Personal Data Processing Policy
1. General Provisions
This personal data processing policy is drafted 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 measures to ensure the security of personal data undertaken by Individual Entrepreneur Danilova Alexandra Vadimovna (hereinafter referred to as the "Operator").
1.1. The Operator considers the observance of human and citizen rights and freedoms in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets, as its most important goal and a condition for carrying out its activities.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the bug-productioncommunity.com website.
2. Key Concepts Used in the Policy
2.1. Automated Processing of Personal Data: The processing of personal data using computer technology.
2.2. Blocking of Personal Data: The 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, that ensure their availability on the Internet at the network address bug-productioncommunity.com.
2.4. Personal Data Information System: A collection of personal data contained in databases, and the information technologies and technical means that ensure their processing.
2.5. Anonymization of Personal Data: Actions as a result of which it is impossible to determine, without the use of additional information, the association of personal data with 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 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 body, municipal body, legal entity, or individual who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of processing personal data, 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 a specific or identifiable User of the bug-productioncommunity.com website.
2.9. Personal Data Allowed by the Data Subject for Distribution: Personal data that is made accessible to an unlimited number of persons by the data subject by giving consent to the processing of personal data allowed by the data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as "Personal Data Allowed for Distribution").
2.10. User: Any visitor to the bug-productioncommunity.com website.
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 undefined group of persons (transfer of personal data) or at familiarizing an unlimited group of persons with personal data, including the publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border Transfer of Personal Data: The transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data: Any actions as a result of which personal data are irretrievably destroyed, making it impossible to further restore the content of personal data in the personal data information system, and/or the destruction of tangible media of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
• Obtain from the data subject reliable information and/or documents containing personal data.
• In the event that the data subject withdraws consent to the processing of personal data, and also sends a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law.
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for 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 data subject, upon their request, with information regarding the processing of their personal data.
• Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation.
• Respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.
• Report to the authorized body for the protection of the rights of data subjects, upon request of this body, the necessary information within 10 days from the date of receipt of such a 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, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data.
• Terminate the transfer (dissemination, provision, access) of personal data, terminate the processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law.
• Fulfill other obligations stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
• Receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator shall provide information to the data subject in an accessible form, and it must not contain personal data relating to other data subjects, except when there are legal grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law.
• Require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights.
• Require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market.
• Withdraw consent to the processing of personal data, and to send a request to terminate the processing of personal data.
• Appeal to the authorized body for the protection of the rights of data subjects or in court against the unlawful actions or omissions of the Operator in the processing of their personal data.
• Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
• Provide the Operator with accurate data about themselves.
• Notify the Operator of any updates or changes to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another data subject without their consent, may be held responsible under Russian law.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out in a lawful, fair, and transparent manner.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. Personal data must not be processed in a way that is inconsistent with the purposes for which it was originally collected.
5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that is relevant to the purpose of processing will be processed.
5.5. The amount and type of personal data processed will be limited to what is necessary for the stated purpose. Processing excessive data is strictly prohibited.
5.6. The Operator will ensure that personal data is accurate, sufficient, and, where necessary, kept up to date. The Operator takes the necessary measures and/or ensures that they are taken to remove or clarify incomplete or inaccurate data.
5.7. Personal data will be stored in a way that allows identification of the data subject only for as long as necessary to fulfill the purpose of processing. Exceptions apply if a longer storage period is required by federal law or a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achievement of the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
5.8. The Operator does not transfer sensitive personal data when a user receives a promotional code, coupon, or other promotions and discounts on third-party resources.
6. Conditions for Processing Personal Data
6.1. Data processing requires the data subject’s consent.
6.2. The Operator may process personal data if necessary to comply with a Russian international treaty or law.
6.3. The Operator may process personal data if required for legal proceedings, judicial orders, or other official actions enforceable under Russian law.
6.4. The Operator may process personal data if it is necessary to fulfill a contract with the data subject, or if the data subject is a beneficiary or guarantor under the contract. This also applies to contracts initiated by the data subject.
6.5. The Operator may process personal data if it is necessary to pursue the Operator’s or a third party’s legitimate interests, or for socially important purposes, as long as the data subject’s rights and freedoms are protected.
6.6. The Operator will process personal data that the data subject has made publicly available.
6.7. The Operator will process personal data that it is legally required to publish or disclose.
7. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The 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.
7.1. The Operator is committed to ensuring the security of personal data and will take all reasonable measures to prevent unauthorized access.
7.2. The Operator will not transfer the User’s personal data to third parties, except when required by law or with the User’s explicit consent.
7.3. Users can correct any inaccuracies in their personal data by sending an email to hello@bugproduction.community with the subject line "Personal Data Update".
7.4. Personal data will be retained only as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by contract or law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at hello@bugproduction.community with the subject line "Withdrawal of Consent to Personal Data Processing".
7.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The data subject is advised to review these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
7.6. When processing personal data authorized for distribution, restrictions set by the data subject on the transfer (excluding access) or on the conditions of processing (excluding access) will not apply if the data is processed in the public interest, as defined by Russian law.
7.7. When processing personal data, the Operator ensures the confidentiality of personal data.
7.8. When delivering goods, the Operator may collect data about the delivery destination and recipient in order to accurately calculate the route. Freight transportation is carried out by transport companies and courier delivery services. Prices are based on the carrier’s rates, depending on the volume and weight of the cargo, as well as the distance from the point of departure.
7.9. The Operator stores personal data in a form that allows identification of the data subject for no longer than necessary for the purposes of processing personal data, unless a storage period is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor.
7.10. The conditions for termination of personal data processing may be the achievement of the purposes of processing personal data, the expiration of the term of the data subject’s consent, the withdrawal of consent by the data subject or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
8. List of Actions Performed by the Operator with Received Personal Data
8.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (disseminates, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
8.2. The Operator uses automated methods to process personal data, either with or without transmitting the information across telecommunication networks.
9. Cross-border Transfer of Personal Data
9.1. The Operator must notify the authorized data protection authority before engaging in cross-border transfers of personal data. This notification is separate from the notification of intent to process personal data.
9.2. Before submitting the notification, the Operator must obtain the necessary information from the foreign entities to whom the data will be transferred.
10. Confidentiality of Personal Data
The Operator is committed to maintaining the confidentiality of personal data. The Operator and other persons who have gained access to personal data must not disclose or disseminate personal data to third parties without the data subject’s consent, unless otherwise provided by federal law.
11. Final Provisions
11.1. Users may request clarifications on issues of interest relating to the processing of their personal data by contacting the Operator via email at hello@bugproduction.community.
11.2. This document will be updated to reflect any changes to the Operator’s personal data processing policy. This policy remains in effect until a new version is published.
11.3. The current version of the Policy is freely available on the Internet at bug-productioncommunity.com/privacypolicy.