Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures taken by Yulia Yuryevna Nerush (hereinafter referred to as the "Operator") to ensure the security of personal data.
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 confidentiality, to be the most important goal and condition of its 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://neuro-interior.tilda.ws/.
2. Basic Terms Used in the Policy2.1.
Automated processing of personal data means the processing of personal data using computer technology.
2.2.
Blocking of personal data means the temporary cessation of the processing of personal data (except where processing is necessary to clarify personal data).
2.3.
Website means a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at: https://neuro-interior.tilda.ws/.
2.4.
Personal data information system means a set of personal data contained in databases and the information technologies and technical means used for their processing.
2.5.
Depersonalization of personal data means actions resulting in the impossibility of determining, without the use of additional information, whether personal data belongs to a specific User or another personal data subject.
2.6.
Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7.
Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8.
Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://neuro-interior.tilda.ws/.
2.9.
Personal data permitted by the personal data subject for dissemination means personal data to which an unlimited number of persons have been granted access by the personal data subject by providing consent to the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10.
User means any visitor to the website https://neuro-interior.tilda.ws/.
2.11.
Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12.
Dissemination of personal data means 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 number of persons, including publication in mass media, placement in information and telecommunication networks, or granting access to personal data by any other means.
2.13.
Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14.
Destruction of personal data means any actions resulting in the irreversible destruction of personal data with no possibility of restoring the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the personal data subject;
• continue processing personal data without the consent of the personal data subject in the event that the subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, provided that there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and the regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject, upon their request, with information regarding the processing of their personal data;
• organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• respond to appeals and requests 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, upon its request, with the necessary information within 10 days from the date of receipt of such request;
• publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
• implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions involving personal data;
• terminate the transfer (dissemination, provision, or access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
• perform other duties stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:

• obtain information regarding the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are legal grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• require the Operator to clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
• require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
• withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
• appeal unlawful actions or omissions of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or in a court of law.

• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate information about themselves;
• notify the Operator of any clarification (update or modification) of their personal data.

4.3.
Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing5.1.
Personal data shall be processed on a lawful and fair basis.
5.2.
The processing of personal data shall be limited to the achievement of specific, predetermined, and legitimate purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3.
The consolidation of databases containing personal data processed for purposes that are incompatible with one another is not permitted.
5.4.
Only personal data that corresponds to the purposes of its processing shall be processed.
5.5.
The content and scope of the processed personal data shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of processing is not permitted.
5.6.
When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of 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 the identification of the personal data subject for no longer than is required by the purposes of processing, unless the retention period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or in the event that the need to achieve such purposes no longer exists, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
Informing the User by sending electronic communications (e-mails).
Personal data processed:

• full name (surname, first name, and patronymic);
• e-mail address;
• telephone numbers.

Legal basis:

• Federal Law No. 149-FZ dated July 27, 2006, "On Information, Information Technologies and Information Protection."

Types of personal data processing:

• sending informational e-mails to the User's e-mail address.

7. Conditions for the Processing of Personal Data
7.1.
Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2.
The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and for the performance of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3.
The processing of personal data is necessary for the administration of justice and for the execution of a judicial act, an act of another authority, or an official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4.
The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into 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 legitimate interests of the Operator or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6.
Personal data made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data) may be processed.
7.7.
Personal data subject to publication or mandatory disclosure in accordance with federal law may be 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 applicable legislation in the field of personal data protection.
8.1.
The Operator shall ensure the security of personal data and take all possible measures to prevent unauthorized persons from gaining access to personal data.
8.2.
The User's personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the personal data subject has given the Operator consent to transfer the 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 independently by sending a notification to the Operator via e-mail at y.nerush@yandex.ru with the subject line "Personal Data Update".
8.4.
The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by an agreement 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 via e-mail at y.nerush@yandex.ru 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 services, and other service providers, is stored and processed by such persons (Operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject is responsible for reviewing the aforementioned documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6.
Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, shall not apply in cases where personal data is processed in state, public, or other public interests as 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 required by the purposes of processing, unless the retention period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9.
The processing of personal data may be terminated upon the achievement of the purposes of processing, the expiration of the consent period of the personal data subject, the withdrawal of consent by the personal data subject, the submission of a request to terminate the processing of personal data, or the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data9.1.
The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating and modification), retrieval, use, transfer (dissemination, provision, and access)…
...provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2.
The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without the use of such networks.
10. Cross-Border Transfer of Personal Data10.1.
Prior to commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized body responsible for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (such notification shall be submitted separately from the notification of the intention to process personal data).
10.2.
Before submitting the aforementioned notification, the Operator shall obtain the relevant information from the authorities of a foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is intended.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions12.1.
The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator via e-mail at: y.nerush@yandex.ru.
12.2.
Any changes to the Operator's Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.
12.3.
The current version of the Policy is publicly available on the Internet at: https://neuro-interior.tilda.ws/policy.