Privacy Policy

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

1.1. The Operator considers compliance with the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy and personal and family confidentiality, to be a fundamental objective and condition of carrying out her activities.

1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the website https://drkonovalova.ru.

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 personal data processing, except where processing is necessary to clarify personal data.

2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, making them available on the Internet at https://drkonovalova.ru.

2.4. Personal data information system means a set of personal data contained in databases, together with the information technologies and technical means used to process such data.
2.5. Anonymisation of personal data means actions that make it impossible to determine, without using additional information, whether personal data belongs to a specific User or another personal data subject.

2.6. Processing of personal data means any action (operation), or set of actions (operations), performed with personal data using automated means or without such means, including collection, recording, systematisation, accumulation, storage, updating (modification), retrieval, use, transfer (dissemination, provision, access), anonymisation, blocking, deletion and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity or individual that independently or jointly with other persons organises and/or carries out the processing of personal data, as well as determines the purposes of processing, the categories of personal data to be processed and the actions (operations) performed with personal data.

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

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

2.10. User means any visitor to the website https://drkonovalova.ru.

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 indefinite number of persons or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.

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, 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 its content in a personal data information system, and/or the destruction of physical media containing personal data.

3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the personal data subject;
— continue processing personal data without the consent of the personal data subject if the subject withdraws consent or requests the cessation of processing, provided that there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to fulfil the obligations established by the Personal Data Law and related regulatory legal acts, 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 concerning the processing of their personal data;
— organise the processing of personal data in accordance with the applicable legislation of the Russian Federation;
— respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorised personal data protection authority, upon its request, with the necessary information within 10 days of receiving the request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as other unlawful actions involving personal data;
— cease the transfer (dissemination, provision or access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfil other obligations established by the Personal Data Law.

4.1. Personal data subjects have the right to:
— obtain information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such data. The list 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 stated purpose of processing, and to take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purpose of marketing goods, works or services;
— withdraw consent to the processing of personal data and request that the processing of personal data be terminated;
— appeal unlawful actions or inaction of the Operator in the processing of their personal data to the authorised personal data protection authority or in court;
— 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;
— notify 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, are liable in accordance with the legislation of the Russian Federation.

5.1. Personal data shall be processed lawfully and fairly.

5.2. Personal data processing shall be limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes for which it was collected is not permitted.

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

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

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

5.6. When processing personal data, its accuracy, adequacy and, where necessary, relevance to the purposes of processing shall be ensured. The Operator shall take necessary measures, and/or ensure that such measures are taken, to delete or correct incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or anonymised once the purposes of processing have been achieved or are no longer necessary, unless otherwise provided by federal law.

6.1. Purpose of processing.
To process the User’s enquiry and provide feedback using the specified telephone number.

6.2. Personal data processed:

• telephone numbers;
• name.

6.3. Legal basis.
The User’s consent to the processing of personal data in accordance with Federal Law No. 152-FZ of 27 July 2006, “On Personal Data.”

6.4. Types of personal data processing.
6.4.1. Collection, recording, systematisation, accumulation, storage, destruction and anonymisation of personal data.
6.4.2. Use of personal data to communicate with the User.

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

7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.

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

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

7.5. Personal data processing is 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 infringed.

7.6. Personal data may be processed where access to such data has been made available to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”).

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.

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

8.1. The Operator ensures the security of personal data and takes all reasonable measures to prevent unauthorised access to personal data.

8.2. The User’s personal data will not be transferred to third parties except where required by applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law agreement.

8.3. If inaccuracies are identified in personal data, the User may update it by sending a notice to the Operator’s email address, elenavictorovna2020@mail.ru, with the subject line “Update of Personal Data.”

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator’s email address, elenavictorovna2020@mail.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 services and other service providers, is stored and processed by such parties in accordance with their user agreements and privacy policies. The personal data subject should review these documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Restrictions imposed by the personal data subject on the transfer (other than granting access), processing or conditions of processing (other than obtaining access) of personal data authorised for dissemination do not apply where such data is processed in state, public or other interests defined by Russian law.

8.7. The Operator ensures the confidentiality of personal data during its processing.

8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.

8.9. Personal data processing may cease when the purposes of processing have been achieved, the personal data subject’s consent has expired or been withdrawn, the subject has requested the cessation of processing, or unlawful processing has been identified.

9.1. The Operator carries out the collection, recording, systematisation, accumulation, storage, updating (modification), retrieval, use, transfer (dissemination, provision, access), anonymisation, blocking, deletion and destruction of personal data.

9.2. The Operator processes personal data by automated means, with and/or without receiving and/or transmitting the information obtained via information and telecommunications networks.

10.1. Before commencing cross-border transfers of personal data, the Operator shall notify the authorised personal data protection authority of the intention to carry out such transfers. This 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 foreign state authorities, foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is planned.

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

12.1. The User may obtain clarification on any matters relating to the processing of their personal data by contacting the Operator at elenavictorovna2020@mail.ru.

12.2. Any changes made by the Operator to this Personal Data Processing Policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available online at https://drkonovalova.ru/privacy-policy.