Privacy Policy
Policy on Personal Data Processing
1. General Provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter — the Personal Data Law), and defines the procedure for personal data processing and measures to ensure personal data security undertaken by Individual Entrepreneur Igor Nikolaevich Medushkin (hereinafter — the Operator).
1.1. The Operator considers observance of human and civil rights and freedoms in the processing of personal data, including protection of privacy and personal and family confidentiality, to be the most important goal and condition of its activity.
1.2. This Operator’s policy on personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://pay.gosmallsteps.com/.
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 cessation of personal data processing (except where processing is required to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://pay.gosmallsteps.com/.
2.4. Personal data information system — a set of personal data contained in databases, and information technologies and technical means enabling their processing.
2.5. Depersonalization of personal data — actions resulting in impossibility, without additional information, to determine whether personal data belongs to 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 automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual, independently or jointly with others organizing and (or) carrying out personal data processing, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, and 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://pay.gosmallsteps.com/.
2.9. Personal data permitted by the personal data subject for distribution — personal data for which access by an unlimited number of persons is granted by the personal data subject by giving consent to processing of personal data permitted for distribution in the manner provided by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://pay.gosmallsteps.com/.
2.11. Provision of personal data — actions aimed at disclosure of personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosure of personal data to an indefinite group of persons (transfer of personal data) or familiarization of an unlimited number of persons with personal data, including publication in mass media, placement in information and telecommunication 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 a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed with impossibility of further restoration of the content of personal data in a personal data information system and (or) material media containing personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
– receive from the personal data subject accurate information and (or) documents containing personal data;
– if the personal data subject withdraws consent to personal data processing, 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 and sufficient to ensure fulfillment of obligations provided by the Personal Data Law and legal acts 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 personal data subject, upon request, with information concerning processing of his/her personal data;
– organize personal data processing in accordance with the procedure established by applicable law of the Russian Federation;
– respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– report necessary information to the authorized body for protection of personal data subjects’ rights, upon request of that body, within 30 days from receipt of such request;
– publish or otherwise provide unrestricted access to this Policy on personal data processing;
– take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to personal data;
– cease transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the procedure and cases provided by the Personal Data Law;
– perform other obligations 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 concerning 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 personal data subjects, except where legal grounds for disclosure of such personal data exist. The list of information and 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 is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take legal measures to protect their rights;
– set a condition of prior consent when personal data is processed for promotion of goods, works, and services on the market;
– withdraw consent to personal data processing;
– appeal unlawful actions or inaction of the Operator in personal data processing to the authorized body for protection of personal data subjects’ rights or in court;
– exercise other rights provided by legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
– provide the Operator with accurate information about themselves;
– notify the Operator of clarification (update, change) of their personal data.
4.3. Persons who provided the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, bear liability in accordance with legislation of the Russian Federation.
5. Legal Bases of Personal Data Processing
5.1. The Operator may process the following personal data: surname, first name, patronymic, email address, phone numbers, email.
5.2. The Operator processes the User’s personal data only if filled in and (or) sent by the User independently through special forms located on the website https://pay.gosmallsteps.com/. By filling out the relevant forms and (or) sending personal data to the Operator, the User expresses consent to this Policy.
5.3. The website also collects and processes anonymized visitor data (including “cookie” files) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.4. The above data is further combined in the text of this Policy under the general concept of Personal Data.
5.5. The Operator does not process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, or intimate life.
5.6. Processing of personal data permitted for distribution from among special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed if prohibitions and conditions provided by Article 10.1 of the Personal Data Law are observed.
6. Principles of Personal Data Processing
6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. Personal data processing is limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. Combining databases containing personal data processed for purposes incompatible with each other is not allowed.
6.4. Only personal data that meets the purposes of processing is subject to processing.
6.5. The content and scope of processed personal data correspond to stated processing purposes. Excessiveness of processed personal data in relation to stated processing purposes is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and where necessary relevance of personal data to processing purposes are ensured. The Operator takes necessary measures and (or) ensures they are taken to delete or clarify incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form allowing identification of the personal data subject, no longer than required by personal data processing purposes, unless the storage period is established by federal law, contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achievement of processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. Purposes of processing the User’s personal data:
– informing the User by sending emails;
– providing the User with access to services, information, and (or) materials available on the website https://pay.gosmallsteps.com/.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending a letter to mail@okursah.ru with the subject “Opt-out of notifications about new products and services and special offers”.
7.3. Anonymized User data collected via internet statistics services is used to collect information about User actions on the website and improve website quality and content.
8. Legal Grounds for Personal Data Processing
8.1. Legal grounds for personal data processing by the Operator are:
– Federal Law “On Information, Information Technologies and Information Protection” dated 27.07.2006 No. 149-FZ;
– the Operator’s constituent documents;
– contracts concluded between the operator and personal data subject;
– federal laws and other regulatory legal acts in the field of personal data protection;
– Users’ consents to processing of their personal data and to processing of personal data permitted for distribution.
8.2. The Operator processes the User’s personal data only if filled in and (or) sent by the User independently through special forms located on the website https://pay.gosmallsteps.com/ or sent to the Operator by email. By filling out relevant forms and (or) sending personal data to the Operator, the User expresses consent to this Policy.
8.3. The Operator processes anonymized User data if this is allowed in the User’s browser settings (cookie storage and JavaScript technology enabled).
8.4. The personal data subject independently decides on provision of personal data and gives consent freely, by own will and in own interest.
9. Conditions of Personal Data Processing
9.1. Personal data processing is carried out with consent of the personal data subject.
9.2. Personal data processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or law, and to perform functions, powers, and duties imposed on the operator by legislation of the Russian Federation.
9.3. Personal data processing is necessary for administration of justice, execution of a judicial act, act of another authority, or official subject to execution in accordance with legislation of the Russian Federation on enforcement proceedings.
9.4. Personal data processing is necessary for execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding 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.
9.5. Personal data processing is necessary for exercise of rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided this does not violate rights and freedoms of the personal data subject.
9.6. Processing of personal data is carried out where access by an unlimited number of persons is provided by the personal data subject or at his/her request (hereinafter — publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure under federal law is carried out.
10. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
Security of personal data processed by the Operator is ensured through implementation of legal, organizational, and technical measures necessary to fully comply with requirements of applicable legislation in the field of personal data protection.
10.1. The Operator ensures safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where related to execution of applicable law or where the personal data subject has given consent to transfer data to a third party for performance of obligations under a civil law contract.
10.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator.
10.4. The period of personal data processing is determined by achievement of purposes for which personal data was collected, unless another period is provided by contract or applicable law. The User may at any time withdraw consent to processing of personal data by sending a notice to the Operator by email marked “Withdrawal of consent to personal data processing”.
10.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and (or) User must independently and timely review those documents. The Operator is not responsible for actions of third parties, including service providers specified in this clause.
10.6. Prohibitions set by the personal data subject on transfer (except granting access), as well as on processing or processing conditions (except obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public, and other public interests defined by legislation of the Russian Federation.
10.7. The Operator ensures confidentiality of personal data during processing.
10.8. The Operator stores personal data in a form allowing identification of the personal data subject no longer than required by personal data processing purposes, unless storage period is established by federal law, contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. A condition for termination of personal data processing may be achievement of processing purposes, expiration of personal data subject’s consent, withdrawal of consent by the personal data subject, or detection of unlawful personal data processing.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with receipt and (or) transfer of received information via information and telecommunication networks or without such transfer.
12. Cross-Border Transfer of Personal Data
12.1. Before starting cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory transfer of personal data is planned provides reliable protection of rights of personal data subjects.
12.2. Cross-border transfer of personal data to territories of foreign states that do not meet the above requirements may be carried out only with written consent of the personal data subject to cross-border transfer of personal data and (or) execution of a contract to which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons who gained access to personal data must not disclose or distribute personal data to third parties without consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User may obtain any clarifications on issues of interest concerning processing of personal data by contacting the Operator via email at help@gosmallsteps.com.
14.2. This document will reflect any changes in the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.