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 of 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 to ensure the security of personal data by Daniil Vladislavovich Shukhman (hereinafter referred to as the “Operator”).
1.1. The Operator’s most important objective 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 the rights to privacy and personal and family secrets.
1.2. This Operator’s Policy regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://shukhman.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data, except where processing is necessary to clarify the personal data.
2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at https://shukhman.com.
2.4. Personal data information system means a collection of personal data contained in databases, as well as information technologies and technical tools used to process such data.
2.5. Depersonalization of personal data means actions that make it impossible to determine, without using additional information, whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data means any action or set of actions performed using automation tools or without using such tools in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision or access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity or individual who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the categories of personal data subject to processing, and the actions or operations performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://shukhman.com.
2.9. Personal data permitted by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been provided by the personal data subject by giving consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for distribution”).
2.10. User means any visitor to the website https://shukhman.com.
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. Distribution of personal data means any actions aimed at disclosing personal data to an unspecified group of persons, including the transfer of personal data or making personal data available to an unlimited number of persons. This includes publishing personal data in the mass media, placing it on information and telecommunications networks, or providing 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 an authority of a foreign state, or to a foreign individual or foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore its content in the personal data information system and/or resulting in the destruction of physical media containing personal data.
3. Main 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 personal data subject’s consent if the personal data subject withdraws consent to the processing of personal data or submits a request to terminate processing, provided that the grounds specified in the Personal Data Law are present;
• independently determine the composition and list of measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and the regulations adopted pursuant to it, 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 request, with information concerning the processing of their personal data;
• organize the processing of personal data in accordance with the procedure established by the applicable laws of the Russian Federation;
• respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the authorized personal data protection authority with the necessary information upon request within 10 days from the date of receipt of such request;
• publish this Policy or otherwise ensure unrestricted access to it;
• take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision or distribution, as well as from other unlawful actions involving personal data;
• stop the transfer, distribution, provision of or access to personal data, terminate its processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
• fulfill other obligations established by the Personal Data Law.

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

• receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information must be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such 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 it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, as well as take other measures provided by law to protect their rights;
• require prior consent for the processing of personal data for the purpose of promoting goods, works or services on the market;
• withdraw consent to the processing of personal data and request the termination of such processing;
• appeal unlawful actions or omissions of the Operator in the processing of their personal data to the authorized personal data protection authority or through the courts;
• 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;
• inform the Operator about 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 Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined and lawful purposes. The processing of personal data incompatible with the purposes for which it was collected is not permitted.
5.3. It is not permitted to combine databases containing personal data 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 volume of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, the Operator shall ensure the accuracy and sufficiency of the personal data and, where necessary, its relevance to the purposes of processing. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. The personal data being processed shall be destroyed or depersonalized once the purposes of processing have been achieved or when it is no longer necessary to achieve those purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing

Purpose of processingPersonal dataLegal groundsTypes of processing
Providing the User with access to services, information and/or materials available on the Website
Surname, first name and patronymic; email address; telephone numbers
The Operator’s charter and constituent documents; agreements concluded between the Operator and the personal data subject
Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
7. Conditions for Processing 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 to perform 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, the enforcement of a court decision or an act of another authority or 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 to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data to which access by an unlimited number of persons has been provided by the personal data subject or at their request may be processed (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedure for Collecting, Storing, Transferring and Otherwise Processing Personal Data
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 personal data protection legislation.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where such transfer is required by 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 are identified in the personal data, the User may update it independently by sending a notification to the Operator’s email address, daniil.shukhman@gmail.com, 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 another period is established 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’s email address, daniil.shukhman@gmail.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 services and other service providers, is stored and processed by those persons or operators in accordance with their User Agreements and Privacy Policies. The personal data subject is responsible for reviewing these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by a personal data subject on the transfer, except for granting access, or on the processing or conditions of processing, except for obtaining access, of personal data permitted for distribution shall not apply where personal data is processed in the public, state or other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of such data.
8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of processing, unless the storage period 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 when the purposes of processing have been achieved, the personal data subject’s consent has expired, the personal data subject has withdrawn their consent or requested the termination of processing, or unlawful processing of personal data has been identified.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies, updates, modifies, retrieves, uses, transfers, distributes, provides access to, depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated processing of personal data, including the receipt and/or transmission of the information obtained through information and telecommunications networks, or without using such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator must notify the authorized personal data protection authority of its intention to carry out such transfer. This notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals or foreign legal entities 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 concerning the processing of their personal data by contacting the Operator via email at daniil.shukhman@gmail.com.
12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available online at https://shukhman.com/privacy.