Personal Data Processing Policy
1. General ProvisionsThis Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for personal data processing and the measures to ensure the security of personal data undertaken by Romanov Alexey Vladimirovich (hereinafter — the Operator).
1.1. The Operator considers as its most important goal and condition for carrying out its activities compliance with human and civil rights and freedoms when processing personal data, including protection of the right to privacy and personal and family secrecy.
1.2. This Operator’s Personal Data Processing Policy (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://audityacht.com/en/.
2. Key Terms Used in the Policy2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and information materials, as well as software for computers and databases ensuring their availability on the Internet at the network address https://audityacht.com/en/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions resulting in the impossibility of determining, without using additional information, that personal data belong to a specific User or other 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), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out personal data processing, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://audityacht.com/.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which an unlimited number of persons is granted access by the personal data subject by giving consent to processing of personal data permitted by the personal data subject for distribution in accordance with the procedure provided by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://audityacht.com/en/.
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 — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irreversibly with no possibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— in the event the personal data subject withdraws consent to personal data processing and/or sends a request to terminate personal data processing, the Operator may continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and перечень (list) of measures necessary and sufficient to ensure fulfillment of obligations provided by the Personal Data Law and regulatory 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 relating to the processing of their personal data;
— organize personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon its request, with necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
— terminate transfer (distribution, provision, access) of personal data, terminate processing and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:
— receive information relating to the 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 when there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to уточнить (clarify) their personal data, block or destroy them if personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
— put forward a condition of prior consent when processing personal data for the purposes of promoting goods, works and services on the market;
— withdraw consent to personal data processing and also send a request to terminate personal data processing;
— appeal unlawful actions or inaction of the Operator when processing their personal data to the authorized body for the protection of the rights of personal data subjects 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 data about themselves;
— inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data processed for purposes that are incompatible with each other is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or anonymized upon achievement of the purposes of processing or in case the need to achieve these purposes is no longer present, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose of processing
providing the User with access to services, information and/or materials contained on the website.
Personal data
last name, first name, patronymic
phone numbers
Legal grounds
statutory (founding) documents of the Operator
contracts concluded between the Operator and the personal data subject
Types of personal data processing
collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
7. Conditions for Personal Data Processing7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, for the performance of 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 judicial act, an act of another body or official subject to execution in accordance with 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 or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for exercising 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 are processed where access to personal data is provided to an unlimited number of persons by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of 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 access to personal data by unauthorized persons.
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 legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator’s email address mr.denisyacht89@mail.ru with the subject “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which personal data were collected, unless a different period is provided by a contract or applicable legislation.
The User may withdraw their consent to personal data processing at any time by sending the Operator a notice via email to mr.denisyacht89@mail.ru with the subject “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication providers and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject shall independently ознакомится (review) with the said documents. The Operator is not responsible for the actions of third parties, including service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on transfer (except for granting access), as well as on processing or processing conditions (except for access) of personal data permitted for distribution, shall not apply in cases of personal data processing in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Conditions for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the consent period, withdrawal of consent by the personal data subject, a request to terminate personal data processing, as well as detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transmission of the obtained information via information and telecommunication networks or without such networks.
10. Cross-Border Transfer of Personal Data10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is submitted separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned.
11. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email mr.denisyacht89@mail.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at: https://audityacht.com/en/privacy
1.1. The Operator considers as its most important goal and condition for carrying out its activities compliance with human and civil rights and freedoms when processing personal data, including protection of the right to privacy and personal and family secrecy.
1.2. This Operator’s Personal Data Processing Policy (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://audityacht.com/en/.
2. Key Terms Used in the Policy2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and information materials, as well as software for computers and databases ensuring their availability on the Internet at the network address https://audityacht.com/en/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions resulting in the impossibility of determining, without using additional information, that personal data belong to a specific User or other 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), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out personal data processing, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://audityacht.com/.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which an unlimited number of persons is granted access by the personal data subject by giving consent to processing of personal data permitted by the personal data subject for distribution in accordance with the procedure provided by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://audityacht.com/en/.
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 — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irreversibly with no possibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— in the event the personal data subject withdraws consent to personal data processing and/or sends a request to terminate personal data processing, the Operator may continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and перечень (list) of measures necessary and sufficient to ensure fulfillment of obligations provided by the Personal Data Law and regulatory 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 relating to the processing of their personal data;
— organize personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon its request, with necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
— terminate transfer (distribution, provision, access) of personal data, terminate processing and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:
— receive information relating to the 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 when there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to уточнить (clarify) their personal data, block or destroy them if personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
— put forward a condition of prior consent when processing personal data for the purposes of promoting goods, works and services on the market;
— withdraw consent to personal data processing and also send a request to terminate personal data processing;
— appeal unlawful actions or inaction of the Operator when processing their personal data to the authorized body for the protection of the rights of personal data subjects 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 data about themselves;
— inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data processed for purposes that are incompatible with each other is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or anonymized upon achievement of the purposes of processing or in case the need to achieve these purposes is no longer present, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose of processing
providing the User with access to services, information and/or materials contained on the website.
Personal data
last name, first name, patronymic
phone numbers
Legal grounds
statutory (founding) documents of the Operator
contracts concluded between the Operator and the personal data subject
Types of personal data processing
collection, recording, systematization, accumulation, storage, destruction and anonymization of personal data
7. Conditions for Personal Data Processing7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, for the performance of 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 judicial act, an act of another body or official subject to execution in accordance with 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 or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for exercising 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 are processed where access to personal data is provided to an unlimited number of persons by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of 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 access to personal data by unauthorized persons.
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 legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator’s email address mr.denisyacht89@mail.ru with the subject “Personal Data Update”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which personal data were collected, unless a different period is provided by a contract or applicable legislation.
The User may withdraw their consent to personal data processing at any time by sending the Operator a notice via email to mr.denisyacht89@mail.ru with the subject “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication providers and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject shall independently ознакомится (review) with the said documents. The Operator is not responsible for the actions of third parties, including service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on transfer (except for granting access), as well as on processing or processing conditions (except for access) of personal data permitted for distribution, shall not apply in cases of personal data processing in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Conditions for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the consent period, withdrawal of consent by the personal data subject, a request to terminate personal data processing, as well as detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receipt and/or transmission of the obtained information via information and telecommunication networks or without such networks.
10. Cross-Border Transfer of Personal Data10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is submitted separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom cross-border transfer of personal data is planned.
11. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email mr.denisyacht89@mail.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at: https://audityacht.com/en/privacy