PRIVACY POLICY AND PERSONAL DATA PROCESSING
GENERAL PROVISIONS, PARTIES AND PURPOSE OF THE DOCUMENTThis Privacy Policy and Personal Data Processing Policy (the “Policy”) sets out the procedure and terms for the processing by Individual Entrepreneur Sofia Sanislavovna Persiyaninova, acting under the laws of the Russian Federation (the “Operator” or “We”), of information about an individual that may be obtained by the Operator from that individual or their legal representative (the “User”, “Data Subject” or “You”) in connection with the following relationships with the Data Subject:
· use of the functions of the website https://jazztechnique.com, including all its domains, subdomains and pages, their content, as well as Internet services and software offered by the Operator for use on the website (collectively, the “Website”);
· the Operator’s exercise of rights and performance of obligations under agreements/contracts entered into between the Operator and the User;
· the handling of requests, complaints, inquiries and messages sent by the Operator and the User to each other.
The purpose of this Policy is to ensure an appropriate legal framework for personal data. The Policy may not contain provisions that restrict the rights and freedoms of a personal data subject, establish cases of processing personal data of minors unless otherwise provided by the laws of the Russian Federation, or permit the data subject’s inaction to serve as a condition for entering into a contract or expressing consent.
LEGAL BASIS FOR PERSONAL DATA PROCESSINGThe legal grounds for processing personal data are:
· consent to the processing of personal data, expressed in the manner prescribed by law and this Policy;
· agreements entered into between the Operator and the User;
· the Operator’s internal regulations governing personal data.
The Data Subject decides whether to provide their personal data and gives consent to its processing freely, of their own will and in their own interests. The Data Subject’s inaction may not be construed as consent. Consent to personal data processing must be specific, informed, conscious and unambiguous. The Data Subject may express consent to this Policy by taking either of the following actions:
· entering into an agreement with the Operator, such as a public offer agreement, provided that the User is given an opportunity to review the full text of this Policy at each point where personal data is collected; or
· checking a box (in an input field) on the Website next to wording such as: “I consent to the processing of personal data in accordance with the Privacy Policy”, provided that the User is given an opportunity to review the full text of this Policy at each point where personal data is collected.
RULES FOR PROCESSING PERSONAL DATAFor each purpose of processing, this Policy specifies the purpose, categories and list of personal data processed, categories of data subjects whose personal data are processed, methods and periods of processing and storage, and the procedure for destruction of personal data upon achievement of the processing purposes or upon the occurrence of other lawful grounds.
Purpose: Authentication of the Data Subject for entering into and performing a contract.
Categories and list of personal data processed: surname, first name, telephone number and email address.
Categories of data subjects whose personal data are processed: Data Subjects who are Users of the Website.
Processing methods: collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, anonymisation, transfer (access and provision), blocking, deletion and destruction of personal data.
Processing and storage period: until the Data Subject submits a request to cease processing/withdraws consent, or for three (3) years.
Destruction procedure upon achievement of the processing purpose or occurrence of other lawful grounds: the person responsible for personal data processing shall erase the data by overwriting (replacing all information storage units with “0”) and draw up an act of destruction of personal data.
Purpose: Communication with the User and sending the User messages, notifications, requests, responses, documents, and advertising or informational messages.
Categories and list of personal data processed: first name, surname, telephone number and email address.
Categories of data subjects whose personal data are processed: Data Subjects who are Users of the Website.
Processing methods: collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, anonymisation, blocking, deletion and destruction of personal data.
Processing and storage period: until the Data Subject submits a request to cease processing/withdraws consent, or for three (3) years.
Destruction procedure upon achievement of the processing purpose or occurrence of other lawful grounds: the person responsible for personal data processing shall erase the data by overwriting (replacing all information storage units with “0”) and draw up an act of destruction of personal data.
Purpose: Handling requests, complaints, inquiries and messages sent by the Operator and the User to each other.
Categories and list of personal data processed: surname, first name, telephone number, email address and the text of the message (if the message contains personal data).
Categories of data subjects whose personal data are processed: Data Subjects who are Users of the Website.
Processing methods: collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, anonymisation, transfer (access and provision), blocking, deletion and destruction of personal data.
Processing and storage period: until the Data Subject submits a request to cease processing/withdraws consent, or for three (3) years.
Destruction procedure upon achievement of the processing purpose or occurrence of other lawful grounds: the person responsible for personal data processing shall erase the data by overwriting (replacing all information storage units with “0”) and draw up an act of destruction of personal data.
Purpose: Enabling the User to post reviews of the Operator’s services.
Categories and list of personal data processed: surname, first name, text of the message (if it contains personal data), details of the User’s social media accounts, and information depicting the User: photographs, video recordings and other technical recordings of the person’s appearance and body.
Categories of data subjects whose personal data are processed: Data Subjects who are Users of the Website.
Processing methods: collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, anonymisation, transfer (access and provision), blocking, deletion and destruction of personal data.
Processing and storage period: until the Data Subject submits a request to cease processing/withdraws consent, or for three (3) years.
Destruction procedure upon achievement of the processing purpose or occurrence of other lawful grounds: the person responsible for personal data processing shall erase the data by overwriting (replacing all information storage units with “0”) and draw up an act of destruction of personal data.
Personal data processing shall be limited to the achievement of these specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of processing is not permitted.
COOKIE TECHNOLOGY· A cookie is a fragment of data sent by the Operator’s server and stored on the Data Subject’s device. The contents of such a file may or may not constitute personal data, depending on whether the file contains personal data or anonymised technical data.
· The Data Subject may prohibit their equipment from receiving such data or restrict their receipt. If the Data Subject refuses to receive such data or restricts their receipt, certain Website functions may not work properly. The Data Subject is responsible for configuring their equipment to ensure a mode of operation and level of cookie data protection appropriate to their preferences. The Operator does not provide technical or legal advice on these matters.
PROCEDURE AND TERMS FOR PROCESSING PERSONAL DATA· “Personal data processing” means any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (provision and access), anonymisation, blocking, deletion and destruction of personal data. This Policy establishes, for each processing purpose, the purposes of processing, categories and list of personal data processed, categories of data subjects whose personal data are processed, methods and periods of processing and storage, and the procedure for destruction of personal data upon achievement of the processing purposes or upon the occurrence of other lawful grounds.
· The Operator may process data using the above methods (operations) both in personal data information systems and without the use of automation tools.
· The Operator shall process personal data for as long as necessary to achieve the specific processing purpose.
· If the Data Subject withdraws consent to personal data processing, consent expires, or the Data Subject submits a request to cease processing, the Operator may block the data and retain and process it in archived form for three (3) years.
MEASURES TO PROTECT PERSONAL DATA· The Operator takes all necessary measures to protect personal data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access, as well as other unlawful forms of processing.
· By default, personal information is processed by automated equipment without access by any person. If access becomes necessary, the Operator shall grant access to personal data only to persons who need the information to achieve the processing purpose. To protect and ensure the confidentiality of the data, such persons must undertake to comply with internal legal rules and procedures, and technical and organisational security measures governing the processing of personal information.
· Adequate security of the location where personal data are processed shall be ensured both when processing personal data without automation tools and when processing them by automated means.
· Personal data may be disclosed only in accordance with the applicable laws of the Russian Federation, at the request of a court or law enforcement authorities, or in other cases provided for by the laws of the Russian Federation.
· The Operator does not verify the accuracy of the information provided by the Data Subject and proceeds on the assumption that, in accordance with the principle of good faith and the requirements of Article 19 of the Civil Code of the Russian Federation, the Data Subject provides accurate and sufficient information, ensures that changes to previously provided information are made in a timely manner, and keeps the information up to date.
TRANSFER OF PERSONAL DATA TO THIRD PARTIES AND DISCLOSURE OF PERSONAL DATAThe Operator may transfer (by granting access to or providing) personal data to the following third parties:
· persons to whom rights or obligations have been assigned/transferred, or in respect of whom a novation has been effected under the relevant agreement (for example, in the event of succession, sale or other disposal of the business as a whole or in part);
· any regulatory authority, law enforcement agency, central or local government authority, other official or governmental body, or court to which the Operator is required to provide information upon request under applicable law;
· persons providing legal protection to the Operator or third parties in the event of an infringement or threatened infringement of their rights, including violations of laws or regulatory documents;
· where the Data Subject has consented to the transfer of personal data to a third party, or where the transfer is necessary to perform an agreement or contract entered into with the Data Subject. This includes cases where the User has permitted their equipment to receive, transmit and store cookie files, if such files contain personal data.
The Operator may disclose (disseminate to an unlimited number of persons) personal data where the User has independently authorised the unrestricted dissemination of the relevant categories of personal data.
RIGHTS AND OBLIGATIONS REGARDING PERSONAL DATA· The Data Subject must ensure that the information provided is accurate, that changes are made in a timely manner, and that the information is kept up to date. Otherwise, the Operator shall not be liable for failure to perform its obligations or for any damages, harm or losses.
· To exercise the right to supplement, correct, block or delete personal data, the Data Subject may send a written request to the Operator’s email address specified in this Policy.
The Data Subject has the following principal rights:
· to request information about the processing of their personal data;
· to withdraw consent to personal data processing;
· to request restrictions on the processing of personal data;
· to request that personal data processing be ceased, where provided for by applicable law and this Policy.
In cases provided for by applicable law, the Data Subject shall have other rights in addition to those listed above.
The Data Subject shall use the contact details set out in this Policy to submit requests to exercise their personal data rights or complaints concerning inaccurate information or unlawful processing. Such requests and complaints shall be reviewed within no more than ten (10) business days from the date they are received by the Operator.
The Data Subject may withdraw consent to personal data processing at any time. To do so, the Data Subject shall send the Operator a written notice of withdrawal of consent to the email address specified in the contact details section of this Policy.
STORAGE AND PROCESSING OF PERSONAL DATA OF CITIZENS OF THE RUSSIAN FEDERATION. CROSS-BORDER TRANSFERS· The Operator processes personal data of citizens of the Russian Federation using databases located within the territory of the Russian Federation.
· Before commencing a cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data are to be transferred provides reliable protection of the rights of personal data subjects, and notify the state authority responsible for personal data protection of its intention to carry out a cross-border transfer to foreign states meeting those requirements.
· Before commencing a cross-border transfer of personal data to a foreign state that does not provide reliable protection of the rights of personal data subjects, the Operator must obtain permission from the state authority responsible for personal data protection to carry out such cross-border transfer.
AMENDMENTS TO THE PRIVACY POLICY. APPLICABLE LAW. INTERPRETATION· The Operator may amend this Policy. The updated version shall state the date of the latest revision. The new version of the Policy shall take effect upon publication, unless otherwise provided in that version. Superseded versions shall be available in the archive at the address specified in the Policy.
· The Operator shall inform Data Subjects who have previously consented to this Policy of any amendments. When choosing the form of notification, the Operator shall be guided by the requirement that consent to personal data processing must be specific, informed, conscious and unambiguous.
· The place where consent is expressed and the place of performance of this Policy shall always be the location of the Operator. The laws of Russia shall always govern the relationship between the Operator and the Data Subject, regardless of the location of the Data Subject or the equipment used by them. All disputes and disagreements shall be resolved at the location of the Operator, unless otherwise provided by law.
· This Policy shall govern the relationship between the Data Subject and the Operator from the moment the Data Subject expresses consent to its terms and shall remain in effect indefinitely. The indefinite term of this Policy as a document does not mean that personal data processing is indefinite or is not subject to time limits. Neither Party may unilaterally terminate this Policy at its own discretion.
Rules of interpretation:· The terms “agreement” and “contract” shall be treated as equivalent.
· The words “include”, “includes”, “including”, “for example”, “such as” and similar expressions shall be deemed to be followed by the words “but not limited to”, and shall not restrict the general meaning of the preceding text.
· The words “or” and “either” shall, by default, be understood as introducing a list, equivalent to “and”, unless the context clearly indicates that “or” means a choice between alternatives.
· A word written with an initial capital letter shall have the same meaning as the same word written in lowercase.
OPERATOR’S DETAILSIndividual Entrepreneur Sofia Sanislavovna Persiyaninova
Taxpayer Identification Number (INN): 540449019574
Email: jazztechnique@yandex.ru
Information on exercising Data Subject rights: The Data Subject may exercise all rights available to a personal data subject and obtain clarifications on personal data processing by contacting the Operator at the Operator’s email address.
DOCUMENT INFORMATIONPublication date of this version of the document: 3 October 2026
