Personal Data Processing Policy1. General Provisions
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been drafted in accordance with Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter – the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by Sergey Andreevich Odintsov (hereinafter – the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the protection of the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family confidentiality, to be one of its highest priorities.
1.2. This Policy applies to all information the Operator may obtain about visitors of the website https://well-state.com/.
2. Key Terms
2.1. Automated processing of personal data – the 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 graphic and informational materials, as well as software and databases, accessible via the Internet at https://well-state.com/.
2.4. Personal data information system – a system consisting of databases containing personal data and IT solutions that process this data.
2.5. Anonymization of personal data – actions that render it impossible to identify the data subject without additional information.
2.6. Processing of personal data – any operation or set of operations performed with or without automation, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a government authority, municipal body, legal or natural person who organizes and/or carries out the processing of personal data independently or jointly and determines the purposes and scope of the data.
2.8. Personal data – any information relating to a directly or indirectly identified or identifiable user of https://well-state.com/.
2.9. Publicly disclosed personal data – personal data made publicly available by the data subject by giving consent in accordance with the Personal Data Law.
2.10. User – any visitor of https://well-state.com/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or group.
2.12. Distribution of personal data – actions aimed at disclosing personal data to an indefinite group of people, including publication in media or online.
2.13. Cross-border transfer of personal data – the transfer of personal data to a foreign state authority or a foreign legal/natural person.
2.14. Destruction of personal data – irreversible deletion of personal data making it impossible to restore its content.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
– request accurate information and/or documents from the data subject;
– continue processing personal data without consent in cases provided by the Personal Data Law;
– define the scope of measures needed to comply with the Personal Data Law unless otherwise stipulated by federal laws.
3.2. The Operator is obliged to:
– provide information on the processing of personal data upon request;
– organize processing in accordance with Russian legislation;
– respond to requests from data subjects or their legal representatives;
– inform the authorized body for the protection of data subjects’ rights within 10 days upon request;
– publish or otherwise ensure unrestricted access to this Policy;
– implement legal, organizational, and technical measures to protect personal data;
– stop processing and destroy personal data in cases stipulated by the Personal Data Law;
– fulfill other obligations as defined by the Personal Data Law.
4. Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
– receive information regarding the processing of their personal data;
– request rectification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not needed for the stated purpose;
– require prior consent for processing in cases of direct marketing;
– withdraw consent and demand termination of processing;
– file complaints with the authorized body or through the courts;
– exercise other rights under Russian law.
4.2. Data subjects are obliged to:
– provide accurate personal data;
– inform the Operator of any updates or changes to their personal data.
4.3. Persons who provide false information or data about other individuals without their consent bear responsibility under Russian law.
5. Principles of Personal Data Processing
5.1. Processing must be lawful and fair.
5.2. Processing is limited to achieving specific, legitimate goals.
5.3. Data incompatible with its intended purposes shall not be merged.
5.4. Only data necessary for the purposes of processing shall be processed.
5.5. The scope of data must be relevant and not excessive.
5.6. Data must be accurate, sufficient, and up to date where necessary.
5.7. Personal data shall be stored no longer than required for the purpose, unless otherwise required by law or agreement.
6. Purpose of Data Processing
Purpose: Informing the user via email, calls, or messages in messengers.
Personal Data:
- Full name
- Email address
- Phone number
Legal Basis:
- Operator’s statutory documents
- Types of Processing:
- Collection, recording, systematization, accumulation, storage, destruction, anonymization
- Sending informational emails and messages
7. Conditions for Processing Personal Data
7.1. With the data subject’s consent
7.2. As required by law or international agreements
7.3. As necessary for legal enforcement
7.4. For contract performance
7.5. To protect legal interests without infringing on rights
7.6. For public data processing
7.7. As mandated by federal law for public disclosure
8. Collection, Storage, Transfer and Processing Procedure
The Operator ensures the security of personal data through legal, organizational, and technical measures.
8.1. Data is securely stored to prevent unauthorized access.
8.2. Personal data is never shared with third parties unless required by law or agreed to by the data subject.
8.3. Users may update their data by emailing wellstateproperty@gmail.com with the subject “Data Update.”
8.4. Data is processed only as long as necessary to fulfill its purpose. Consent can be withdrawn at any time by emailing “Withdrawal of Consent” to wellstateproperty@gmail.com.
8.5. Data collected by third-party services is stored and processed in accordance with their policies. The Operator is not responsible for third-party actions.
8.6. Public interest exceptions override restrictions on disclosure.
8.7. Confidentiality is guaranteed throughout processing.
8.8. Data is retained no longer than necessary unless otherwise provided by law.
8.9. Processing ends upon goal achievement, consent expiration, withdrawal, or unlawful use.
9. Actions Taken with Personal Data
9.1. The Operator collects, records, organizes, accumulates, stores, updates, extracts, uses, transfers, anonymizes, blocks, deletes, and destroys personal data.
9.2. Automated processing may occur with or without telecom networks.
10. Cross-Border Data Transfer
10.1. The Operator must notify the authorized authority before any cross-border data transfer.
10.2. Prior to notification, the Operator must verify the recipient’s legal compliance.
11. Data Confidentiality
The Operator and any party with access to personal data are required not to disclose or distribute such data without the subject’s consent unless otherwise required by law.
12. Final Provisions
12.1. Users may contact the Operator with questions at wellstateproperty@gmail.com.
12.2. Changes to this Policy will be reflected in this document. The Policy remains effective until replaced.
12.3. The latest version is publicly available at https://well-state.com/politics/en