Personal data processing policy
1. general points

This personal data processing policy is prepared in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ “On Personal Data” (hereinafter the “Personal Data Law”) and defines the personal data processing procedure and personal data security measures undertaken by Baranova Monaco (hereinafter the “Operator”).
1.1 The Operator’s most important purpose and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of rights to privacy, personal and family secrets.
1.2 This Operator’s personal data processing policy (the “Policy”) applies to all information that the Operator may receive about visitors to https://baranovamonaco.com/.

2. basic concepts used in the policy
2.1 Automated processing of personal data is the processing of personal data by means of computer technology.
2.2 Blocking of personal data – temporary suspension of processing of personal data (unless the processing is necessary to clarify the personal data).
2.3 Website – a collection of graphic and informational materials, as well as computer programs and databases, making them available on the Internet at the network address https://baranovamonaco.com/.
2.4 Personal data information system – a set of information technologies and technical means contained in personal data bases and ensuring the processing of personal data.
2.5 Impersonalisation of personal data – actions that make it impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another subject of personal data.
2.6 Processing of personal data means any action (operation) or a set of actions (operations) performed with or without the use of means of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7 Operator – a state body, municipal authority, legal entity or natural person, independently or together with other persons, arranging and/or carrying out the processing of personal data, as well as determining the purposes of processing of personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8 Personal data – any information relating directly or indirectly to an identified or identifiable User of the https://baranovamonaco.com/ website.
2.9 Personal data permitted by the personal data subject for dissemination – personal data, access to which is granted to an unlimited number of persons by the personal data subject by giving consent to processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter
– personal data permitted for dissemination).
2.10. A user is any visitor to the https://baranovamonaco.com/ website.
2.11. Provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data – any action aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or to make personal data available to an unlimited number of persons, including disclosure of personal data in the media, placement in 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 a foreign state authority, foreign natural person or foreign legal entity.
2.14. Destruction of personal data – any action resulting in the destruction of personal data irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and/or destruction of tangible media of personal data.

3 The basic rights and duties of the Operator
3.1 The operator shall have the right:
– Receive accurate information and/or documents containing personal data from the data subject;
– If the personal data subject withdraws their consent to the processing of personal data and requests the termination of personal data processing, the operator may continue the processing of personal data without the consent of the personal data subject on the grounds set out in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of obligations under the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2 The operator shall be obliged to:
– provide the data subject, at his or her request, with information relating to the processing of his or her personal data;
– organise the processing of personal data in accordance with the procedure established by the applicable laws 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;
– to notify the competent authority for the protection of the rights of personal data subjects upon the request of that authority within 10 days from the date of receipt of such request;
– publish or otherwise provide unrestricted access to this Policy on the processing of personal data;
– Take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, sharing, distribution of personal data, as well as other unlawful acts in relation to personal data;
– stop the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for in the Personal Data Act;
– fulfil other obligations stipulated in the Personal Data Act.

4. basic rights and obligations of personal data subjects
4.1 Personal data subjects have the right to
– Receive information relating to the processing of his or her personal data, except in cases provided for by federal laws. Information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, unless there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Act;
– Demand that the operator clarify, block or destroy personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and to take statutory measures to protect their rights;
– to condition prior consent when processing personal data for the purpose of marketing goods, works and services;
– To withdraw consent to the processing of personal data and to request the termination of the processing of personal data;
– To appeal to the competent authority for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in processing his personal data;
– to exercise other rights provided for by Russian law.
4.2 Personal data subjects shall
– provide the Operator with accurate information about yourself;
– inform the operator of any changes (updates, amendments) to your personal data.
4.3 Persons who provided the Operator with false information about themselves or information about another personal data subject without their consent shall be liable in accordance with Russian law.

5. Principles of personal data processing
5.1 Processing of personal data shall be lawful and fair.
5.2 Processing of personal data shall be limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.
5.3 Databases containing personal data whose processing is incompatible with each other shall not be merged.
5.4 Only personal data that is suitable for processing shall be processed.
5.5 The content and scope of personal data processed shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.
5.6 When processing personal data, the accuracy of personal data, its sufficiency and, where necessary, its relevance in relation to the purposes of personal data processing shall be ensured. The operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7 Personal data shall be stored in a form that allows identification of the personal data subject for no longer than the purpose of personal data processing requires, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalised upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.

6. Purposes of personal data processing
Purpose of treatment
Clarification of order details
Personal data
• surname, first name, patronymic
• email
• telephone numbers
• Address of actual place of residence and registration at theplace of residence and/or domicile
Legal grounds
• the statutory (constituent) documents of the Operator
Types of personal data processing
• Collection, recording, systematisation, accumulation, storage, destruction and anonymisation of personal data
• Sending newsletters to an email address

7. Conditions for the processing of personal data
7.1 Processing of personal data is subject to the personal data subject’s consent to the processing of their personal data.
7.2 Processing of personal data is necessary in order to achieve the purposes set out in an international treaty of the Russian Federation or by law, to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
7.3 Processing of personal data is necessary for administration of justice, execution of a judicial act, act of another authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4 Processing of personal data is necessary in order to fulfil an agreement to which the personal data subject is a party or a beneficiary or guarantor, as well as to conclude 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 The processing of personal data is necessary for the exercise of the rights and lawful interests of the operator or third parties or for the achievement of socially important objectives, provided that the rights and freedoms of the personal data subject are not infringed thereby.
7.6 Personal data shall be processed to which access is granted to an unlimited number of persons by the subject of personal data or at his or her request (hereinafter, “publicly accessible personal data”).
7.7 Personal data subject to publication or compulsory disclosure under federal law shall be processed.

8. Procedure for the collection, storage, transfer and other processing of personal data
The security of personal data processed by the Operator is ensured by implementing legal, organisational and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.
8.1 The operator shall ensure the security of personal data and shall take all possible measures to exclude access to personal data by unauthorised persons.
8.2 Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfil obligations under a civil law contract.
8.3 If inaccuracies in the personal data are identified, the User may update the personal data themselves by sending a notification to the Operator’s email address baranova.assistant@gmail.com, marked “Update of personal data”.
8.4 The time period for processing personal data is determined by achieving the purposes for which the personal data was collected, unless a different time period is stipulated by the contract or applicable law.
The user may withdraw their consent to the processing of personal data at any time by sending a notice by e-mail to the Operator’s e-mail address baranova.assistant@gmail.com, marked “Withdrawal of consent to process personal data”.
8.5 All information that is collected by third party services, including payment systems, means of communication and other service providers, is stored and processed by said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or with the said documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6 The prohibitions established by the personal data subject on the transfer (other than granting access) and processing or conditions of processing (other than obtaining access) of personal data authorised for distribution shall not apply in cases of processing of personal data for state, public and other public interests as defined by Russian law.
8.7 The operator shall ensure the confidentiality of personal data when processing personal data.
8.8. The operator shall store personal data in a form enabling the identification of the personal data subject for no longer than the purposes of personal data processing require, unless the period of storage of personal data is prescribed by federal law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor under which the personal data subject is a beneficiary.
8.9 A condition for termination of personal data processing may be the achievement of the personal data processing objectives, expiry of the personal data subject’s consent, withdrawal of consent by the personal data subject or a request to terminate personal data processing, as well as detection of unlawful processing of personal data.

9. List of actions performed by the operator with the personal data received
9.1 The operator shall collect, record, systematise, aggregate, store, clarify (update, modify), extract, use, transmit (distribute, provide, access), anonymise, block, delete and destroy personal data.
9.2 The Operator shall carry out automated processing of personal data with or without the receipt and/or transmission of the information received via information and telecommunications networks.

10. Cross-border transfer of personal data
10.1 The operator shall notify the competent authority for the protection of personal data subjects of its intention to transfer personal data across borders (such notification shall be sent separately from the notification of intention to process personal data) before commencing the cross-border transfer of personal data.
10.2 Before submitting the above notification, the Operator shall obtain the relevant information from the foreign authorities, foreign natural persons, foreign legal persons to whom 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 are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final provisions
12.1 The User may obtain any clarification on questions of interest regarding the processing of their personal data by contacting the Operator by email at baranova.assistant@gmail.com.
12.2 This document will reflect any changes to the Operator’s personal data processing policy. The Policy shall be valid indefinitely until replaced by a new version.
12.3 The current version of the Policy is freely available on the Internet at https://baranovamonaco.com/privacy.