1. General Provisions
This Personal Data Processing Policy is prepared 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") and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Ekaterina Tuvina (hereinafter referred to as the Operator).
1.1. The Operator considers its most important goal and condition for carrying out its activities to be the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Operator’s policy 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://tuvina.ru.
2. Key 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 cessation of personal data processing (except when 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://tuvina.ru.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility of determining, without 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 automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual, independently or jointly with others organizing and/or carrying out 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 – any information directly or indirectly related to an identified or identifiable User of the website
https://tuvina.ru.
2.9. Personal data permitted for dissemination – personal data to which access by an unlimited number of persons is granted by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User – any visitor to the website
https://tuvina.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 making personal data available to an unlimited number of persons, including the publication of personal data in the media, posting on information and telecommunication networks, or providing access to personal data 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 authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with no possibility of further recovery of the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
– Receive reliable information and/or documents containing personal data from the subject of personal data.
– Continue processing personal data without the subject’s consent if grounds specified in the Personal Data Law exist.
– Independently determine the composition and list of measures necessary and sufficient to fulfill obligations under the Personal Data Law and related regulations, 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, upon request, with information regarding the processing of their personal data.
– Organize the processing of personal data in accordance with the current legislation of the Russian Federation.
– Respond to inquiries and requests 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 personal data subjects’ rights with necessary information within 30 days of receiving a request.
– Publish or otherwise ensure unrestricted access to this Policy regarding personal data processing.
– Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, or other unlawful actions.
– Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in cases and manner prescribed by the Personal Data Law.
– Fulfill other obligations stipulated by the Personal Data Law.
4. Key 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 by federal laws. Information is provided in an accessible form and must not contain personal data related to other subjects unless legally justified.
– Demand that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purposes.
– Require prior consent for processing personal data for marketing purposes.
– Withdraw consent to the processing of personal data.
– Appeal to the authorized body or court against unlawful actions or inaction of the Operator regarding their personal data.
– Exercise other rights provided by Russian legislation.
4.2. Personal data subjects must:
– Provide the Operator with accurate information about themselves.
– Notify the Operator of any updates or changes to their personal data.
4.3. Individuals who provide the Operator with false information about themselves or another subject without consent are liable under Russian law.
5. Personal Data Processed by the Operator
5.1. Full name.
5.2. Email address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized visitor data (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, etc.).
5.5. The above data is collectively referred to as Personal Data in this Policy.
5.6. The Operator does not process special categories of personal data (race, nationality, political views, religious or philosophical beliefs, intimate life).
5.7. Processing of personal data permitted for dissemination is allowed only if the prohibitions and conditions specified in Article 10.1 of the Personal Data Law are met.
5.8. The User’s consent to the processing of personal data permitted for dissemination is obtained separately from other consents.
5.8.1 The User provides consent directly to the Operator.
5.8.2 The Operator must, within three business days of receiving consent, publish information on the processing conditions, prohibitions, and requirements for dissemination.
5.8.3 The transfer of personal data permitted for dissemination must cease upon the subject’s request, which must include their full name, contact details, and a list of data to stop processing.
5.8.4 Consent for processing personal data permitted for dissemination is revoked once the Operator receives the request specified in clause 5.8.3.
6. Principles of Personal Data Processing
6.1. Processing is lawful and fair.
6.2. Limited to specific, predefined, and legitimate purposes.
6.3. Incompatible databases must not be merged.
6.4. Only data relevant to the processing purposes is processed.
6.5. The content and volume of processed data must correspond to the stated purposes.
6.6. Accuracy, sufficiency, and relevance of data must be ensured.
6.7. Storage must not exceed the necessary period unless otherwise required by law.
7. Purposes of Personal Data Processing
7.1. To inform the User via email.
7.2. To provide access to services and materials on
https://tuvina.ru.
7.3. The Operator may send notifications about new products, services, and special offers. Users may opt out by emailing Privacy Policy with the subject “Unsubscribe from notifications.”
7.4. Anonymized data is used to improve website quality.
8. Legal Grounds for Processing
8.1. Legal grounds include:
– Federal laws (e.g., Federal Law No. 149-FZ “On Information”).
– Operator’s statutory documents.
– Agreements with the User.
– User’s consent.
8.2. The Operator processes data only if the User submits it via forms on
https://tuvina.ru or by email. Submission implies consent to this Policy.
8.3. Anonymized data is processed if allowed by the User’s browser settings (cookies, JavaScript).
9. Conditions of Processing
9.1. Requires the subject’s consent.
9.2. Necessary for fulfilling legal obligations or contracts.
9.3. Required for justice or enforcement proceedings.
9.4. Needed to protect the Operator’s or third parties’ legitimate interests.
9.5. Publicly available data may be processed.
10. Collection, Storage, and Transfer of Personal Data
10.1. The Operator ensures data security and prevents unauthorized access.
10.2. Data is not transferred to third parties unless required by law or under a civil contract.
10.3. Users may update their data by emailing Privacy Policy with the subject “Update personal data.”
10.4. Processing continues until the purpose is achieved or consent is withdrawn.
10.5. Third-party services (payment systems, etc.) handle data under their own policies.
10.6. Restrictions on data processing do not apply in cases of public interest.
10.7. The Operator ensures confidentiality.
10.8. Storage duration is determined by the processing purpose unless otherwise required by law.
10.9. Processing ceases upon achieving the purpose, withdrawal of consent, or unlawful processing.
11. Actions Performed with Personal Data
11.1. Collection, recording, systematization, storage, updating, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction.
11.2. Automated processing with or without information networks.
12. Cross-Border Data Transfer
12.1. The Operator ensures that the foreign state provides adequate protection before transferring data.
12.2. Transfer to non-compliant countries requires the subject’s written consent.
13. Confidentiality
The Operator and authorized persons must not disclose or distribute personal data without consent unless required by law.
14. Final Provisions
14.1. Users may contact the Operator for clarifications via email.
14.2. The Policy may be updated. The current version is available at
https://tuvina.ru/privacy.
14.3. The Policy remains effective until replaced by a new version.