure its accuracy, sufficiency, and, where necessary, its relevance to the purposes of processing. The Operator shall take or ensure the implementation of necessary measures to delete or clarify incomplete or inaccurate data. 

5.7. Personal data shall be stored in a form that allows identification of the data subject no longer than is necessary for the purposes of processing unless a longer storage period 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 depersonalized once the purpose of processing has been achieved or when such necessity ceases, unless otherwise provided by federal law. 

6. Purposes of Personal Data Processing 

Purpose of processing 
Informing the User by sending messages via messenger. 

Personal data processed 
l   Telegram nickname. 

Legal basis 
l   Contracts concluded between the Operator and the personal data subject.  

Types of personal data processing
l   Sending informational messages through the messenger. 

7. Conditions for Processing Personal Data 

7.1. Personal data shall be processed with the consent of the personal data subject to such processing.

7.2. Processing of personal data is permitted when necessary to achieve the purposes set forth by an international treaty of the Russian Federation or by law, or to perform the functions, powers, and duties assigned to the Operator under the legislation of the Russian Federation. 

7.3. Processing of personal data is carried out when necessary for the administration of justice or for the execution of a judicial act, or an act issued by another authority or official subject to enforcement under Russian law on enforcement proceedings. 

7.4. Processing of personal data is permitted when 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 of a contract under which the subject will be a beneficiary or guarantor. 

7.5. Personal data may be processed when necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that such processing does not infringe upon the rights and freedoms of the personal data subject. 

7.6. Processing applies to personal data made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data). 

7.7. Processing also applies to personal data subject to publication or mandatory disclosure in accordance with federal law. 

8. 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 legal, organizational, and technical measures that fully comply with the current legislation on personal data protection. 

8.1. The Operator guarantees the security of personal data and takes all possible measures to prevent unauthorized access. 

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases required by law or when the User has given consent for such transfer to fulfill obligations under a civil contract. 

8.3. If any inaccuracies are found in their personal data, the User may update them by sending an email to the Operator at jekk80@yandex.ru with the subject line “Update of personal data.” 

8.4. The duration of personal data processing is determined by the time required to achieve the purposes for which the data was collected, unless otherwise specified by a contract or by law.
The User may withdraw consent to the processing of personal data at any time by sending an email to jekk80@yandex.ru with the subject line “Withdrawal of consent to the processing of personal data.” 

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 own user agreements and privacy policies. The Operator bears no responsibility for the actions of third parties, including the service providers mentioned herein. 

8.6. Restrictions imposed by the personal data subject on the transfer (except access provision) or on the processing or conditions of processing (except access provision) of personal data permitted for distribution do not apply when such processing is carried out in the state, public, or other public interests as defined by Russian legislation. 

8.7. While processing personal data, the Operator ensures its confidentiality. 

8.8. The Operator stores personal data in a form that allows identification of the personal data subject only for as long as necessary to achieve the purposes of processing, unless a longer retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. 

8.9. Grounds for terminating the processing of personal data include the achievement of processing purposes, expiry of consent, withdrawal of consent, receipt of a request to stop processing, or the discovery of unlawful processing. 

9. List of Actions Performed by the Operator with the Received Personal Data 

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

9.2. The Operator performs automated processing of personal data, including the transmission and/or receipt of information via information and telecommunication networks or without such use.

10. Cross-Border Transfer of Personal Data 

10.1. Prior to initiating the cross-border transfer of personal data, the Operator must notify the authorized body responsible for protecting the rights of personal data subjects of its intention to conduct such a transfer (this notification is submitted separately from the general notification of intent to process personal data). 

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

 11. Confidentiality of Personal Data 

The Operator and other persons with access to personal data are prohibited from disclosing or distributing such data to third parties without the consent of the personal data subject, unless otherwise required by federal law. 

 12. Final Provisions 

12.1. Users may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at jekk80@yandex.ru

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains effective indefinitely until replaced by a new version. 

12.3. The current version of the Policy is publicly available on the website at https://evgeni-orlov.ru/en/privacy