Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of Russian Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (the "Personal Data Law"), and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by self-employed individual Ivan Dmitrievich Sudakov (the "Operator").

1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, to be the most important goal and condition of its activities.

1.2. This policy of the Operator regarding the processing of personal data (the "Policy") applies to all information the Operator may obtain about visitors to the website https://sudakov-ivan.com.

2. Basic 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 personal data processing (except when processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the internet at the network address https://sudakov-ivan.com.

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 as a result of which it becomes impossible, without additional information, to determine that personal data belongs to a specific User.

2.6. Processing of personal data — any action or set of actions performed, with or without the use of automation tools, with personal data, including collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator — an individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of the processing of personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://sudakov-ivan.com.

2.9. User — any visitor to the website https://sudakov-ivan.com.

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

2.11. Distribution of personal data — actions aimed at disclosing personal data to an indefinite group of persons.

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

2.13. Destruction of personal data — actions as a result of which personal data is irrevocably destroyed.

3. Basic 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 data subject;
continue processing personal data without the subject's consent where grounds specified in the Personal Data Law exist;
independently determine the composition and list of measures necessary to fulfill obligations under the Personal Data Law.

3.2. The Operator is obligated to:

provide the data subject with information regarding the processing of their personal data;
organize the processing of personal data in accordance with the procedure established by applicable Russian law;
respond to inquiries and requests from data subjects;
publish or otherwise ensure unrestricted access to this Policy;
take legal, organizational, and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, or distribution.

4. Basic Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:

receive information regarding the processing of their personal data;
demand clarification, blocking, or destruction of personal data if it is incomplete, outdated, or unlawfully obtained;
withdraw consent to the processing of personal data;
appeal unlawful actions of the Operator to the authorized body or in court.

4.2. Data subjects are obligated to:

provide the Operator with reliable information about themselves;
notify the Operator of any changes to their personal data.

5. Principles of Personal Data Processing

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

5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes.

5.3. It is not permitted to combine databases containing personal data processed for incompatible purposes.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and scope of personal data processed correspond to the stated purposes of processing.

5.6. When processing personal data, its accuracy, sufficiency, and relevance to the purposes of processing are ensured.

5.7. Personal data is stored for no longer than required by the purposes of processing.

6. Purposes of Personal Data Processing

Purpose 1: providing the User with access to services, information, and materials posted on the website, and fulfilling the sale-and-purchase agreement for digital goods.
Personal data: email address, IP address, cookie files, browser data.
Legal basis: agreements concluded between the Operator and the data subject.
Types of processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.

Purpose 2: informing the User about promotions, new products, updates, and materials (marketing emails).
Personal data: email address.
Legal basis: consent of the data subject given during registration or when placing an order on the website.
Types of processing: storage, use, transfer to a mailing service for sending emails.

The User may unsubscribe from marketing emails at any time by clicking the "Unsubscribe" link in any such email, or by sending a request to info@sudakov-ivan.ru. Unsubscribing does not affect the ability to use the website and account area.

7. Conditions for Processing Personal Data

7.1. The processing of personal data is carried out with the consent of the data subject.

7.2. The processing of personal data is necessary for the performance of an agreement to which the data subject is a party.

7.3. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator, provided that the rights and freedoms of the data subject are not violated.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Processing of Personal Data

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 not be transferred to third parties, except in cases related to compliance with applicable law or with the consent of the data subject.

8.3. If inaccuracies in personal data are identified, the User may update it by sending the Operator a notification to info@sudakov-ivan.ru with the subject "Personal data update".

8.4. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification to info@sudakov-ivan.ru with the subject "Withdrawal of consent to personal data processing".

8.5. All information collected by third-party services, including payment systems, is stored and processed by those parties in accordance with their own terms of use and privacy policy. The Operator is not responsible for the actions of third parties.

8.6. The Operator ensures the confidentiality of personal data.

8.7. Processing of personal data may be terminated upon achievement of the processing purposes, withdrawal of consent by the data subject, or detection of unlawful processing.

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

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data, including receiving and/or transferring information over information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before carrying out cross-border transfer of personal data, the Operator is obligated to notify the authorized body for the protection of the rights of personal data subjects.

10.2. The Operator is obligated to ensure that the foreign state to whose territory personal data is to be transferred provides adequate protection of the rights of personal data subjects.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User may obtain any clarifications regarding the processing of personal data by contacting the Operator by email at info@sudakov-ivan.ru.

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

12.3. The current version of the Policy is freely available at https://sudakov-ivan.com/privacy.