PERSONAL DATA PROCESSING POLICY

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and establishes the procedure for processing personal data and the measures taken by ANO “Theatrical Technologies” (hereinafter referred to as the “Operator”) to ensure the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy and personal and family confidentiality, to be one of its most important objectives and conditions for conducting its activities.

1.2. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://anott.info.

2. Key Terms Used in This Policy

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

2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where processing is necessary to clarify or update personal data.

2.3. Website means a collection of graphic and informational materials, as well as software and databases, making them available on the Internet at https://anott.info.

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

2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belong to a particular User or other personal data subject.

2.6. Processing of personal data means any action or set of actions performed with or without the use of automated means in relation to personal data, including collection, recording, organization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision or access), depersonalization, blocking, deletion and destruction of personal data.

2.7. Operator means a state or municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of processing, the personal data to be processed and the actions performed with such personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://anott.info.

2.9. Personal data authorized by the data subject for dissemination means personal data to which the data subject has granted access to an unlimited number of persons by providing consent to the processing of personal data authorized for dissemination in accordance with the procedure established by the Personal Data Law.

2.10. User means any visitor to the website https://anott.info.

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

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an unlimited number of persons, including publication of personal data in the media, placement on information and telecommunications networks, or otherwise providing access to personal data.

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

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore their content in a personal data information system and/or resulting in the destruction of physical media containing such 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 data subject;

— continue processing personal data without the consent of the data subject, where grounds specified by the Personal Data Law exist, including where the data subject withdraws consent or requests termination of processing;

— independently determine the measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulations adopted pursuant thereto, unless otherwise provided by applicable federal laws.

3.2. The Operator is obliged to:

— provide the data subject, upon request, with information concerning the processing of their personal data;

— organize the processing of personal data in accordance with the applicable legislation of the Russian Federation;

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

— provide the authorized body responsible for protecting the rights of personal data subjects with the necessary information within 10 days of receiving such a request;

— publish or otherwise provide unrestricted access to this Policy;

— take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or dissemination, as well as against other unlawful actions involving personal data;

— cease the transfer, processing and access to personal data and destroy personal data in the cases and manner provided for by the Personal Data Law;

— perform other obligations established 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 concerning the processing of their personal data, except in cases provided for by federal law;

— require the Operator to clarify, block or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and take measures provided by law to protect their rights;

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

— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;

— appeal to the authorized body responsible for protecting the rights of personal data subjects or to a court against unlawful acts or omissions of the Operator in processing their personal data;

— 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;

— inform the Operator of any clarification, update or change to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent shall be liable 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. Personal data processing shall be limited to achieving specific, predetermined and legitimate purposes. Processing incompatible with the purposes for which personal data were collected shall not be permitted.

5.3. Databases containing personal data processed for incompatible purposes shall not be combined.

5.4. Only personal data relevant to the purposes of processing shall be processed.

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

5.6. The accuracy, sufficiency and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take or arrange for appropriate measures to delete or correct incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than required for the purposes of processing, unless a longer retention period is established by federal law or an agreement to which the data subject is a party, beneficiary or guarantor. Personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or when they are no longer necessary, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing:
Providing the User with access to the services, information and/or materials available on the website.

Personal data processed:
• Last name, first name and patronymic name.

Legal basis:
• Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection.”

Types of personal data processing:
• Sending informational emails to the User’s email address.

7. Conditions for Personal Data Processing

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

7.2. Personal data may be processed where such processing is necessary to achieve purposes stipulated by an international treaty of the Russian Federation or by law, or to exercise the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.

7.3. Personal data may be processed where necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data may be processed where necessary for the performance of an agreement to which the data subject is a party, beneficiary or guarantor, or for entering into an agreement at the initiative of the data subject or an agreement under which the data subject will be a beneficiary or guarantor.

7.5. Personal data may be processed where necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data made publicly available by the data subject or at their request may be processed.

7.7. Personal data subject to publication or mandatory disclosure under federal law may be processed.

8. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data

The security of personal data processed by the Operator shall be ensured through the implementation of legal, organizational and technical measures necessary to comply fully with applicable personal data protection legislation.

8.1. The Operator shall ensure the security of personal data and take all possible measures to prevent unauthorized persons from accessing personal data.

8.2. The User’s personal data shall not be transferred to third parties under any circumstances, except where required by applicable law or where the data subject has consented to such transfer for the purpose of fulfilling obligations under a civil-law agreement.

8.3. If inaccuracies are identified in personal data, the User may update them independently by sending a notification to the Operator at tolstov27@gmail.com with the subject line “Personal Data Update.”

8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is stipulated by an agreement or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending an email to tolstov27@gmail.com 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, shall be stored and processed by those parties in accordance with their respective User Agreements and Privacy Policies.

The Operator shall not be responsible for the actions of such third parties, including the service providers referred to in this paragraph.

8.6. Restrictions imposed by the personal data subject on the transfer (other than provision of access), processing or conditions of processing of personal data authorized for dissemination shall not apply where personal data are processed in the public, state or other public interests defined by the legislation of the Russian Federation.

8.7. The Operator shall ensure the confidentiality of personal data when processing them.

8.8. The Operator shall store personal data in a form that permits identification of the data subject for no longer than necessary for the purposes of processing, unless a longer storage period is established by federal law or an agreement to which the data subject is a party, beneficiary or guarantor.

8.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the data subject’s consent, withdrawal of consent by the data subject, receipt of a request to terminate processing, or identification of unlawful processing of personal data.

9. Actions Performed by the Operator with Personal Data

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

9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the resulting information via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing cross-border transfers of personal data, the Operator shall notify the authorized body responsible for protecting the rights of personal data subjects of its intention to carry out such transfers. Such notification shall be submitted separately from the notification of the intention to process personal data.

10.2. Before submitting the above notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals and/or foreign legal entities to which the cross-border transfer of personal data is intended to be made.

11. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data shall not disclose personal data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain clarification on any matters relating to the processing of their personal data by contacting the Operator at tolstov27@gmail.com.

12.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.

12.3. The current version of this Policy is publicly available on the Internet at: https://anott.info/conf.