Policy on the Processing of Personal Data

1. General Provisions

This policy on the processing of personal data is developed in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures for ensuring the security of personal data taken by Individual Entrepreneur Roman Alexandrovich Shapovalov (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 and citizens in 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. https://gpt-open.ru.

2. Basic Concepts 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 cessation of the processing of 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 and databases, ensuring their availability on the Internet at the network address. https://gpt-open.ru.

2.4. Information system of personal data — a collection of personal data contained in databases and ensuring their processing through information technologies and technical means.

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

2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), 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 who independently or together with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, 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://gpt-open.ru.

2.9. Personal data authorized by the subject of personal data for dissemination — personal data to which access has been granted to an unlimited circle of persons by the subject of personal data through consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data authorized for dissemination").

2.10. User — any visitor to the website. https://gpt-open.ru.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or 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 at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in mass media, placement on information and telecommunication networks, or providing access to personal data 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 resulting in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the information system of personal data and/or destruction of material carriers of personal data.

3. Basic 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 subject of personal data;

— in case the subject of personal data withdraws consent to the processing of personal data, as well as submits a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 obligations established by the Personal Data Law and regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the subject of personal data, at his request, with information regarding the processing of his personal data;

— organize the processing of personal data in accordance with the requirements of 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 Personal Data Law;

— inform the authorized body for the protection of the rights of subjects of personal data at the request of this body of the necessary information within 10 days from the date of receipt of such a request;

— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

— 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 in relation to personal data;

— cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

— perform other duties established by the Personal Data Law.

4. Basic Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right to:

— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data related to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for its obtaining is established by the Personal Data Law;

— demand the Operator to clarify their personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;

— stipulate prior consent when processing personal data for marketing purposes;

— withdraw consent to the processing of personal data and to submit a request to cease 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 provided for 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 clarification (updating, changing) of their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another subject of personal data without the consent of the latter are liable in accordance with the legislation of the Russian Federation.

5. Principles of Processing Personal Data

5.1. Processing of personal data is carried out on a lawful and fair basis.

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

5.3. It is not permitted to combine databases containing personal data, the processing of which is carried out for incompatible purposes.

5.4. Only personal data that meets the purposes of processing shall be subject to processing.

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

5.6. During the processing of personal data, accuracy, sufficiency, and, where necessary, relevance to 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. Storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than is necessary to achieve the purposes of processing personal data, unless the storage 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 reaching the purposes of processing or if the need for achieving these purposes is lost unless otherwise provided by federal law.

6. Purposes of Processing Personal Data

ЦPurpose of processing	Purpose of processing
Personal data	email address
Legal grounds	charter documents of the Operator
Types of processing of personal data	Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data Sending informational letters to the email address

Purpose of processing
Personal data
Legal grounds
Types of processing of personal data

7. Conditions for Processing Personal Data

7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

7.2. Processing of personal data is necessary to achieve the purposes provided for by international treaties of the Russian Federation or laws for the performance of functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, execution of a court order, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the execution of a contract, of which the subject of personal data is a party, or for the conclusion of a contract at the initiative of the subject of personal data or a contract, under which the subject of personal data will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary for the exercise of rights and legitimate interests of the Operator or third parties or to achieve socially significant goals provided that the rights and freedoms of the subject of personal data are not violated.

7.6. Processing is carried out of personal data to which the subject of personal data has granted access to an unlimited circle of persons or at his request (hereinafter referred to as "publicly available personal data").

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

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 comply with the requirements of current legislation on the protection of personal data.

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

8.2. The User’s personal data will never be transferred to third parties under any circumstances, except in cases related to compliance with current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address info@gpt-open.ru with the subject "Updating Personal Data".

8.4. The duration of the processing of personal data is determined by the achievement of the purposes for which the personal data was collected unless another term is provided by the contract or current legislation.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address info@gpt-open.ru with the subject "Withdrawal of Consent to the Processing of Personal Data".

8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the Operator is not responsible for the actions of third parties, including those specified in this paragraph of service providers.

8.6. The prohibitions set by the subject of personal data on the transfer (except for the provision of access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data during processing.

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

8.9. The cessation of processing of personal data may occur upon reaching the purposes of processing personal data, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data, or a request to cease processing personal data, as well as detection of unlawful processing of personal data.

9. List of Actions Taken by the Operator with Received Personal Data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.

10. Cross-Border Transfer of Personal Data

10.1. The Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data before beginning such activity (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator must obtain the corresponding information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom it plans to transfer personal data.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User may obtain any clarifications regarding questions related to the processing of their personal data by contacting the Operator via email. info@gpt-open.ru.

12.2. This document will reflect any changes to the Operator’s policy on processing personal data. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at the address, https://gpt-open.ru/privacy.