Personal Data Processing Policy

This is an English translation of the Russian-language policy published at realeasystudio.site/policy. In case of any discrepancy, the Russian version prevails.

1. General provisions

This personal data processing policy has been prepared in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (the “Personal Data Law”) and sets out the procedure for processing personal data and the measures to ensure its security taken by Individual Entrepreneur Anton Robertovich Bordakovskii, TIN 771877824703 (the “Operator”). Easy Studio and its advertising division Easy Agency operate under this entity.

1.1. The Operator’s most important goal and condition of its activity is the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and to personal and family secrets.

1.2. This Policy applies to all information that the Operator may receive about visitors to the websites https://realeasystudio.site and https://изистудия.рф.

2. Key terms

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data — temporary suspension of processing (except where processing is needed to clarify the data).

2.3. Website — the set of graphic and information materials, software and databases available on the internet at https://realeasystudio.site and изистудия.рф.

2.4. Personal data information system — the personal data contained in databases together with the information technologies and technical means that process it.

2.5. Depersonalization of personal data — actions after which it is impossible, without additional information, to determine which User or other data subject the data belongs to.

2.6. Processing of personal data — any action or set of actions performed with personal data, with or without automation, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.

2.7. Operator — a state or municipal body, legal entity or individual that, alone or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of processing, the composition of the data and the actions performed with it.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://realeasystudio.site.

2.9. Personal data permitted for distribution — personal data to which the data subject has granted access to an unlimited number of persons by giving consent in the manner provided by the Personal Data Law.

2.10. User — any visitor to the websites https://realeasystudio.site and https://изистудия.рф.

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

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons, including publication in the media, posting on information and telecommunication networks or providing access 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 authority, foreign individual or foreign legal entity.

2.14. Destruction of personal data — any actions that irreversibly destroy personal data, making it impossible to restore its content in the information system, and/or destroy the physical media containing it.

3. Rights and obligations of the Operator

3.1. The Operator has the right to:

receive accurate information and/or documents containing personal data from the data subject;
continue processing personal data without the data subject’s consent where the Personal Data Law provides grounds for it, even if the data subject withdraws consent or requests that processing stop;
independently determine the measures necessary and sufficient to fulfil the obligations provided by the Personal Data Law and the regulations adopted under it, unless otherwise provided by law.

3.2. The Operator is obliged to:

provide the data subject, on request, with information about the processing of their personal data;
organize the processing of personal data in the manner established by the legislation of the Russian Federation;
respond to requests and inquiries from data subjects and their legal representatives in accordance with the Personal Data Law;
provide the authorized data protection authority with the necessary information within 10 days of receiving its request;
publish or otherwise ensure unrestricted access to this Policy;
take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution and other unlawful actions;
stop the transfer of personal data, stop processing and destroy personal data in the cases and manner provided by the Personal Data Law;
perform other duties provided by the Personal Data Law.

4. Rights and obligations of data subjects

4.1. Data subjects have the right to:

receive information about the processing of their personal data, except in cases provided by federal law. The information is provided in an accessible form and must not contain personal data of other data subjects unless there are legal grounds for disclosing it;
require the Operator to clarify, block or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose, 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;
withdraw consent to the processing of personal data and request that processing stop;
appeal against unlawful actions or inaction of the Operator to the authorized data protection authority or in court;
exercise other rights provided by the legislation of the Russian Federation.

4.2. Data subjects are obliged to provide the Operator with accurate information about themselves and to inform the Operator of any changes to their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or with information about another data subject without that person’s consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data is processed lawfully and fairly.

5.2. Processing is limited to achieving specific, predetermined and legitimate purposes. Processing incompatible with the purposes of collection is not permitted.

5.3. Databases containing personal data processed for incompatible purposes are not combined.

5.4. Only personal data that meets the purposes of processing is processed.

5.5. The content and volume of processed personal data correspond to the stated purposes. Excessive processing is not permitted.

5.6. The Operator ensures the accuracy and sufficiency of personal data and, where necessary, its relevance to the purposes of processing, and takes measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows the data subject to be identified no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized once the purposes of processing have been achieved or are no longer needed, unless otherwise provided by federal law.

6. Purposes of processing

Purpose: Informing the User by sending emails
Personal data: Surname, first name, patronymic; email address; phone numbers
Legal grounds: The Operator’s constituent documents
Types of processing: Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

7. Conditions of processing

7.1. Personal data is processed with the consent of the data subject.

7.2. Processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the Operator by Russian law.

7.3. Processing is necessary for the administration of justice or the execution of a judicial act or an act of another body or official subject to enforcement under Russian law on enforcement proceedings.

7.4. Processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, or for concluding a contract at the data subject’s initiative.

7.5. Processing 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 data subject are not violated.

7.6. Personal data made publicly accessible by the data subject or at their request is processed.

7.7. Personal data subject to publication or mandatory disclosure under federal law is processed.

8. Collection, storage, transfer and other processing

The security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with the applicable data protection legislation.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except as required by applicable law or where the data subject has consented to the transfer to a third party for the performance of obligations under a civil law contract.

8.3. If the User finds inaccuracies in their personal data, they may update it by sending a notice to the Operator at a.b.robertovich@gmail.com with the subject “Updating personal data”.

8.4. The processing period is determined by the achievement of the purposes for which the data was collected, unless another period is provided by contract or applicable law. The User may withdraw consent to processing at any time by sending a notice to a.b.robertovich@gmail.com with the subject “Withdrawal of consent to personal data processing”.

8.5. Information collected by third-party services, including payment systems and communication providers, is stored and processed by those parties in accordance with their own user agreements and privacy policies. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.6. Prohibitions set by the data subject on the transfer or processing of personal data permitted for distribution do not apply where personal data is processed in state, public and other public interests defined by Russian law.

8.7. The Operator ensures the confidentiality of personal data.

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

8.9. Processing may be terminated upon achievement of its purposes, expiry of the data subject’s consent, withdrawal of consent or a request to stop processing, or upon discovery of unlawful processing.

9. Actions performed with personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information over information and telecommunication networks.

10. Cross-border transfer of personal data

10.1. Before carrying out cross-border transfer of personal data, the Operator must notify the authorized data protection authority of its intention to do so (separately from the notification of its intention to process personal data).

10.2. Before submitting such a notification, the Operator must obtain the relevant information from the foreign authorities, foreign individuals or foreign legal entities to which the cross-border transfer is planned.

11. Confidentiality of personal data

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

12. Final provisions

12.1. The User can obtain any clarification on the processing of their personal data by contacting the Operator at a.b.robertovich@gmail.com.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of this translation is available at https://realeasystudio.site/privacy-policy; the current Russian version is available at https://realeasystudio.site/policy.