Personal Data Processing Policy

1. General provisions

1.1. The Operator’s primary goal and condition of its activities is to respect the rights and freedoms of individuals when processing their personal data, including the right to privacy and family secrecy.

1.2. This Operator’s personal data processing policy (the “Policy”) applies to all information that the Operator may obtain about visitors of the website https://shynkovski.ru.

2. Key terms used in the Policy

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

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

2.3. Website — a set of graphic and information materials, as well as computer programs and databases, making them available on the Internet at https://shynkovski.ru.

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

2.5. Depersonalization of personal data — actions that make it impossible, without additional information, to determine the ownership of personal data by a specific User or other data subject.

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

2.7. Operator — a state authority, municipal authority, 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 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://shynkovski.ru.

2.9. Personal data authorized by the data subject for dissemination — personal data to which an unrestricted circle of persons is granted access by the data subject through consent to processing of personal data authorized for dissemination in the manner provided by the Personal Data Law (hereinafter — personal data authorized for dissemination).

2.10. User — any visitor of the website https://shynkovski.ru.

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 making personal data known to an unrestricted circle of persons, including publication in the media, placement in information and telecommunications networks, or otherwise providing access to personal data.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data — any actions that permanently destroy personal data with no possibility of further recovery of the content of personal data in the personal data information system and/or that destroy the physical media of personal data.

3. Main rights and obligations of the Operator

3.1. The Operator has the right to:

• obtain from the data subject reliable information and/or documents containing personal data;
• if the data subject withdraws consent to processing of personal data, or sends a request to stop processing personal data, continue processing personal data without the data subject’s consent where grounds provided by the Personal Data Law exist;
• independently determine the composition and list of measures necessary and sufficient to fulfill the obligations provided by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. Obligations of the Operator

3.2. The Operator must:

• provide the data subject, upon request, with information relating to the processing of their personal data;
• organize the processing of personal data in the manner established by the applicable laws of the Russian Federation;
• respond to requests of data subjects and their legal representatives in accordance with the Personal Data Law;
• provide the authorized personal data protection authority, upon that authority’s request, with the necessary information within 10 days of receiving 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, alteration, blocking, copying, provision, dissemination of personal data, and from other unlawful actions regarding personal data;
• stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;
• perform other duties provided 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 relating to the processing of their personal data, except in cases provided by federal laws. Information is provided by the Operator in an accessible form and must not contain personal data relating to other 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 not necessary for the stated processing purpose, and take measures provided by law to protect their rights;
• set a condition of prior consent when personal data are processed for the purpose of promoting goods, works and services on the market;
• withdraw consent to personal data processing and send a request to stop processing personal data;
• appeal to the authorized personal data protection authority or in court against unlawful acts or omissions of the Operator when processing their personal data;
• exercise other rights provided by the laws of the Russian Federation.

4.2–4.3. Obligations of subjects

4.2. Personal data subjects must:

• provide the Operator with accurate data about themselves;
• inform the Operator of clarification (updating, changing) of their personal data.

4.3. Liability

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

5. Principles of personal data processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing incompatible with the purposes of personal data collection is not allowed.

5.3. Combining databases containing personal data processed for mutually incompatible purposes 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 processing purposes. Excessiveness of processed personal data relative to the stated purposes is not allowed.

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

5.7. Personal data are stored in a form that allows identification of the data subject for no longer than required by the processing purposes, unless a storage period is established by federal law, a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the processing purposes or if there is no longer a need to achieve those purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

6.1. Processing purpose:

ensuring the operation of the website shynkovski.ru; reviewing incoming User requests and applications (including via forms and communication channels on the Site, as well as via messengers and communication services MAX, Yandex Telemost, VKontakte, Blink and similar services indicated on the Site); consulting on Digital, design, SMM and business-idea review services; organizing feedback with potential clients; concluding, performing and terminating civil-law service contracts (including payment by card / SBP / bank details and sending a receipt); sending promotional and informational messages to the email address where the User has given separate consent; statistical analysis of site traffic where consent to analytics cookies has been given.

6.2. Personal data:

email address; phone numbers; surname, first name, patronymic (if provided by the subject); messenger identifier (nickname) (when contacting via messenger); content of the request; payment amount; payment comment; payment details (date, transaction identifier, payment purpose); IP address; browser and device information; technical cookies and localStorage; interface language; anonymized technical data about site visits (with consent to analytics cookies). Full bank card details are not collected or stored by the Operator.

6.3. Legal grounds:

consent of the data subject; contracts (including acceptance of the public offer on shynkovski.ru) concluded between the operator and the data subject; legitimate interests of the operator (ensuring the operation and security of the site); Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”; Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Protection of Information”; Federal Law No. 422-FZ of 27 November 2018 on the professional income tax experiment (to the extent needed to form and send an NPD receipt for settlements).

6.4. Types of personal data processing:

collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (provision, access) to the acquiring bank Joint Stock Company “TBank” (JSC “TBank”, INN 7710140679) to the extent necessary to process card and/or SBP payment and subsequent receipt formation, blocking, deletion, destruction and depersonalization of personal data.

6.5. Separate purpose — sending informational and promotional materials to the User (where separate consent has been given by ticking the corresponding optional checkbox on the Site; the checkbox is not pre-ticked):

Purpose: sending the User informational and promotional materials, news of the Contractor (Operator), announcements of new projects, services and special offers.

Who sends and where: individual entrepreneur Shynkovski Tomash Victorovich (the Operator) — to the email address specified by the User.

Data composition: email address (e-mail).

Retention period: until the User withdraws consent.

Withdrawal and unsubscribe: the User may at any time withdraw consent to receive promotional and informational emails. Every marketing email contains a prominent “Unsubscribe” link (button) that removes the email from the promotional list in one click; withdrawal is also possible by sending a message to the Operator’s email with the subject “Unsubscribe from mailing”. Payment for Services and the mandatory consents (Offer, personal data processing for contract performance) do not depend on consent to marketing emails.

7. Conditions of personal data processing

7.1. Personal data are processed with the consent of the data subject to the processing of their personal data.

7.2. Personal data processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, to perform functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

7.3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, act of another body or official to be enforced under the enforcement legislation of the Russian Federation.

7.4. Personal data processing is necessary for performance of a contract to which the data subject is a party or beneficiary or guarantor, as well as for concluding a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the data subject.

7.6. Processing of personal data to which an unrestricted circle of persons has been granted access by the data subject or at their request (publicly available personal data) is carried out.

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

8. Procedure for collection, storage, transfer and other 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 meet the requirements of applicable personal data protection legislation.

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

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the data subject has given consent to the Operator to transfer data to a third party to perform obligations under a civil-law contract (including to the acquiring bank for payment processing and receipt generation).

8.2.1. To accept card and SBP payments, the Operator transfers to Joint Stock Company “TBank” (JSC “TBank”, INN 7710140679) information necessary to initiate and process the payment and send a receipt (in particular: amount, payment purpose/description, email for the receipt, technical transaction identifiers). Full bank card details are not accepted or stored by the Operator — payment details are entered on the acquiring bank’s secure pages.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator’s email tomash@shynkovski.ru with the subject “Personal data update”.

8.4. The personal data processing period is determined by achievement of the purposes for which the personal data were collected, unless another period is provided by a contract or applicable law.

The User may at any time withdraw consent to personal data processing by sending a notice by email to the Operator at tomash@shynkovski.ru with the subject “Withdrawal of consent to personal data processing”.

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those persons (operators) in accordance with their user agreements and privacy policies. The Operator recommends that data subjects review those documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions established by the data subject on transfer (other than granting access), as well as on processing or processing conditions (other than obtaining access) of personal data authorized for dissemination, do not apply where personal data are processed in state, public and other public interests defined by the laws 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 identification of the data subject for no longer than required by the processing purposes, unless a storage period is established by federal law, a contract to which the data subject is a party, beneficiary or guarantor.

8.9. Conditions for stopping personal data processing may include achievement of the processing purposes, expiry of the data subject’s consent, withdrawal of consent by the data subject or a request to stop processing personal data, as well as discovery of unlawful personal data processing.

9. List of actions performed by the Operator with obtained personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (provides, grants access) to the extent necessary for the purposes stated in section 6 of this Policy (including to JSC “TBank” as acquiring bank), depersonalizes, blocks, deletes and destroys personal data. The Operator does not publish Users’ personal data in open access and does not disseminate them to an indefinite circle of persons.

9.2. The Operator carries out automated processing of personal data with or without obtaining and/or transmitting the obtained information over information and telecommunications networks.

10. Cross-border transfer of personal data and database location

10.1. The Operator does not carry out cross-border transfer of Users’ personal data from the Site: the site and the database containing personal data of citizens of the Russian Federation are hosted on servers in the Russian Federation; traffic analytics (where consented) uses services that process data in the Russian Federation; interface fonts are served from the Site’s own server.

10.1.1. Hosting provider: Cloud Technologies LLC (Cloud.ru), INN 7736279160; legal address: 123100, Moscow, Presnensky municipal district, 2nd Zvenigorodskaya St., 28. The provider’s infrastructure uses data centres in the Russian Federation (including the Moscow region). Current Site server IP: 194.113.34.135.

10.1.2. Communication channels MAX, Yandex Telemost and VKontakte are services of Russian operators. Contact via other third-party messengers/services (including those listed on the Site) is initiated by the User; the Operator does not initiate cross-border transfer of personal data from the Site. Processing by such services is governed by their own rules.

10.2. If in the future the Operator begins cross-border transfer of personal data, it will, before starting such activity, notify the authorized personal data protection authority in the manner provided by the Personal Data Law and obtain the necessary information from the data recipients.

11. Confidentiality of personal data

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

12. Operator details

12.1. Operator: Individual Entrepreneur Shynkovski Tomash Victorovich.

12.2. INN: 503128601163.

12.3. OGRNIP: 325774600432613.

12.4. Legal address: 109651, Россия, г. Москва, р-н Марьино, ул. Донецкая, д. 13, кв. 268.

12.5. Contact phone: +7 (995) 104-29-54.

12.6. Contact email: tomash@shynkovski.ru.

12.7. Website: https://shynkovski.ru.

13. Final provisions

13.1. The User may obtain any clarifications on matters relating to the processing of their personal data by contacting the Operator by email at tomash@shynkovski.ru.

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

13.3. The current version of the Policy is freely available on the Internet at https://shynkovski.ru/privacy.