1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "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 Deer Antlers (hereinafter referred to as the Operator).

1.1. The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of privacy rights, personal and family secrets, as its most important goal and condition for 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 can obtain about visitors to the website https://deer-antlers.ru.

2. Basic Terms 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 the processing of personal data (except for cases when processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://deer-antlers.ru.

2.4. Personal data information system — a collection of personal data contained in databases and ensuring their processing by information technologies and technical means.

2.5. Depersonalization of personal data — actions resulting in the impossibility to determine, without using additional information, the belonging of personal data to a specific User or other personal data subject.

2.6. Personal data processing — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator — a state body, municipal body, legal or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, 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://deer-antlers.ru.

2.9. Personal data permitted by the subject of personal data for distribution — personal data to which access is provided to an unlimited number of persons by the subject of personal data through giving consent to the processing of personal data permitted by the subject of personal data for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).

2.10. User — any visitor of the website https://deer-antlers.ru.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquainting an unlimited circle of persons with personal data, including public disclosure 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 — the 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 — any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoration of personal data content in the personal data information system and/or material carriers of personal data are destroyed.

3. Main Rights and Duties of the Operator

3.1. The Operator has the right to:

obtain from the subject of personal data reliable information and/or documents containing personal data;
in case of revocation of consent to the processing of personal data by the subject of personal data, as well as when a request is submitted demanding the cessation of processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 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 subject of personal data, upon his/her request, with information regarding the processing of his/her 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 of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
notify the authorized body for the protection of the rights of personal data subjects, upon request of this body, with the necessary information within 10 days from the date of receipt of such a request;
publish or otherwise ensure 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, distribution of personal data, as well as from other illegal actions regarding personal data;
cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedure and in cases provided for by the Personal Data Law;
perform other duties provided for by the Personal Data Law.
4. Main Rights and Duties of Personal Data Subjects

4.1. Personal data subjects have the right to:

receive information relating to the processing of his/her personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating 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 Personal Data Law;
demand the Operator to clarify his/her personal data, block, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his/her rights;
set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
revoke consent to the processing of personal data, as well as submit a request for cessation of processing of personal data;
complain to the authorized body for the protection of the rights of personal data subjects or in court about unlawful actions or inaction of the Operator during the processing of his/her personal data;
exercise other rights provided for 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 the clarification (update, change) of their personal data.
**4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data processing is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate goals. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of its processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is 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 identifying the personal data subject no longer than required by the purposes of processing personal data unless the storage period of personal data is established by federal law, a contract, or the personal data subject is the beneficiary or guarantor under which the personal data subject is a party. The processed personal data is destroyed or depersonalized upon achieving the processing goals or if the need to achieve these goals is lost unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Processing Purpose

informing the User by sending emails
Personal Data

surname, first name, patronymic
email address
phone numbers
Legal Grounds

Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 No. 149-FZ
Types of Personal Data Processing

Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
Sending informational emails to the email address
7. Conditions for Processing Personal Data

7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data.

7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or a law, for the performance of functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.

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

7.4. Processing of personal data is necessary for the execution of a contract, of which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.

7.5. 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 goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at his/her request (hereinafter referred to as publicly available personal data).

7.7. Processing of personal data subject to publication or mandatory disclosure under federal law is carried out.

8. Procedure for Collecting, Storing, Transferring, 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.

8.1. The Operator ensures the security of personal data and takes all possible measures to exclude unauthorized 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 the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@deer-antlers.ru marked "Personal Data Update".

8.4. The processing period of personal data is determined by the achievement of the purposes for which the personal data was collected unless another period is provided for by the contract or current legislation.

The User may, at any time, withdraw his/her consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@deer-antlers.ru marked "Withdrawal of Consent to Personal Data Processing".

8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or other persons using these services are required to independently familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. The prohibitions established by the personal data subject on the transfer (except for granting access) and on the processing or conditions of processing (except for access) of personal data permitted for dissemination do not apply in cases of processing personal data in public, state, and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data during the processing of personal data.

8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required by the purposes of processing personal data unless a longer storage period is established by federal law, a contract to which the personal data subject is a party, or a beneficiary or guarantor under which the personal data subject is a party.

8.9. The termination of personal data processing may occur upon the achievement of the purposes of personal data processing, expiration of the personal data subject's consent, revocation of consent by the personal data subject, or a request to terminate the processing of personal data, as well as upon detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, access), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data with receiving and/or transmitting the received information via information and telecommunication networks or without such networks.

10. Cross-Border Transfer of Personal Data

10.1. Before starting cross-border transfer of personal data, the Operator must 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 sent separately from the notification of intention to process personal data).

10.2. Before submitting the above notification, the Operator must receive the relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have 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.