Privacy Policy

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and determines the procedure for processing personal data and the measures to ensure the security of personal data taken by the Petrozavodsk City Public Organization “Petrozavodsk–Tübingen Friendship Society” (hereinafter — the Operator).

Operator: Petrozavodsk City Public Organization “Petrozavodsk–Tübingen Friendship Society”

(abbreviated name: PGOO “OD Petrozavodsk–Tübingen”)
OGRN 1191001009902, INN 1001345225, KPP 100101001
Legal address: 185011, Republic of Karelia, Petrozavodsk, Nekrasova St. (Kukkovka District), 42
Phone: +7 (953) 549-55-88
E-mail: ptz-tue1@yandex.ru

1. General provisions

1.1. The Operator’s most important goal and condition for carrying out its activities is to observe the rights and freedoms of man and citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrecy.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the Website.

1.3. The Operator’s Website operates on the basis of the “GIRVAS” content management system, which belongs to third parties. Technical support of the Website is carried out on the basis of an agreement with the developer — Individual Entrepreneur Andrey Ruslanovich Shestakov (OGRNIP 323100000029062), who may act as a person processing personal data on behalf of the Operator in terms of the technical support of the Website.

1.4. This Policy is a publicly available document posted on the Internet at: https://tuebingen.10-nko.ru/page/document--privacy-policy

2. Basic concepts 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 the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address: tuebingen.10-nko.ru, as well as its subdomains.

2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to 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 with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — Petrozavodsk City Public Organization “Petrozavodsk–Tübingen Friendship Society,” which independently or jointly with other persons 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.

2.9. Personal data authorized by the subject of personal data for distribution — personal data to which access by an unlimited circle of persons has been provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner provided for by the Personal Data Law.

2.10. User — any visitor to the Website.

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

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including publication of personal data in the media, placement in information and telecommunications networks, or providing access to personal data in any other way.

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

2.14. Destruction of personal data — any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material media of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right:

to receive from the subject of personal data reliable information and/or documents containing personal data;
in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sends a request demanding the termination of the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the normative 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 subject of personal data, at their request, with information concerning the processing of their personal data;
to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
to respond to appeals and requests of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
to inform the authorized body for the protection of the rights of subjects of personal data, at the request of that body, of the necessary information within 10 days from the date of receipt of such request;
to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
to take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, 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, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
to fulfill other obligations provided for by the Personal Data Law.

4. Basic rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right:

to receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases 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;
to demand from the Operator clarification of their personal data, its blocking or destruction if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
to put forward a condition of prior consent when processing personal data for the purposes of promoting goods, works, and services on the market;
to withdraw consent to the processing of personal data, as well as to send a request demanding the termination of the processing of personal data;
to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when processing their personal data;
to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged:

to provide the Operator with reliable data about themselves;
to inform the Operator about the clarification (updating, modification) of their personal data.

5. Principles of personal data processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, 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 the processed personal data correspond to the stated purposes of processing. Excessiveness of the processed personal data in relation to the stated purposes of their processing is not permitted.

5.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, where necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows the subject of personal data to be identified, no longer than the purposes of processing personal data require, unless the storage period of personal data is established by federal law or by a contract to which the subject of personal data is a party, a beneficiary, or a guarantor. The processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Conditions for processing personal data

6.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

6.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

6.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

6.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or a beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.

6.5. The 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 goals, provided that the rights and freedoms of the subject of personal data are not violated.

6.6. The processing of personal data is carried out, access to which by an unlimited circle of persons has been provided by the subject of personal data or at their request (hereinafter — publicly available personal data).

6.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

7. Procedure for collection, storage, transfer, and other types of processing of personal data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary for the full fulfillment of the requirements of the current legislation in the field of personal data protection.

7.1. The Operator ensures the preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

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

7.3. If inaccuracies are found in personal data, the User can update them independently by sending the Operator a notification to the email address ptz-tue1@yandex.ru with the subject “Personal Data Update.”

7.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by a contract or current legislation. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to ptz-tue1@yandex.ru with the subject “Withdrawal of Consent to Personal Data Processing.”

7.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

7.6. The prohibitions established by the subject of personal data on transfer (except for provision of access), as well as on processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Russian Federation.

7.7. When processing personal data, the Operator ensures the confidentiality of personal data.

7.8. If the Operator carries out the delivery of goods (including merch), data about the recipient and the final delivery point (last name, first name, address, contact phone number) may be collected to fulfill obligations under the contract. Delivery of goods is carried out with the involvement of transport companies and courier services, which act as independent operators of personal data and process the information provided to them in accordance with their own privacy policies.

7.9. The Operator stores personal data in a form that allows the subject of personal data to be identified, no longer than the purposes of processing personal data require, unless the storage period of personal data is established by federal law or by a contract to which the subject of personal data is a party, a beneficiary, or a guarantor.

7.10. The Operator works with the following categories of personal data on the Website: last name, first name, patronymic (if any), email address, phone number, and information collected through metric programs. Additionally, at the User’s discretion and when independently filling out the relevant forms, the Operator may receive: a facial image (avatar), links to personal pages on social networks, as well as other information that the User has decided to indicate in their profile.

7.11. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a demand to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.

8. Use of web analytics and technical support services

8.1. The Operator uses the following services provided by YANDEX LLC (INN: 7736207543, legal address: 119021, Moscow, L. Tolstogo St., 16):

Yandex.Metrica — for collecting depersonalized statistical data on User behavior on the Website (traffic sources, pages viewed, time on the site, depth of viewing, technical characteristics of devices, masked IP address).
Yandex.Webmaster — for technical analysis and optimization of the Website (data on page indexing, scanning errors, search queries in depersonalized form).

8.2. The legal basis for processing data using these services is the User’s consent expressed in the browser settings (acceptance of cookies) and continued use of the Website. The User can prohibit the collection of data by Yandex.Metrica using the browser extension “Yandex.Metrica Blocker.”

8.3. More details on the procedure for processing data by Yandex services can be found in the Yandex Privacy Policy: https://yandex.ru/legal/confidential/

9. List of actions performed by the Operator with the received personal data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunications networks or without such.

10. Cross-border transfer of personal data

10.1. The Operator does not carry out cross-border transfer of personal data to the territory of foreign states.

10.2. If in the future there is a need for cross-border transfer of personal data, the Operator undertakes to notify the authorized body for the protection of the rights of subjects of personal data in the manner established by the legislation of the Russian Federation and to obtain all necessary information from foreign recipients of personal data before the start of such transfer.

11. Confidentiality of personal data

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

12. Final provisions

12.1. The User can obtain any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator via email at ptz-tue1@yandex.ru.

12.2. This document will reflect any changes to the personal data processing policy by the Operator. The Policy is valid 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://tuebingen.10-nko.ru/page/document--privacy-policy

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