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Privacy

PRIVACY POLICY AND PERSONAL DATA PROCESSING MATRESHKA.TV

1. General provisions

This personal data processing policy has been 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 Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by the LIMITED LIABILITY COMPANY "IT CORPS", TIN 2636220206 OGRN 1222600005891 (hereinafter — the Operator).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

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 receive about website visitors MATRYOSHKA.TV.

2. General concepts in politics

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary termination 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 informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address: MATRYOSHKA.TV.

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 as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data – 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 (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator is a legal entity that independently or jointly with other persons organizes and (or) processes personal data, as well as determines 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 related directly or indirectly to a specific or identifiable User of the website MATRYOSHKA.TV.

2.9. Personal data authorized by the subject of personal data for distribution - personal data to which an unlimited number of persons have access provided by the subject of personal data (hereinafter - personal data authorized for distribution).

2.10. User – any visitor to the website MATRYOSHKA.TV.

2.11. Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data), or familiarization with personal data of an unlimited circle of persons, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data to anyor in another way.

2.13. Cross–border transfer of personal data is the transfer of personal data to the territory of a foreign state to the 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 is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the material carriers of personal data are destroyed.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right:

  1. 3.1.1. to receive accurate information and/or documents containing personal data from the data subject;

  2. 3.1.2. in case the data subject withdraws consent for the processing of personal data, the Operator has the right to continue processing personal data without the data subject's consent if there are grounds specified in the Law on Personal Data;

  3. 3.1.3. independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Law on Personal Data and the normative legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged:

  1. 3.2.1. to provide the data subject, upon request, with information related to the processing of their personal data;

  2. 3.2.2. to organize the processing of personal data in accordance with the current legislation of the Russian Federation;

  3. 3.2.3. to respond to requests and inquiries of data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

  4. 3.2.4. to provide the necessary information to the authorized body for the protection of the rights of data subjects upon the request of this body within 30 days from the date of receiving such request;

  5. 3.2.5. to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

  6. 3.2.6. to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as other illegal actions with respect to personal data;

  7. 3.2.7. to terminate the transfer (distribution, provision, access) of personal data, cease the processing, and destroy personal data in the manner and cases provided by the Law on Personal Data;

  8. 3.2.8. to perform other obligations stipulated by the Law on Personal Data.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right:

  1. 4.1.1. to receive information regarding the processing of their personal data, except as provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;

  2. 4.1.2. to demand that the Operator clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also to take measures provided by law to protect their rights;

  3. 4.1.3. to withdraw consent for the processing of personal data;

  4. 4.1.4. to appeal to the authorized body for the protection of the rights of personal data subjects or in court for unlawful actions or inaction of the Operator regarding the processing of their personal data;

  5. 4.1.5. to exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged:

  1. 4.2.1. to provide the Operator with accurate information about themselves;

  2. 4.2.2. to inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Individuals who have provided the Operator with false information about themselves or information about another personal data subject without their consent bear responsibility in accordance with the legislation of the Russian Federation.

5. Personal Data That May Be Processed

5.1. The list of Users' personal data processed for the purposes defined in section 7 of this Policy includes:

  1. 5.1.1. last name, first name, patronymic;

  2. 5.1.2. email address;

  3. 5.1.3. phone numbers;

  4. 5.1.4. year, month, date, and place of birth;

  5. 5.1.5. photographs;

  6. 5.1.6. details of an identity document.

  7. 5.1.7. The website also collects and processes anonymized data about visitors (including "cookie" files) using internet analytics services (Yandex.Metrica, Google Analytics, and others).

5.2. The above-mentioned data (hereinafter referred to as the "Policy") is collectively referred to as "Personal Data."

5.3. The Operator does not process special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.

5.4. The processing of the special categories of personal data specified in part 1 of Art. 10 of the Federal Law No. 152-FZ "On Personal Data" is allowed in cases where the processing of personal data is necessary in connection with the implementation of international treaties of the Russian Federation on readmission.

5.5. The User's consent to the processing of personal data allowed for distribution is provided separately from other consents to the processing of their personal data. In this case, the conditions provided, in particular, in Art. 10.1 of the Law on Personal Data, are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

  1. 5.5.1. The User provides their consent for the processing of personal data allowed for distribution directly to the Operator.

  2. 5.5.2. The Operator is obliged, within three working days from the date of receiving the User's consent, to publish information about the processing conditions, the presence of prohibitions, and conditions for the processing of personal data allowed for distribution by an unlimited number of persons.

  3. 5.5.3. The transfer (distribution, provision, access) of personal data allowed by the personal data subject for distribution must be terminated at any time upon the request of the personal data subject. This request must include the last name, first name, patronymic (if available), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data, the processing of which is subject to termination. The specified personal data in this request can only be processed by the Operator to whom it is sent.

  4. 5.5.4. The consent for the processing of personal data allowed for distribution expires upon receipt by the Operator of the request specified in paragraph 5.11.3 of this Policy regarding the processing of personal data.

  5. 5.5.5. In case the personal data is disclosed by the personal data subject to an indefinite number of persons without providing the consent provided for in this article, the responsibility for providing evidence of the legality of the subsequent distribution or other processing of such personal data lies with each person who distributed or otherwise processed them.

6. Principles of Personal Data Processing

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

6.2. The processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

6.3. Combining databases containing personal data processed for incompatible purposes is not allowed.

6.4. Only personal data that meets the purposes of their processing is subject to processing.

6.5. The content and scope of processed personal data correspond to the stated purposes of processing. Processing of excessive personal data in relation to the stated purposes of processing is not allowed.

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

6.7. Storage of personal data is carried out in a form that allows identifying the personal data subject for no longer than necessary for the purposes of processing personal data, unless the retention period of personal data is established by federal law, a contract, the party to which, the beneficiary or guarantor under which is the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case there is no longer a need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing

7.1. The purpose of processing User's personal data:

  1. 7.1.1. informing the User by sending emails;

  2. 7.1.2. providing the User with access to services, information, and/or materials contained on the website MATRESHKA.TV;

  3. 7.1.3. identifying the User registered on the website MATRESHKA.TV for their subsequent authorization. Providing the User with access to personalized data of the website MATRESHKA.TV. Confirming the accuracy and completeness of the personal data provided by the User. Creating an account for using parts of the website MATRESHKA.TV if the User has consented to creating an account. Providing the User with effective technical support when facing problems related to the use of the website MATRESHKA.TV.

7.2. Additionally, the Operator has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt-out of receiving informational messages by sending a letter to the Operator at the email address director@matreshka.tv with the subject "Opt-out from notifications about new products and services and special offers."

7.3. De-identified data of Users collected using internet statistics services is used to collect information about Users' actions on the website, improve the quality and content of the website.

8. Legal Bases for Personal Data Processing

8.1. The legal bases for the Operator's processing of personal data are:

  1. 8.1.1. contracts concluded between the Operator and the personal data subject;

  2. 8.1.2. Federal Law No. 149 "On Information, Information Technologies, and Information Protection," Federal Law No. 152 "On Personal Data";

  3. 8.1.3. federal laws and other regulatory legal acts in the field of personal data protection;

  4. 8.1.4. consents of Users to the processing of their personal data, for the processing of personal data allowed for distribution.

8.2. The Operator processes the User's personal data only if they are filled out and/or submitted by the User independently through special forms located on the website MATRESHKA.TV or sent to the Operator via email.

8.3. The Operator processes de-identified data about the User if it is allowed in the User's browser settings (enabled "cookie" files and the use of JavaScript technology).

8.4. The personal data subject independently decides to provide their personal data and gives consent freely, by their own will, and in their own interest.

9. Personal data processing conditions

9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.

9.2. The processing of personal data is necessary to achieve the goals provided for by the Federal Law "On Information, Information Technologies and Information Protection, as well as to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

9.3. The processing of personal data is necessary for the administration of justice, the 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.

9.4. The processing of personal data is necessary for the execution of a contract to which either the beneficiary or the guarantor is the subject of personal data, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.

9.5. 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 subject of personal data are not violated.

9.6. Personal data subject to publication or mandatory disclosure in accordance with Federal Law is processed.

10. Procedure for the collection, storage, transfer and other types of processing of personal data

10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to the personal data of unauthorized persons.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.

10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's email address director@matreshka.tv marked "Updating of personal data".

10.4. The term of processing of personal data is determined by the achievement of the purposes for which personal data was collected, unless another term is provided for by the contract or current legislation. The User can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator's e-mail address director@matreshka.tv marked "Withdrawal of consent to the processing of personal data".

10.5. 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 subject of personal data and/or the User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

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

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

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

10.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the identification of unlawful processing of personal data.

11. List of actions performed by the operator with the received personal data

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

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

12. Cross-border transfer of personal data

12.1. The Operator, if it is necessary to carry out cross-border transfer of personal data, at the request of the User, expressed in attempts to place a separate media material, is obliged to make sure that the foreign state to whose territory it is intended to transfer personal data provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent of the personal data subject to cross-border transfer of his personal data and/or execution of the contract to which the personal data subject is a party.

13. Confidentiality of personal data

13.1. The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by Federal Law.

14. Information about Implemented Requirements for Personal Data Protection

14.1. When processing personal data, necessary legal, organizational, and technical measures are taken to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unauthorized actions with regard to personal data.

14.2. In order to ensure the security of personal data, the company "IT Corps" (LLC) implements the following measures:

  1. 14.2.1. identification of threats to the security of personal data during their processing in information systems;

  2. 14.2.2. application of organizational and technical measures to ensure the security of personal data during their processing in information systems, ensuring compliance with the requirements for the established levels of security;

  3. 14.2.3. evaluation of the effectiveness of the measures taken to ensure the security of personal data processed in information systems of personal data;

  4. 14.2.4. accounting of personal data storage media;

  5. 14.2.5. detection of facts of unauthorized access to personal data and response to such incidents;

  6. 14.2.6. recovery of personal data modified or destroyed due to unauthorized access to them;

  7. 14.2.7. establishment of rules for access to personal data processed in information systems of personal data;

  8. 14.2.8. registration and logging of actions performed with personal data in information systems of personal data;

  9. 14.2.9. control over the measures taken to ensure the security of personal data in accordance with the established level of security of personal data.

15. Final Provisions

15.1. The User can receive any clarifications on matters concerning the processing of their personal data by contacting the Operator via email director@matreshka.tv.

15.2. Any changes to the policy for processing personal data by the Operator will be reflected in this document. The policy is valid indefinitely until replaced by a new version.

15.3. The current version of the Policy is freely available on the Internet at the address https://matreshka.tv/footer/rules/privacy/.