POLICY
ON PERSONAL DATA PROCESSING

1. General provisions

This policy on personal data processing (hereinafter referred to as the Policy) defines the procedure for personal data processing and measures to ensure personal data security taken by IE Raeva Alina Andreevna (hereinafter referred to as the Operator).
The main purpose and conditions for the Operator’s activities are to respect human and civil rights and freedoms of individuals when processing their personal data including protecting their rights for privacy and personal and family secrets. The Policy applies to any information that the Operator receives about visitors and users of the website with the domain name https://alina-raeva.com including its subdomains (hereinafter jointly referred to as the Operator’s website).



2. Terms and definitions
 
Personal data refers to any information relating directly or indirectly to a specific or identifiable User of the Operator’s website.

Personal data subject refers to a physical person who can be directly or indirectly defined through their personal data.

Personal data processing refers to any action (operation) or set of actions (operations) performed with or without the use of personal data automation tools, including personal data collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (sharing, provision, access), depersonalization, blocking, deletion, and destruction.
 
Automated processing of personal data refers to personal data processing using computer technology.

Cross-border transfer of personal data refers to personal data transfer to the territory of a foreign country to a foreign government body, foreign natural person, or foreign legal entity.

Deletion of personal data refers to any actions that result in an irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or destroy the physical media containing personal data.

Personal data blocking refers to temporary suspension of personal data processing (except for cases when processing is required to clarify personal data).

Personal data depersonalization refers to actions that make it impossible to determine, without the use of additional information, personal data ownership by a specific User or other subject of personal data.

Personal data disclosure refers to actions aimed at disclosing personal data to a specific person or a specific group of people.

Personal data authorized for sharing by the personal data subject refers to personal data to which an unlimited circle of persons has been granted access by the personal data subject by giving consent to personal data processing authorized by the personal data subject for personal data sharing in accordance with the procedure provided for by the Personal Data Act (hereinafter referred to as Personal Data Authorized for Sharing).

Personal data sharing refers to any actions aimed at personal data disclosure to an indefinite group of persons (personal data transfer) or at familiarization with personal data by an unlimited circle of persons, including personal data publication in mass media, information and telecommunications networks or provision of access to personal data by any other means.

The User refers to any visitor to the Operator’s website.


3. Basic rights and obligations of the Operator
3.1. The Operator shall have the right to:
– receive from the personal data subject reliable information and/or documents containing personal data;
– in the event that the personal data subject withdraws their consent to personal data processing, the Operator shall be entitled to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Act;
– independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Act and other regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Act or other federal laws.

3.2. The Operator shall be obliged to:
– provide the personal data subject, at his or her request, with information concerning their personal data processing;
– organize personal data processing in accordance with the procedure established by the current 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 Act;
– provide the body authorized for the protection of personal data subjects’ rights with the necessary information at the request of that authorized body within 30 calendar days from the date of the receipt of such request;
– publish or otherwise provide unrestricted access to this Policy;
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, deletion, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions;
– stop transmitting (sharing, providing, accessing) and processing personal data, and destroy it in the manner and in the cases provided for by the Personal Data Act;
– perform other duties as stipulated by the Personal Data Act.
4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects shall have the right to:
– receive information concerning their personal data processing, except in cases provided for by federal laws. The Operator shall provide the personal data subject with the information in an accessible form which shall not contain personal data relating to other personal data subjects, except in cases when there are legal grounds for disclosing such personal data. The scope of information and the procedure for obtaining it are established by the Personal Data Act;
– require the Operator to clarify, block or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purposes, as well as to take measures provided for by law to protect their rights;
– impose a condition of prior consent when processing their personal data for the purpose of marketing goods, works and services;
– withdraw their consent to personal data processing;
– exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects shall be obliged to:
– provide the Operator with accurate information about themselves;
– inform the Operator about any clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.


5. The Operator may process the following personal data of the User

• surname, first name, patronymic;
• email address;
• telephone number;
• registered address;
• date and place of birth;
• identity document details

The Operator’s website also collects and processes depersonalized data about its visitors (including cookies) using web analytics services (Yandex Metrica, Google Analytics, and others). In this Policy, the above data is collectively referred to as Personal data.

5.1. The Operator does not process special categories of personal data. It is allowed to process personal data that is authorized for sharing and belongs to the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Act, provided that the prohibitions and conditions set out in Article 10.1 of the Personal Data Act are complied with.

5.2. The User’s consent to the processing of personal data authorized for sharing shall be documented separately from the other consents to the processing of their personal data. The User shall directly provide the Operator with consent to process their personal data authorized for sharing.
The Operator shall publish information about the processing conditions and the existence of prohibitions and conditions for the processing of personal data authorized for sharing, by an unlimited circle of persons within no later than 3 (three) working days from the receipt of the User’s consent. The transfer (sharing, provision, access) of personal data authorized by the personal data subject for sharing must be terminated at any time upon the request of the personal data subject.
The request must include the surname, first name, patronymic (if available), telephone number, email address or postal address of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator who it is sent to.
Consent to the processing of personal data authorized for sharing shall cease to be valid upon the Operator’s receipt of such request.


6. Principles of personal data processing

6.1. Personal data shall be processed in accordance with the applicable law and on a fair basis.

6.2. Personal data processing shall be limited to the achievement of its purposes. Personal data processing that is inconsistent with the purposes of personal data collection shall not be permitted.

6.3. It shall not be permitted to combine databases containing personal data that is processed for the purposes that are incompatible with each other.

6.4. Only personal data that meets its processing purposes shall be processed.

6.5. The content and scope of the processed personal data shall be consistent with the stated processing purposes. The processed personal data shall not be excessive in relation to the stated processing purposes.

6.6. Accuracy, adequacy and, where necessary, relevance of personal data in relation to the processing purposes shall be ensured when processing personal data. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or correct incomplete or inaccurate data.

6.7. Personal data shall be stored in a form that allows personal data subjects to be identified for no longer than is necessary for the purposes of personal data processing, unless the personal data storage period is established by the Federal Law, an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or in the event that the need to achieve these purposes ceases to exist, unless otherwise provided for by the Federal Law.


7. Purposes for personal data processing

7.1. The User’s personal data shall be processed for the following purposes:
– to inform the User by sending emails and messages;
– to conclude, perform and terminate service agreements;
– to provide the User with access to the Operator’s website and its services;
– to register the User on the Operator’s website, if such registration is required;
– to send service messages;
– to send newsletters from the Operator and its partners;
– to conduct marketing researches;
– to make calls.

7.2. The Operator shall also have the right to send the User newsletters containing useful information from the Operator and/or the Operator’s partners. The User may refuse to receive such newsletters at any time by sending an email to the Operator at alvion.pro100@gmail.com  titled as ‘Refusal to newsletters’.

7.3. Users’ depersonalized data collected through Internet statistics services shall be used to gather information about Users’ activities on the Operator’s website to improve its quality and content.


8. Legal basis for personal data processing

8.1. The legal basis for personal data processing by the Operator shall be as follows:
– agreements concluded between the Operator and the subject of personal data;
– federal laws and other regulatory acts related to personal data protection;
– the User’s consent to their personal data processing, to the processing of their personal data authorized for sharing.

8.2. The Operator shall process the User’s personal data only if it is filled in and/or sent by the User independently through special forms located on the Operator’s website or sent directly to the Operator per email. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

8.3. The Operator shall process depersonalized data about the User if this is permitted in the User’s browser settings (if cookies and JavaScript are enabled).

8.4. The personal data subject independently decides on their personal data provision and gives their consent freely, of their own free will and in their own interest.


9. Terms and conditions for personal data processing

9.1. Personal data shall be processed upon the personal data subject’s consent to the processing of their personal data.

9.2. Personal data processing is required to achieve the purposes set out in the international treaty of the Russian Federation or by law, to perform the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.

9.3. Personal data processing is required for the administration of justice, the enforcement of a court order, an order of another authority or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Personal data processing is required for the fulfilment of an agreement, to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

9.5. Personal data processing is required to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.

9.6. Personal data whose access has been granted to an unlimited number of persons by the personal data subject or upon his/her request (hereinafter referred to as Publicly available personal data) shall be processed.

9.7. Personal data that is subject to publication or mandatory disclosure in accordance with the Federal Law shall be processed.


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

Security of personal data processed by the Operator shall be ensured through the implementation of legal, organizational and technical measures that are required to fully comply with the regulations of the current legislation on personal data protection.

10.1. The Operator shall ensure personal data safety and shall take all possible measures to prevent access to personal data by unauthorized persons.

10.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of the applicable legislation or if the personal data subject has provided consent to the Operator to transfer their data to a third party for the performance of obligations under a service agreement.

10.3. Should inaccurate personal data be found, the User may update it themselves by sending a notification to the Operator’s email address alvion.pro100@gmail.com  titled as ‘Personal data update’.

10.4. The duration of personal data processing shall be determined by the achievement of the purposes for which the personal data was collected unless another period is provided for by the Public Offer or applicable laws. The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator’s email address  alvion.pro100@gmail.com titled as ‘Withdrawal of consent to personal data processing’.

10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, shall be stored and processed by the specified entities (Operators) in accordance with their User Agreements and Privacy Policies. The subject of personal data and/or the User shall be obliged to familiarize themselves with the specified documents in a timely manner.
The Operator shall not be liable for the actions of third parties including service providers referred to in this clause.

10.6. Prohibitions enforced by the personal data subject on the transfer (except for providing access) as well as on the processing or conditions for processing (except for obtaining access) of personal data permitted for sharing, shall not apply in the cases of personal data processing in the government, social and other public interests defined by the legislation of the Russian Federation.

10.7. When processing personal data, the Operator shall ensure its confidentiality.

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

10.9. Conditions for the termination of personal data processing may include achievement of the purposes of personal data processing, expiry of the consent of the personal data subject or withdrawal of the consent by the personal data subject, as well as detection of unlawful personal data processing.


11. Actions with the received personal data carried out by the Operator

The Operator may collect, record, organize, accumulate, store, clarify (update, modify), extract, use, transfer (share, provide, access), depersonalize, block, delete, and destroy personal data. The Operator may carry out automated processing of personal data with or without receiving and/or transmitting the obtained information via information and telecommunications networks.


12. Cross-border transfer of personal data

Before initiating a cross-border transfer of personal data, the Operator must ensure that the foreign country which the personal data is to be transferred to provides reliable protection of the rights of personal data subjects.

Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only be carried out with a written consent of the personal data subject to the cross-border transfer of his/her personal data and/or for the purpose of executing an agreement which the personal data subject is a party to.


13. Personal data privacy

The Operator and other persons who have access to personal data shall be obliged not to disclose and not to share it with third parties without consent of the personal data subject, unless otherwise is provided for by the Federal Law.


14. Final provisions

If you have any questions, you can receive any clarification regarding the processing of your personal data by contacting the Operator per email: alvion.pro100@gmail.com.

The Policy is valid indefinitely until it is replaced by its new version and published on the Operator’s website.

In the event that certain provisions of the Policy become invalid, all other provisions of the Policy shall remain in force.

The Operator:
Full name: Raeva Alina Andreevna
INN 773612895188
OGRNIP 322774600172257
Email: alvion.pro100@gmail.com
Contact period: working days, 10.00-19.00 (Moscow time zone)
Published on: July 26, 2025