Personal Data Processing Policy

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 referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Elena Mikhailovna Lezhon (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy and personal and family secrecy, to be its most important goal and condition for carrying out its activities.
1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://elenalejeune.com/eng.

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 cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at https://elenalejeune.com/eng.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, 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 who independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of personal data 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 an identified or identifiable User of the website https://elenalejeune.com/eng.
2.9. Personal data permitted by the data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the data subject by giving consent for the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User — any visitor to the website https://elenalejeune.com/eng.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data accessible to an unlimited group of persons, including publication in mass media, placement in information and telecommunications 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 state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of restoring its content in a personal data information system and/or destruction of physical media containing personal data.

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 personal data subject;
— in the event of withdrawal of consent by the personal data subject or submission of a request to terminate personal data processing, continue processing personal data without the subject’s consent 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 provided for by the Personal Data Law and related regulatory legal acts, 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 regarding the processing of their personal data;
— organize personal data processing in accordance with the legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— inform the authorized body for the protection of personal data subjects’ rights upon request within 10 days from the date of receipt of 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, modification, blocking, copying, provision, dissemination, and other unlawful actions;
— terminate transfer (dissemination, provision, access) of personal data, terminate processing, and destroy personal data in cases and in the manner prescribed by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. The information shall be provided in an accessible form and must not contain personal data relating to other subjects, unless there are legal grounds for disclosure;
— demand clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing;
— require prior consent for processing personal data for marketing purposes;
— withdraw consent to personal data processing and demand termination of processing;
— appeal unlawful actions or inaction of the Operator to the authorized body or in court;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of updates or changes to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or about another personal data subject without their consent shall bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of collection is not permitted.
5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of processing shall be processed.
5.5. The content and volume of processed personal data must correspond to the stated purposes. Excessive data processing is not permitted.
5.6. Accuracy, sufficiency, and relevance of personal data shall be ensured. The Operator shall take necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the data subject no longer than required for the purposes of processing, unless a longer retention period is established by federal law or contract. Personal data shall be destroyed or anonymized upon achievement of processing purposes unless otherwise provided by law.

6. Purposes of Personal Data Processing
(Translation can be continued if you provide the next section.)
Purpose of Processing
Informing the User by sending electronic messages.
Personal Data

• Last name, first name, patronymic
• Phone numbers

Legal Grounds
Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection”.
Types of Personal Data Processing
Transfer of personal data.

7. Conditions for Processing Personal Data
7.1. Personal data shall be processed with the consent of the personal data subject.
7.2. Personal data processing is necessary to achieve the objectives предусмотренные an international treaty of the Russian Federation or by law, to perform functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a court act, or an act of another authority or official subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance 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.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data that has been made publicly available by the personal data subject or at their request (public personal data) may be processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.

8. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
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 if the personal data subject has given consent for such transfer to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them by sending a notification to the Operator’s email address: Elena_mosk@list.ru with the subject line “Update of Personal Data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to Elena_mosk@list.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. Any information collected by third-party services, including payment systems and communication providers, is stored and processed by those parties in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of such third parties.
8.6. Restrictions established by the personal data subject on transfer or processing of personal data permitted for distribution shall not apply in cases where personal data is processed in state, public, or other public interests as defined by Russian legislation.
8.7. The Operator ensures confidentiality when processing personal data.
8.8. The Operator stores personal data in a form that allows identification of the subject no longer than required for processing purposes, unless otherwise established by federal law or contract.
8.9. Processing of personal data may be terminated upon achievement of the processing purposes, expiration or withdrawal of consent, request to terminate processing, or detection of unlawful processing.

9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without the transmission of information via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data
10.1. Before carrying out cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intention to carry out such transfer.
10.2. Before submitting such notification, the Operator must obtain relevant information from foreign authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer is planned.

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

12. Final Provisions
12.1. The User may obtain any clarification regarding the processing of personal data by contacting the Operator at Elena_mosk@list.ru.
12.2. Any changes to the personal data processing policy will be reflected in this document. The Policy remains valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available at:
https://elenalejeune.com/policy-eng