This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ dated July 27, 2006, «On Personal Data» (hereinafter referred to as the «Personal Data Law») and defines the policies, procedures, and terms governing the processing of personal data by Natalia V. Golik, Sole Proprietor (hereinafter referred to as the «Operator»).
Any matters related to the processing of personal data not addressed by this Policy shall be governed by the applicable legislation of the Russian Federation on personal data.
1.1. The Operator considers the protection of human and civil rights and freedoms in the processing of personal data — including the right to privacy and the confidentiality of personal and family life — to be a fundamental priority and prerequisite of its operations.
1.2. This Personal Data Processing Policy (hereinafter referred to as the «Policy») applies to all information that the Operator may collect from visitors to the website https://smmgolik.com/.
2.1. Automated Processing of Personal Data — the processing of personal data using computing technology.
2.2. Restriction of Personal Data — the temporary cessation of personal data processing (except where processing is necessary to update or correct such data).
2.3. Website — a collection of graphic and informational materials, as well as software applications and databases, made accessible on the Internet at https://smmgolik.com/.
2.4. Personal Data Information System — the aggregate of personal data contained in databases, together with the information technologies and technical means that enable their processing.
2.5. Anonymization of Personal Data — actions that render it impossible, without the use of additional information, to attribute personal data to a specific User or other data subject.
2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed on personal data, whether by automated or non-automated means, including collection, recording, organization, accumulation, storage, modification (updating, amendment), retrieval, use, transfer (distribution, provision, access), anonymization, restriction, deletion, and destruction.
2.7. Operator — a government body, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes, scope, and methods of such processing.
2.8. Personal Data — any information relating directly or indirectly to an identified or identifiable User of the website https://smmgolik.com/.
2.9. Personal Data Authorized for Distribution by the Data Subject — personal data made accessible to an unlimited number of persons by the data subject through their consent to the processing and distribution of such data in the manner prescribed by the Personal Data Law (hereinafter referred to as «data authorized for distribution»).
2.10. User — any visitor to the website https://smmgolik.com/.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific individual or a defined group of persons.
2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited audience, including publication through mass media, placement on information and telecommunications networks, or granting access by any other means.
2.13. Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state, to a foreign government authority, 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 recover the content of such data within the personal data information system and/or resulting in the destruction of physical media containing personal data.
3.1. The Operator has the right to:
— Receive accurate information and/or documents containing personal data from the data subject;
— Continue processing personal data without the data subject’s consent in the event of consent withdrawal or a request to cease processing, provided that lawful grounds exist under the Personal Data Law;
— Independently determine the composition and scope of measures necessary and sufficient to fulfill its obligations under the Personal Data Law and related regulations, unless otherwise stipulated by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— Provide data subjects, upon request, with information concerning the processing of their personal data;
— Organize the processing of personal data in accordance with the applicable legislation of the Russian Federation;
— Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized body for the protection of data subjects’ rights with the necessary information within 10 days of receiving such a request;
— Publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
— Implement legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, restriction, copying, provision, distribution, and any other unlawful actions;
— Cease the transfer (distribution, provision, access) of personal data, discontinue processing, and destroy personal data in the manner and in the cases prescribed by the Personal Data Law;
— Fulfill all other obligations as provided for by the Personal Data Law.
4.1. Data subjects have the right to:
— Obtain information regarding the processing of their personal data, except in cases provided for by federal law. Such information shall be provided by the Operator in an accessible format and shall not include personal data of other data subjects, unless there are lawful grounds for disclosing such data. The scope and procedure for obtaining this information are established by the Personal Data Law;
— Request rectification, restriction, or destruction of their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take lawful measures to protect their rights;
— Require prior consent as a condition for the processing of personal data for the purposes of marketing goods, works, and services;
— Withdraw consent to the processing of personal data and to submit a request for the cessation of such processing;
— File a complaint with the authorized body for the protection of data subjects’ rights or seek judicial remedies against unlawful actions or inaction by the Operator in processing their personal data;
— Exercise any other rights provided for by the legislation of the Russian Federation.
4.1. Data subjects have the right to:
— Obtain information regarding the processing of their personal data, except in cases provided for by federal law. Such information shall be provided by the Operator in an accessible format and shall not include personal data of other data subjects, unless there are lawful grounds for disclosing such data. The scope and procedure for obtaining this information are established by the Personal Data Law;
— Request rectification, restriction, or destruction of their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take lawful measures to protect their rights;
— Require prior consent as a condition for the processing of personal data for the purposes of marketing goods, works, and services;
— Withdraw consent to the processing of personal data and to submit a request for the cessation of such processing;
— File a complaint with the authorized body for the protection of data subjects’ rights or seek judicial remedies against unlawful actions or inaction by the Operator in processing their personal data;
— Exercise any other rights provided for by the legislation of the Russian Federation.
4.3. Individuals who provide the Operator with inaccurate information about themselves or submit personal data of another data subject without that person’s consent shall be held liable in accordance with the legislation of the Russian Federation.
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing that is incompatible with the purposes for which personal data was collected is not permitted.
5.3. Databases containing personal data processed for incompatible purposes shall not be merged.
5.4. Only personal data that meets the purposes of its processing shall be subject to processing.
5.5. The content and scope of personal data processed shall be consistent with the stated purposes of processing. Excessive personal data relative to the stated purposes shall not be processed.
5.6. The accuracy, sufficiency, and — where necessary — relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take reasonable steps to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than is required by the purposes of processing, unless the retention period is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. Personal data shall be destroyed or anonymized once the purposes of processing have been achieved or once there is no longer a need to achieve those purposes, unless otherwise provided for by federal law.
| Purpose of processing | Informing users via email communications |
| Personal data processed | Full name; email address; phone number(s); date and place of birth (year, month, day) |
| Legal basis | Federal Law No. 152-FZ dated July 27, 2006, «On Personal Data» |
| Types of processing | Collection, recording, organization, accumulation, storage, destruction, and anonymization of personal data; sending informational emails |
7.1. Personal data is processed with the data subject’s consent.
7.2. Processing of personal data is necessary to fulfill the purposes established by international treaties of the Russian Federation or by law, as well as to carry out 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 the administration of justice, the execution of a judicial act, or an act of another authority or official subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the data subject’s initiative or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the legitimate rights and interests of the Operator or third parties, or to achieve socially significant goals, provided that this does not infringe upon the rights and freedoms of the data subject.
7.6. Personal data that has been made publicly available by the data subject or at the data subject’s request (hereinafter referred to as «publicly available personal data») may be processed.
7.7. Personal data that is subject to publication or mandatory disclosure under federal law may be processed.
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary for full compliance with the applicable legislation on the protection of personal data.
8.1. The Operator ensures the integrity of personal data and takes all reasonable measures to prevent unauthorized access.
8.2. Users’ personal data will never, under any circumstances, be transferred to third parties, except where required by applicable law or where the data subject has given consent for the Operator to transfer data to a third party for the performance of obligations under a civil-law agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data by sending a notification to the Operator at email@smmgolik.com with the subject line «Personal Data Update.»
8.4. The retention period for personal data is determined by the fulfillment of the purposes for which the data was collected, unless otherwise specified by a contract or applicable law. The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator at email@smmgolik.com with the subject line «Withdrawal of Consent to Personal Data Processing.»
8.5. All information collected by third-party services — including payment systems, communication tools, and other service providers — is stored and processed by such parties (Operators) in accordance with their respective Terms of Use and Privacy Policies. The data subject is encouraged to review such documents. The Operator bears no responsibility for the actions of third parties, including the service providers referenced in this section.
8.6. Any restrictions on transfer (other than access), processing, or processing conditions (other than access) imposed by the data subject with respect to data authorized for distribution shall not apply where personal data is processed in the state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator shall maintain the confidentiality of personal data throughout processing.
8.8. The Operator shall store personal data in a form that allows identification of the data subject for no longer than is required by the purposes of processing, unless the retention period is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Personal data processing may be terminated upon the achievement of processing purposes, the expiration of the data subject’s consent, the withdrawal of consent by the data subject, a request to cease processing, or the identification of unlawful processing.
9.1. The Operator performs the following operations with personal data: collection, recording, organization, accumulation, storage, modification (updating, amendment), retrieval, use, transfer (distribution, provision, access), anonymization, restriction, deletion, and destruction.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of information via information and telecommunications networks.
10.1. Prior to initiating any cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of data subjects’ rights of its intention to carry out such transfer (this notification is submitted separately from the notification of the intent to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain the relevant information from the foreign government authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
The Operator and any other persons who have gained access to personal data are required not to disclose to third parties or distribute personal data without the consent of the data subject, unless otherwise provided for by federal law.
12.1. Users may obtain clarification on any matters related to the processing of their personal data by contacting the Operator at email@smmgolik.com.
12.2. This document shall reflect any changes to the Operator’s personal data processing policy. This Policy shall remain in effect indefinitely until replaced by a new version.
12.3. The current version of this Policy is publicly available online at https://smmgolik.com/en/polozhenie-ob-obrabotke-personalnyh-dannyh/
