Privacy policy

privacy policy

Personal data processing policy

1. General provisions. This personal data processing policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006, On Personal Data (the Personal Data Law). It defines the processing procedure and security measures applied by OOO SOVREMENNYE RESHENIYA, INN 9725192190, KPP 772501001 (the Operator).

1.1. Respecting individuals’ rights and freedoms when processing their personal data, including privacy and personal and family confidentiality, is a primary objective and condition of the Operator’s activities.

1.2. This policy (the Policy) applies to all information the Operator may obtain about visitors to https://white-studio.pro.

2. Definitions used in this Policy

2.1. Automated processing: processing personal data using computing equipment.

2.2. Blocking: temporarily suspending processing, except where processing is necessary to correct personal data.

2.3. Website: graphic and information materials, computer programs and databases made accessible on the internet at the address https://white-studio.pro.

2.4. Personal data information system: personal data held in databases together with the technology and equipment used to process it.

2.5. Anonymisation: actions preventing personal data from being attributed to a particular User or other data subject without additional information.

2.6. Processing: any operation or set of operations on personal data, automated or otherwise, including collection, recording, organisation, accumulation, storage, clarification (updating or correction), retrieval, use, transfer (dissemination, provision or access), anonymisation, blocking, deletion and destruction.

2.7. Operator: a public or municipal body, legal entity or individual that, alone or jointly, organises or performs processing and determines its purposes, the data involved and the operations performed.

2.8. Personal data: any information relating directly or indirectly to an identified or identifiable User of https://white-studio.pro.

2.9. Data authorised for dissemination: personal data that a data subject makes accessible to an unlimited number of people by consenting to dissemination under the procedure set out in the Personal Data Law.

2.10. User: any visitor to https://white-studio.pro.

2.11. Provision: disclosure of personal data to a particular person or defined group of people.

2.12. Dissemination: disclosure to an undefined group of people or allowing an unlimited number of people to view personal data, including publication in the media, on telecommunications networks or by providing access in any other way.

2.13. Cross-border transfer: transferring personal data to a foreign state’s territory, to its authorities, individuals or legal entities.

2.14. Destruction: irreversible destruction of personal data so that its content cannot be restored in the information system, and/or destruction of physical media holding it.

3. Operator’s principal rights and duties

3.1. The Operator may:

— obtain accurate information and/or documents containing personal data from the data subject;

— continue processing without consent after withdrawal or a request to stop processing where grounds specified by the Personal Data Law exist;

— determine the measures necessary and sufficient to fulfil duties under the Personal Data Law and related regulations, unless otherwise prescribed by that law or other federal laws.

3.2. The Operator must:

— provide the data subject, on request, with information about the processing of their personal data;

— organise processing as required by applicable Russian legislation;

— respond to data subjects and their legal representatives as required by the Personal Data Law;

— provide information requested by the competent data protection authority within 10 days of receiving its request; — publish this Policy or otherwise provide unrestricted access to it;

— take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions;

— stop transfer (dissemination, provision or access) and processing, and destroy personal data in the circumstances and manner specified by the Personal Data Law;

— fulfil other duties imposed by the Personal Data Law.

4. Data subjects’ principal rights and duties

4.1. Data subjects may:

— obtain information about processing, except where federal law provides otherwise. The Operator provides it in an accessible form without other individuals’ personal data unless disclosure has a lawful basis. The Personal Data Law determines the information provided and the procedure for obtaining it;

— require correction, blocking or destruction where data is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose, and take legal measures to protect their rights;

— require prior consent to processing for marketing goods, works or services;

— withdraw consent and request that processing cease;

— challenge unlawful actions or omissions by the Operator before the competent data protection authority or a court;

— exercise other rights provided by Russian legislation. 4.2. Data subjects must: — provide accurate information about themselves;

— notify the Operator of corrections, updates or changes to their personal data.

4.3. Anyone providing inaccurate information about themselves or another person’s data without that person’s consent is liable under Russian legislation.

5. Principles of processing

5.1. Processing is lawful and fair.

5.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes of collection is prohibited.

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

5.4. Only data relevant to the purposes of processing is processed.

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

5.6. Data must be accurate, sufficient and, where necessary, up to date for its purposes. The Operator takes or ensures measures to remove or correct incomplete or inaccurate data.

5.7. Data is kept in an identifiable form no longer than required by the purposes, unless federal law or a contract involving the data subject as a party, beneficiary or guarantor sets a retention period. Data is destroyed or anonymised once its purposes are achieved or it is no longer needed, unless federal law provides otherwise.

6. Purposes of processing. Purpose: providing the User with access to the website’s services, information and/or materials. Personal data: telephone number. Legal basis: Federal Law No. 149-FZ of 27 July 2006, On Information, Information Technologies and Protection of Information. Operations: transfer of personal data.

7. Conditions for processing

7.1. Processing takes place with the data subject’s consent.

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

7.3. Processing is necessary for the administration of justice, enforcement of a court ruling or an act of another body or official that must be enforced under Russian enforcement legislation.

7.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, or to conclude a contract at their initiative or one in which they will be a beneficiary or guarantor.

7.5. Processing is necessary to exercise the Operator’s or third parties’ rights and legitimate interests, or achieve socially significant purposes, provided it does not infringe the data subject’s rights and freedoms.

7.6. Processing concerns data made accessible to an unlimited number of people by the data subject or at their request (publicly accessible personal data).

7.7. Processing concerns data subject to publication or mandatory disclosure under federal law.

8. Collection, storage, transfer and other processing. Security is ensured through legal, organisational and technical measures necessary to comply fully with applicable personal data protection legislation.

8.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorised access.

8.2. User data is not transferred to third parties except where required by applicable law or where the data subject has consented to transfer to a third party for fulfilling contractual obligations.

8.3. Users can correct inaccurate data by emailing info@white-studio.pro with the subject Personal data update.

8.4. Processing ends when the purposes for which the data was collected are achieved, unless a contract or applicable law establishes another period. Users may withdraw consent at any time by emailing info@white-studio.pro with the subject Withdrawal of consent to personal data processing.

8.5. Information collected by third-party services, including payment systems, communications services and other providers, is stored and processed by those entities under their own user agreements and privacy policies. The data subject should consult those documents. The Operator is not responsible for the actions of those third-party providers.

8.6. Restrictions imposed by the data subject on transfer (other than providing access) or processing, and conditions for processing (other than obtaining access), of data authorised for dissemination do not apply to processing in state, social and other public interests defined by Russian legislation.

8.7. The Operator maintains confidentiality when processing personal data.

8.8. Data is kept in a form identifying the data subject no longer than necessary for its purposes, unless federal law or a contract involving the data subject as party, beneficiary or guarantor determines a retention period.

8.9. Processing may cease when its purposes are achieved, consent expires or is withdrawn, the data subject requests cessation, or unlawful processing is identified.

9. Operations performed by the Operator

9.1. The Operator collects, records, organises, accumulates, stores, clarifies (updates or corrects), retrieves, uses, transfers (disseminates, provides or grants access), anonymises, blocks, deletes and destroys personal data.

9.2. Automated processing may involve receiving or transmitting information over information and telecommunications networks, or take place without such networks.

10. Cross-border transfer

10.1. Before beginning cross-border transfers, the Operator must notify the competent authority for protecting data subjects’ rights of its intention. This notice is separate from the notification of intended personal data processing.

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

11. Confidentiality. The Operator and others with access to personal data must not disclose or disseminate it without the data subject’s consent, unless federal law provides otherwise.

12. Final provisions

12.1. Users can request clarification about personal data processing by emailing info@white-studio.pro.

12.2. Changes to this Policy will be reflected in this document. The Policy remains effective until replaced by a new version.

12.3. The current Policy is publicly available at https://white-studio.pro/en/privacy-policy/.