Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Peter Frost LLC, INN 4703125811, OGRN 1124703000212, legal address: 3e Gogolya St., Vsevolozhsk, Vsevolozhsky District, Leningrad Region, 188643 (hereinafter — the Operator).

1.1. The Operator's primary goal and condition for carrying out its activities is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.

1.2. This Operator's Policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://peterfrost.eng.tilda.ws.

1.3. A notice regarding the processing of personal data has been submitted by the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) in accordance with the procedure stipulated by Article 22 of the Personal Data Law.

2. Basic Concepts 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 cessation of processing of personal data (except where processing is necessary to clarify personal data).

2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://peterfrost.eng.tilda.ws.

2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data to a specific User or other personal data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation means or without using such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, 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, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, 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://peterfrost.eng.tilda.ws. For the purposes of this Policy, personal data also includes IP address, cookies, browser and operating system data, information about the User's actions on the Site collected using web analytics services, if such information allows the identification of the User.

2.9. Personal data permitted for dissemination by the personal data subject — personal data to which the personal data subject has granted access to an unlimited circle of persons by giving consent to the processing of personal data permitted for dissemination by the personal data subject in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data permitted for dissemination).

2.10. User — any visitor to the website https://peterfrost.eng.tilda.ws.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including publishing personal data in the mass media, posting in information and telecommunication 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, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data, as well as upon receiving a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if 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 duties stipulated by the Personal Data Law and regulatory legal acts adopted in accordance therewith, 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 his/her request, with information relating to the processing of his/her personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation 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;
— notify the authorized body for the protection of the rights of personal data subjects, at its request, of the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful 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 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 Subjects

4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is 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, except 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;
— require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary 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 when processing personal data for the purpose of marketing goods, works, and services;
— withdraw consent to the processing of personal data, as well as submit a request to cease processing of personal data;
— appeal against the unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator of the clarification (updating, change) of their personal data.

4.3. Persons who have provided the Operator with false 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. Processing of personal data is carried out on a lawful and fair basis.

5.2. Processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows the identification of the personal data subject, no longer than required by the purposes of processing personal data, unless the storage period for 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 are destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided for by federal law.

6. Purposes of Personal Data Processing


Types of personal data processing: collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (provision, access), depersonalization, blocking, deletion, destruction.

7. Conditions for Processing Personal Data

7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

7.2. 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 carry out the functions, powers, and duties assigned by the legislation of the Russian Federation to the Operator.

7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with 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 personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.

7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing of personal data to which access by an unlimited circle of persons is provided by the personal data subject or at their request (hereinafter — publicly available personal data) is carried out.

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured by implementing 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 ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. Transfer of the User's personal data to third parties is permitted only in cases provided for by current legislation of the Russian Federation, or with the prior consent of the personal data subject to such transfer, including for the purpose of fulfilling obligations under a civil law contract.

8.2.1. The Operator has the right to entrust the processing of personal data to third parties (hosting providers, email services, payment systems, delivery services, etc.) only on the basis of a processing agreement, which must contain requirements regarding confidentiality, security, and compliance of processing with the purposes provided for in this Policy. The Operator is liable for the actions of such persons within the limits established by Article 6 of the Personal Data Law.

8.2.2. Categories of third parties who may be entrusted with the processing of personal data:

Hosting provider (ensuring the operation of the Site);

Email service (sending messages to Users);

Other persons

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator's email address info@peter-frost.ru marked "Updating of personal data."

8.4. Terms of processing and storage of personal data:

The User's personal data is processed without a time limit, by any lawful means, including in personal data information systems using automation means or without using such means.

In the event of withdrawal of consent, processing is terminated, and personal data is destroyed within 30 days from the date of receipt of the withdrawal, unless otherwise provided by law or contract.

The User may at any time withdraw their consent to the processing of personal data by sending a notice to the Operator via email at info@peter-frost.ru marked "Withdrawal of consent to the processing of personal data."

8.5. Regarding web analytics services and cookies:
The User may restrict or prohibit the processing of cookies and the collection of data about actions on the Site through their browser settings. Continued use of the Site after the display of the cookie notice means the User's consent to the processing of relevant data for the purposes specified in Section 6 of this Policy.

8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing of personal data in state, public, and other public interests determined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows the identification of the personal data subject, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Grounds for termination of personal data processing may include achievement of the purposes of processing personal data, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject or a request to cease processing of personal data, as well as detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Obtained Personal Data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the received information via information and telecommunication networks.

10. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

11. Final Provisions

11.1. The User may obtain any clarification regarding issues of interest related to the processing of their personal data by contacting the Operator via email at info@peter-frost.ru.

11.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.

11.3. The current version of the Policy is freely available on the Internet at https://peterfrost.eng.tilda.ws/privacypolicy.