Privacy 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 Elena Vladislavovna Bogdanova (hereinafter referred to as the “Operator”).
1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy and personal and family confidentiality, to be its primary objective and a condition for carrying out its activities.
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://ba-studio.ru.

2. Key Terms 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 suspension of the processing of personal data, except where processing is necessary to clarify the personal data.
2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases that ensure their availability on the Internet at https://ba-studio.ru.
2.4. Personal data information system — a set of personal data contained in databases, as well as information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions as a result of which it is impossible to determine, without using additional information, the affiliation of personal data with a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — 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 (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://ba-studio.ru.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which an unlimited number of persons have been granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User — any visitor to the website https://ba-studio.ru.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unspecified number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, making it impossible to further restore the content of the personal data 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 Operator
3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the personal data subject;
• in the event that the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing the 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 obligations established by thePersonal Data Law and regulatory legal acts adopted pursuant thereto, 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 legislation of the Russian Federation;
• respond to requests and inquiries from personal data subjects and their legalrepresentatives in accordance with the requirements of the Personal Data Law;
• provide the authorized body responsible for protecting the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
• publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions involving personal data;
• terminate the transfer (dissemination, 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 obligations provided for by the Personal Data Law.

4. Main 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 shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other personal data subjects, except wherethere are lawful 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, block, or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
• require prior consent to the processing of personal data for the purposesof promoting goods, works, and services on the market;
• withdraw consent to the processing of personal data and submit a requestto terminate the processing of personal data;
• appeal to the authorized body responsible for protecting the rights of personaldata subjects or to a court against unlawful actions or omissions of the Operator in the processing of their personal data;
• 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 of any clarification, updating, or modification of their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about anotherpersonal 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. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data shall not be permitted.
5.3. Databases containing personal data processed for purposes that are incompatible with one another shall not be combined.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing shall not be permitted.
5.6. When processing personal data, their accuracy and sufficiency and, where necessary, their relevance to the purposes of processing shall be ensured. 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 a contract to which the personal data subject is a party, beneficiary, or guarantor. The personal data being processed shall be destroyed or anonymized upon achievement of the purposes of processing or when the need to achieve such purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing
Communication with the User, provision of consultations regarding services, processing of inquiries submitted through the website, and responding to requests.
Personal data

• surname, first name, patronymic;
• email address;
• telephone numbers.

Legal grounds
The User’s consent (given by checking the relevant box before submitting theform) and performance of a contract (or preparation for entering into a contract at the User’s initiative).
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization 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 providedfor by an international treaty of the Russian Federation or by law, and to performthe functions, powers, and duties imposed on the Operator by the legislationof the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or enforcement of an act of another body or officialsubject to execution in accordance with the legislation of the Russian Federationon enforcement proceedings.
7.4. The 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 wellas for entering into a contract at the initiative of the personal data subject or a contract 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 purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data to which an unlimited number of persons have been grantedaccess by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”) are processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law are processed.

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 through the implementation of legal, organizational, and technical measures necessary to fully comply with the applicable legislation on personal data protection.
8.1. The Operator ensures the security of personal data and takes all possiblemeasures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has given the Operator consent to transfer the datato a third party for the purpose of performing obligations under a civil-law contract.
8.3. If inaccuracies are identified in personal data, the User may update themindependently by sending a notification to the Operator’s email address, ba@ba-studio.ru, with the subject line “Personal Data Update.”
8.4. The period of processing personal data is determined by the achievement ofthe purposes for which the personal data were collected, unless another periodis provided for by a contract or applicable legislation.
The User may withdraw their consent to the processing of personal data at any timeby sending a notification by email to the Operator’s email address, ba@ba-studio.ru, with the subject line “Withdrawal of Consent to the Processing of Personal Data.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processedby the relevant persons (Operators) in accordance with their respective User Agreements and Privacy Policies. The personal data subject is responsible for familiarizing themselves with such documents. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this section.
8.6. Restrictions established by a personal data subject on the transfer (exceptfor granting access), as well as on the processing or conditions of processing (except for granting access) of personal data permitted for dissemination, shallnot apply where personal data are processed in state, public, or other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentialityof personal 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 a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achievement of thepurposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, submission of a request to terminate the processing of personal data, or identification of unlawful processing of personal data.

9. List of Actions Performed by theOperator with the Personal Data Received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies(updates, modifies), extracts, uses, transfers (disseminates, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the information obtained through information andtelecommunications networks or without such networks.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is required to notify the authorized body responsible for protecting the rights of personal data subjects of its intention to carry out such cross-border transfer of personal data. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the aforementioned notification, the Operator is required to obtain relevant information from the authorities of the foreign state, foreign individuals, and 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 required not to disclose such personal data to third parties or disseminate them without theconsent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain any clarification regarding matters related to the processingof their personal data by contacting the Operator via email at ba@ba-studio.ru.
12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in effect indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://ba-studio.ru/privacy_policy.