Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of the Federal Law No. 152-ФЗ “On Personal Data” dated July 27, 2006 (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 the individual entrepreneur Diana Sergeevna Saraeva (hereinafter referred to as the Operator).
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 secrets, to be their most important goal and a condition for carrying out their activities.
1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://gca.studio.
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 suspension of personal data processing (except in cases where processing is necessary to correct personal data).
2.3. Website — a combination of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://gca.studio.
2.4. Personal data information system — a collection of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without the use of additional information, the affiliation of personal data to a specific User or other personal data subject.
2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, correction (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines 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 relating directly or indirectly to a specific or identifiable User of the website https://gca.studio.
2.9. Personal data authorized by the subject of personal data for distribution — personal data to which an unlimited circle of persons is granted access by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in accordance with the procedure provided for by the Personal Data Law (hereinafter the personal data authorized for distribution).
2.10. User — any visitor to the website https://gca.studio.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including the publication of personal data in the media, posting on information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system, and/or destruction of the physical media containing personal data.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in the event that the subject of personal data withdraws their consent to the personal data processing, as well as sends a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator shall:
— provide the personal data subject, at their request, with information concerning the processing of their personal data;
— organize personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries 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 the rights of personal data subjects with the necessary information at the request of that body within 10 days from receipt of such a request;
— publish or otherwise provide unrestricted access to this Policy regarding personal data processing;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and in cases provided for by the Personal Data Law;
— perform other duties provided for by the Personal Data Law.
4. Basic 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 for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— request the Operator to correct, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
— impose a condition of prior consent for the processing of personal data for the purpose of marketing goods, works, and services;
— withdraw consent to the processing of personal data, as well as send a request to terminate the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator’s unlawful actions or inaction in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
— provide the Operator with accurate data about themselves;
— notify the Operator of any correction (update, change) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predefined, and lawful purposes. Personal data processing that is incompatible with the purposes of personal data collection is not permitted.
5.3. It is not permitted to combine databases containing personal data that is processed for purposes that are incompatible with each other.
5.4. Only personal data that meets the purposes of its processing shall be processed..
5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. The personal data processed shall not be excessive with regard to the stated purposes of processing.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than is necessary for the purposes of processing personal data, unless the period of storing personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in the event that the need to achieve these purposes ceases to exist, unless otherwise provided by federal law.
6. Purposes of personal data processing
| Purpose of processing | Providing the User with access to services, information, and/or materials contained on the website; spam detection; technical purposes; ensuring security and compliance with the legislation of the Russian Federation; ensuring feedback from the User, including sending responses to inquiries, including through the use of third-party mailing services |
| Personal data | email addressphone numbersnameIP address; browser user-agent data; information from cookies |
| Legal basis | Legal acts pursuant to which and in accordance with which the Operator processes personal data: the Constitution of the Russian Federation; the Subject’s consent to the processing of personal data (in cases not expressly provided for by the legislation of the Russian Federation, but corresponding to the Operator’s authority); fulfillment of the Subject’s request; |
| Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data |
7. Conditions for processing personal data
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by an international agreement of the Russian Federation or by law, to carry out the functions, powers, and responsibilities assigned to the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a court order, an order of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data is processed, access to which is provided by the personal data subject or at their request to an unlimited circle of persons (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the collection, storage, transfer, and other types of personal data processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator shall ensure the preservation of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of applicable law or if the personal data subject has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are found in personal data, the User may update them independently by sending a notification to the Operator’s email address doc@gca.holdings with the subject line “Update of personal data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator’s email address doc@gca.holdings 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 tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution shall not apply in cases of processing personal data in the state, community, and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator shall ensure the confidentiality of personal data.
8.8. The operator shall store personal data in a form that allows the identification of the personal data subject for no longer than is necessary for the purposes of processing personal data, unless the personal data storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The conditions for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject, or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of actions performed by the Operator with the personal data received
9.1. The Operator collects, records, systematizes, accumulates, stores, corrects (updates, changes), extracts, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunications networks or without such.
10. Cross-border transfer of personal data
10.1. Before commencing cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of their intention to carry out cross-border transfer of personal data (such notification shall be sent 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 foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons who have access to personal data shall not disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.
12. Final provisions
12.1. The User may obtain any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator via email at doc@gca.holdings.
12.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://gca.studio/privacy-policy.