Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of 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 to ensure the security of personal data undertaken by Anastasia Ivanovna Zhemchugova (hereinafter referred to as the “Operator”).
1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy and personal and family confidentiality, to be its most important objective 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://spaceholders.info.
2. Key Terms Used in the Policy
2.1. Automated personal data processing – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://spaceholders.info.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means used to process them.
2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another personal data subject.
2.6. Personal data processing – 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 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 performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://spaceholders.info.
2.9. Personal data permitted by the personal data subject for distribution – personal data to which access is granted to an unlimited number of persons by the personal data subject by giving consent for processing in accordance with the procedure provided for by the Personal Data Law.
2.10. User – any visitor to the website https://spaceholders.info.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data – actions aimed at disclosing personal data to an indefinite number of persons, including publication in mass media, posting in information and telecommunication networks, or providing access 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 – actions resulting in the irreversible destruction of personal data with no possibility of further restoration of its content in personal data information systems and/or destruction of physical data carriers.
3. 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;
  • continue processing personal data without the consent of the personal data subject in cases provided for by the Personal Data Law after consent has been withdrawn;
  • independently determine the necessary and sufficient measures to ensure compliance with obligations under the Personal Data Law and related regulations, unless otherwise provided by law.
3.2. The Operator is obliged to:
  • provide the personal data subject with information regarding the processing of their personal data upon request;
  • organize personal data processing in accordance with Russian legislation;
  • respond to requests and inquiries from personal data subjects and their representatives;
  • provide necessary information to the authorized personal data protection authority within 30 days of receiving a request;
  • publish or otherwise ensure unrestricted access to this Policy;
  • take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
  • cease processing and destroy personal data in cases provided for by law;
  • fulfill other obligations stipulated by the Personal Data Law.
4. 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 for by law;
  • request clarification, blocking, or destruction of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for processing purposes;
  • require prior consent for processing personal data for marketing purposes;
  • withdraw consent for personal data processing;
  • appeal unlawful actions or inaction of the Operator to an authorized authority or court;
  • exercise other rights provided by Russian law.
4.2. Personal data subjects are obliged to:
  • provide accurate personal data;
  • inform the Operator of updates or changes to their personal data.
4.3. Persons who provide false information about themselves or about another person without consent bear responsibility under Russian law.
5. Personal Data Processed by the Operator
5.1. Full name (last name, first name, patronymic).
5.2. Phone numbers.
5.3. Year, month, date, and place of birth.
5.4. The website also collects anonymized data (including cookies) using analytics services such as Yandex.Metrica and Google Analytics.
5.5. The above data are collectively referred to as “Personal Data.”
5.6. Special categories of personal data (race, nationality, political views, religious or philosophical beliefs, intimate life) are not processed.
5.7.–5.8.4. Processing of personal data permitted for distribution is carried out in strict accordance with Article 10.1 of the Personal Data Law.
6. Principles of Personal Data Processing
Personal data is processed lawfully, fairly, for specific and legitimate purposes, limited to necessary scope, accurate, up-to-date, and stored no longer than required.
7. Purposes of Personal Data Processing
7.1. Informing Users via email.
7.2. Conclusion, execution, and termination of civil-law contracts.
7.3. Sending notifications about products, services, and offers (with opt-out via email: spaceholdersinfo@yahoo.com).
7.4. Improving website quality and content using anonymized analytics data.
8. Legal Grounds for Processing Personal Data
Processing is carried out on the basis of:
  • applicable laws and regulations;
  • constituent documents of the Operator;
  • contracts with personal data subjects;
  • user consent.
9. Conditions for Personal Data Processing
Processing is carried out with consent or where required by law, contract performance, legitimate interests, public interest, or disclosure obligations.
10. Procedure for Collection, Storage, and Processing
The Operator ensures personal data security through legal, organizational, and technical measures. Personal data is not transferred to third parties except as required by law or with consent.
Users may update or withdraw consent by emailing spaceholdersinfo@yahoo.com.
11. Actions Performed with Personal Data
Collection, storage, updating, use, transfer, depersonalization, blocking, deletion, and destruction, including automated processing.
12. Cross-Border Transfer of Personal Data
Cross-border transfer is permitted only to countries providing adequate protection or with written consent of the data subject.
13. Confidentiality
Personal data must not be disclosed without consent unless otherwise provided by law.
14. Final Provisions
14.1. Inquiries may be sent to spaceholdersinfo@yahoo.com.
14.2. The Policy is valid indefinitely until replaced.
14.3. The current version is available at https://steppingstone.world/privacy-eng

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