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Policy on the Processing of Personal Data


1. General Provisions
This Policy on the Processing of Personal Data has been developed in accordance with the requirements of Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter – the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data carried out by Ludmilla Stecklein Osnabrück (hereinafter – 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, personal and family secrets, as the main goal and condition of its activities.
1.2. The 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 of the website https://en.atomy24.net

2. Key Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data with the use of 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 information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://en.atomy24.net
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 that make it impossible, without additional information, to determine whether the 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 the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state or municipal authority, legal entity, or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, the scope 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 https://en.atomy24.net
2.9. Personal data authorized by the subject for distribution – personal data to which the subject has provided access to an unlimited number of persons by giving consent to the processing of such data in the manner prescribed by the Personal Data Law (hereinafter – personal data authorized for distribution).
2.10. User – any visitor of the website https://de.atomy24.net
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 number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the media, posting in information and telecommunication 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, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the permanent destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible media of 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 case of withdrawal of consent to the processing of personal data by the subject, as well as in case of a request to terminate the processing of personal data, continue processing without consent on the grounds specified in the Personal Data Law;
  • independently determine the scope and list of measures necessary and sufficient to ensure the 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 must:
  • provide the data subject, upon request, with information regarding the processing of their personal data;
  • organize the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
  • respond to objections and requests from data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
  • provide the competent authority for the protection of the rights of individuals whose personal data is processed, upon its request, with the necessary information within 10 days of receiving such a request;
  • publish this Policy on the processing of personal data or otherwise provide unrestricted access to it;
  • take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, and dissemination, as well as from other unlawful actions regarding personal data;
  • cease the transfer (dissemination, provision, access) of personal data, terminate processing, and destroy personal data in cases provided for by the Law on Personal Data;
  • fulfill other obligations established by the Law on Personal Data.
4. Fundamental Rights and Obligations of Data Subjects

4.1 Data subjects have the right to:
  • receive information on the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except in cases where there is a legal basis for disclosing such data. The list of information and the procedure for obtaining it is defined by the Law on Personal Data;
  • demand from the Operator clarification, blocking, or destruction of their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legally established measures to protect their rights;
  • make the processing of personal data for the purposes of marketing goods, works, and services conditional upon prior consent;
  • withdraw their consent to the processing of personal data and submit a request to terminate such processing;
  • appeal to the competent authority for the protection of data subjects’ rights or to the court against unlawful actions or inaction of the Operator in processing 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 reliable data about themselves;
  • inform the Operator about clarification (updating, amending) of their personal data.
4.3 Persons who have provided the Operator with false information about themselves or about another data subject without the latter’s consent shall be held liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1 Processing of personal data shall be carried out on a lawful and fair basis.
5.2 Processing of personal data shall be limited to the achievement of specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3 It is prohibited to combine databases containing personal data processed for incompatible purposes.
5.4 Only personal data that meets the purposes of its processing may be processed.
5.5 The content and scope of processed personal data shall correspond to the stated purposes of processing. Processed personal data must not be excessive in relation to the stated purposes of its processing.
5.6 In processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
5.7 Personal data shall be stored in a form that allows the identification of the data subject, and no longer than is required for the purposes of processing, unless a storage period is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized once the purposes of processing are achieved or when they are no longer required for such purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of Processing
Informing the user by sending emails
Personal Data
  • Surname, first name, patronymic
  • Email address
  • Phone numbers
  • Year, month, date, and place of birth
Legal Grounds
Federal Law “On Information, Information Technologies, and Information Protection” dated 27.07.2006 No. 149-FZ.
Types of Personal Data Processing
Transfer of personal data

7. Conditions for the Processing of Personal Data
7.1 The processing of personal data shall be carried out with the consent of the data subject to the processing of his or her personal data.
7.2 The processing of personal data is necessary to achieve the purposes provided for by international treaties of the Russian Federation or by law, to fulfill the functions, powers, and obligations imposed on the operator by the legislation of the Russian Federation.
7.3 The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another authority, or an official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4 The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5 The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
7.6 The processing of personal data made publicly available by the data subject to an unlimited number of persons or at the request of the data subject (hereinafter referred to as publicly available personal data) shall be carried out.
7.7 The processing of personal data subject to publication or mandatory disclosure under federal law shall be carried out.

8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the operator shall be ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of applicable laws in the field of personal data protection.
8.1 The operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2 The user’s personal data shall under no circumstances be transferred to third parties, except in cases related to the execution of applicable legislation or if the data subject has given consent to the operator to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3 If inaccuracies in personal data are detected, the user may independently update them by sending a notification to the operator at the e-mail address privacy@thismywebsite.com
8.4 The period of processing of personal data is determined by the achievement of the purposes for which the personal data was collected, unless otherwise provided by contract or applicable law. The user may withdraw consent to the processing of personal data at any time by sending a notification to the operator via e-mail at privacy@thismywebsite.com
8.5 All information collected by third-party services, including payment systems, communication facilities, and other service providers, shall be stored and processed by such persons (operators) in accordance with their user agreement and privacy policy. Personal data is subject to and/or governed by the said documents. The operator shall not be responsible for the actions of third parties, including the service providers referred to in this clause.
8.6 Prohibitions established by the data subject on the transfer (except for granting access), as well as on processing or conditions of processing (except for granting access) of personal data authorized for dissemination, do not apply to the processing of personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7 The operator shall ensure the confidentiality of personal data during its processing.
8.8 The operator shall store personal data in a form that makes it possible to identify the data subject no longer than required for the purposes of processing, unless the storage period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9 Grounds for termination of the processing of personal data may include the achievement of the purpose of processing, the expiry of the data subject’s consent, the withdrawal of consent by the data subject, a request to terminate the processing of personal data, or the establishment of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data
9.1 The operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
9.2 The operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data
10.1 Before commencing the cross-border transfer of personal data, the operator is obliged to notify the authority responsible for the protection of the rights of personal data subjects of its intention to carry out such a transfer (this notification shall be submitted separately from the notification of the intention to process personal data).
10.2 The operator is obliged to obtain the relevant information from foreign authorities, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned before sending the aforementioned notification.

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

12. Final Provisions
12.1 The user has the right to contact the operator via e-mail at privacy@thismywebsite.com
to clarify issues regarding the processing of his or her personal data.
12.2 This document reflects all changes in the operator’s policy regarding the processing of personal data. The policy is valid indefinitely until it is replaced by a new version.
12.3 The current version of the policy is freely available on the Internet at https://en.atomy24.net/privacy/