Personal data processing policy

1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Limited Liability Company Lavka Project (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for conducting its activities is to ensure the rights and freedoms of individuals during the processing of their personal data, including the protection of the right to privacy, personal, and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website http://dynastyclub.ch.

2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data — processing of personal data using computing means.
2.2. Blocking of Personal Data — temporary cessation of processing personal data (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as software for computers and databases, providing access to them on the internet at the address http://dynastyclub.ch.
2.4. Information System of Personal Data — a collection of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of Personal Data — actions that result in the inability to determine the belonging of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of Personal Data — any action (operation) or set of actions (operations) performed using automation means or without such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, 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 performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal Data — any information relating directly or indirectly to a defined or identifiable User of the website http://dynastyclub.ch.
2.9. Personal Data Allowed for Distribution by the Subject of Personal Data — personal data for which access has been provided to an unlimited circle of individuals by the subject of personal data through consent for the processing of personal data permitted for distribution in accordance with the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website http://dynastyclub.ch.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific individual or specific circle of individuals.
2.12. Distribution of Personal Data — any actions aimed at disclosing personal data to an indefinite circle of individuals (transfer of personal data) or making personal data available to an unlimited circle of individuals, including the publication of personal data in mass media, posting on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-Border Transfer of Personal Data — transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data — any actions that result in personal data being irrevocably destroyed with no possibility of further recovery of the content of personal data in the personal data information system and/or the destruction of physical carriers of personal data.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data accurate information and/or documents containing personal data;
— in case the subject of personal data withdraws consent to the processing of personal data or sends a request to stop processing personal data, the Operator may continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, at their request, with information concerning 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 requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
— inform the authorized body for the protection of the rights of subjects of personal data upon request of this body, providing the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy on personal data processing;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions concerning personal data;
— cease the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data in accordance with the procedure and in cases provided for by the Law on Personal Data;
— fulfill other obligations stipulated by the Law on Personal Data.

4. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data 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 subject of personal data by the Operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Law on Personal Data;
— demand from the Operator the clarification of their personal data, their blocking, or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights;
— impose a condition of prior consent for the processing of personal data for the purposes of promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data and send a request to stop processing personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights stipulated by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of any clarifications (updates, changes) to their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another subject of personal data without the latter's consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of their collection is not allowed.
5.3. It is not permitted to combine databases containing personal data that are processed for incompatible purposes.
5.4. Only personal data that meets the processing purposes shall be processed.
5.5. The content and volume of personal data processed correspond to the declared purposes of processing. Excessive processing of personal data in relation to the declared purposes is not allowed.
5.6. When processing personal data, the accuracy, adequacy, and, when necessary, relevance of personal data concerning the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows for the identification of the subject of personal data for no longer than is necessary to achieve the purposes of processing personal data unless the retention period of personal data is established by federal law, contract, of which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if there is no longer a need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of Processing
Providing access to the User to services, information, and/or materials contained on the website
Personal Data
Surname, first name, patronymic; email address; phone numbers; year, month, day, and place of birth; photographs; citizenship certificate; address of actual residence and registration at the place of residence and/or temporary stay; information about education, profession, specialty, and qualifications, details of educational documents; information about marital status and family composition; information about property status; information about income; information about debts; information about previous positions held and work experience, military service, military registration
Legal Grounds
Performance of a contract with the User, consent to the processing of personal data
Types of Personal Data Processing
Collection, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, destruction

7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data.
7.2. Processing of personal data is carried out without the consent of the subject of personal data in the following cases:
— personal data is processed in accordance with the legislation of the Russian Federation;
— personal data is processed for the performance of a contract, the party of which is the subject of personal data;
— personal data is processed for the purposes of the Operator’s legitimate interests or third parties or for the purposes of personal data processing in accordance with the legislation of the Russian Federation;
— personal data is processed for statistical or other research purposes, provided that the subject of personal data is not identified.

8. Rights of Subjects of Personal Data
8.1. The subject of personal data has the right to request from the Operator:
— clarification of their personal data;
— blocking or destruction of their personal data if they are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing.
8.2. The Operator is obliged to take measures to fulfill the request of the subject of personal data.
8.3. The subject of personal data has the right to withdraw consent to the processing of personal data at any time by sending a corresponding request to the Operator.
8.4. The subject of personal data has the right to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in processing their personal data.

9. Cross-Border Transfer of Personal Data
9.1. The Operator must ensure that the recipient of the personal data in a foreign state provides adequate protection of the rights of subjects of personal data before transferring personal data to the territory of a foreign state.
9.2. Cross-border transfer of personal data is carried out with the consent of the subject of personal data or in cases specified in clauses 2-11 of Part 2 of Article 12 of the Law on Personal Data.

10. Final Provisions
10.1. This Policy is subject to review and approval by the Operator.
10.2. The Operator has the right to make changes and additions to this Policy.
10.3. The Policy comes into effect from the date of its publication on the website http://dynastyclub.ch.