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Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been compiled 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 taken by the Private Cultural Institution "Jewish Museum and Tolerance Center" (hereinafter referred to as the Operator, Private Cultural Institution "Jewish Museum and Tolerance Center").

1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including protecting the rights to privacy, personal and family secrets.

1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://www.jewish-museum.ru/en/policy/.

1. Key concepts 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 suspension of personal data processing (except in cases 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 https://www.jewish-museum.ru/en/policy/.

2.4. Personal data information system— A collection of personal data contained in databases and the information technologies and technical means that support their processing.

2.5. Anonymization of personal data—actions that make it impossible to determine without the use of additional information the ownership of personal data by 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 with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a government agency, municipal body, legal entity, or individual independently or jointly with other persons organizing and/or carrying out the processing of personal data, and also determining the purposes of processing personal data, the composition of personal data to be processed, 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://www.jewish-museum.ru/en/policy/.

2.9. Personal data permitted for distribution by the personal data subject— personal data, access to which by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).

2.10. User— Any visitor to the websitehttps://www.jewish-museum.ru/en/policy/.

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 number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including disclosure of personal data in the media, posting in information 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 government agency, foreign individual, or foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are irrevocably destroyed, making it impossible to further restore the contents of personal data in the personal data information system, and/or the destruction of tangible media containing personal data.

3. Main 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 that the personal data subject revokes consent to the processing of personal data, or if an application is submitted requesting termination of the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
  • Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Law on Personal Data and the regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obligated to:

  • provide the personal 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 current legislation of the Russian Federation;
  • Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
  • Disclose the necessary information to the authorized body for the protection of the rights of personal data subjects, at the request of such body, within 10 days from the date of receipt of such request;
  • Publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
  • Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
  • Stop the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases stipulated by the Law on Personal Data;
  • fulfill other obligations stipulated by the Law on Personal Data.
  • "If an unauthorized accidental transfer (provision, distribution, access) of personal data is established, resulting in a violation of Users' rights, notify the authorized body of the incident within 24 hours of the discovery of such an incident, and take other measures in connection with the identified incident within the timeframes established by 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 stipulated by federal laws. The Operator provides the personal data subject with information in an accessible form, and it must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
  • require the Operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
  • set a condition for prior consent to the processing of personal data for the purpose of promoting goods, works, and services on the market;
  • to revoke consent to the processing of personal data, as well as to request the cessation of the processing of personal data;
  • to appeal to the authorized body for the protection of the rights of personal data subjects or in court unlawful actions or inaction of the Operator when processing their personal data;
  • to exercise other rights provided for by Russian legislation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with accurate information about themselves;
  • notify the Operator of any clarification (updates, changes) of their personal data.

4.3. Persons who provide the Operator with false information about themselves or about another personal data subject without the latter's consent are liable in accordance with Russian Federation law.

5. Principles of Personal Data Processing

5.1. Personal data is processed lawfully and fairly.

5.2. Personal data is processed only to achieve specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes for which it was collected is prohibited.

5.3. Combining databases containing personal data processed for incompatible purposes is prohibited.

5.4. Only personal data that meets the purposes for which it is processed will be processed.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive amounts of processed personal data in relation to the stated purposes of processing are not permitted.

5.6. When processing personal data, its accuracy, sufficiency, and, where necessary, relevance to the purposes of processing the personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows for the identification of the subject of the personal data, for no longer than required for the purposes of processing the personal data, unless the storage period for the personal data is established by federal law or an agreement to which the subject of the personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon the achievement of the processing purposes or when the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

6.1. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting the personal data is not permitted.

6.2. Only personal data that is relevant to the purposes for which it is processed will be processed.

6.3. The Operator processes personal data for the following purposes:

  • ensuring compliance with the Constitution of the Russian Federation, federal laws, and other regulatory legal acts of the Russian Federation;
  • carrying out its activities in accordance with the charter of the Jewish Museum and Tolerance Center;
  • completing and submitting required reporting forms to executive authorities and other authorized organizations;
  • implementing civil law relations;
  • maintaining accounting records;
  • implementing access control.

6.4. The processing of employees' personal data may be carried out solely for the purpose of ensuring compliance with laws and other regulatory legal acts.

6.5. The User's personal data may be processed:

- informing the User by sending emails;

- concluding, executing, and terminating civil contracts to which the Personal Data Subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the Personal Data Subject or an agreement under which the Personal Data Subject will be a beneficiary or guarantor;

- providing the User with access to services, information, and/or materials contained on the website.

6.6. Anonymized User Data Collected Using Internet Services Statistics are used to collect information about User actions on the website and improve the quality of the website and its content.

7. The Operator may process the following personal data of the User

7.1. User's last name, first name, and patronymic.

7.2. User's registration address and residential address.

7.3. Email address, telephone numbers.

7.4. Date of birth.

7.5. Gender.

7.6. Passport details (series, number, issuer, date of issue, department code).

7.7. The Site also collects and processes anonymized visitor data (including cookies) using internet statistics services.

7.8. The above data is hereinafter collectively referred to as "Personal Data."

7.9. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.

7.10. The processing of personal data permitted for distribution, from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data, is permitted if the prohibitions and conditions set forth in Article 10.1 of the Law on Personal Data are observed.

7.11. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of their personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

7.12.1 The User provides consent to the processing of personal data permitted for distribution directly to the Operator.

7.12.2 The transfer (distribution, provision, access) of personal data permitted for distribution by the personal data subject must be terminated at any time upon the personal data subject's request. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is addressed.

7.12.3 Consent to the processing of personal data permitted for distribution terminates upon the Operator's receipt of the request specified in paragraph 7.12.2 of this Policy regarding the processing of personal data.

8. Terms of Personal Data Processing

8.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.

8.2. Personal data shall be processed to achieve the goals stipulated by an international treaty of the Russian Federation or by law, or to exercise the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

8.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or the act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

8.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, a beneficiary, or a guarantor, as well as for the conclusion of an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

8.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

8.6. Personal data is processed that is made available to an unlimited number of persons by the subject of the personal data or at their request (hereinafter referred to as publicly available personal data).

8.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

9. Procedure for collection, storage, and transfer

other types of personal data processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully meet the requirements pursuant to applicable legislation on personal data protection.

9.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.

9.2. The Operator has the right to entrust the processing of personal data to third parties based on agreements concluded with such parties (hereinafter referred to as "Third Parties"), the list of which is specified in the Consent to the Processing of Personal Data by Third Parties. Third Parties undertake to comply with the principles and rules for processing personal data stipulated by the Law on Personal Data, other laws and regulations, maintain confidentiality, and take the necessary measures to ensure compliance with the obligations stipulated by the Law on Personal Data. For each Third Party, the agreement concluded with the Operator will define the list of personal data processed, the purposes of their processing, and the list of actions (operations) that will be performed with the personal data by the Third Party. The Third Party's obligations to maintain the confidentiality and security of personal data during its processing, as well as a list of measures taken by the processor to ensure the protection of the personal data it processes, including the requirement to notify the Operator of incidents involving personal data; the obligation, upon the Operator's request, during the validity period of the order to process personal data, to provide the Operator with documents and other information confirming the measures taken and compliance with the requirements established by the Personal Data Law for the execution of the Operator's order. The Third Party is not required to obtain the consent of the personal data subject to the processing of their personal data. If the processing of personal data at the Operator's order requires the consent of the User, such consent is obtained directly by the Operator.

9.3. If any inaccuracies in personal data are discovered, the User may update them independently, by sending a notification to the Operator's email addressinfo@jewish-museum.ru with the subject "Update personal data".

9.4. The Operator's processing and storage period for personal data is unlimited. The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email addressinfo@jewish-museum.ru with the subject "Withdrawal of consent to the processing of personal data".

9.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obligated to promptly familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

9.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public, or other public interests, defined by the legislation of the Russian Federation.

9.7. The Operator ensures the confidentiality of personal data when processing personal data.

9.8. The Operator shall store personal data in a form that allows identification of the personal data subject, for no longer than required for the purposes of processing the personal data, unless the personal data storage period is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.

9.9. The termination of personal data processing may be conditional upon the achievement of the personal data processing purposes, expiration of the personal data subject's consent or the revocation of consent by the personal data subject, as well as the detection of unlawful processing of personal data.

10. List of actions performed by the Operator with received personal data

10.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, modify), retrieve, use, transfer (disseminate, provide, access), depersonalize, block, delete, and destroy personal data.

10.2. The operator carries out automated processing of personal data. personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obligated 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 on any questions regarding the processing of their personal data by contacting the Operator by email at info@jewish-museum.ru.

12.2. The Operator reserves the right to amend this policy. When making changes, the date of the last update is indicated in the current version. The new version of this policy takes effect from the moment it is posted on the Website or in the App, unless otherwise provided in the new version of this policy. The current version is always available on the Website.