Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy is drafted in compliance with Federal Law No. 152-FZ dated 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 the Operator (hereinafter referred to as the "Operator").

1.1. The Operator sets as its most important goal and condition for the performance of its activities the respect for human and civil rights and freedoms during the processing of personal data, including the protection of 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 may obtain about visitors to the website https://drills.imaginal.dev.

2. Basic Concepts Used in the Policy

• Automated processing of personal data — processing of personal data using computer technology.
• Blocking of personal data — temporary termination of personal data processing (unless processing is necessary to clarify personal data).
• Website — a collection of graphic and information materials, as well as computer software and databases that ensure their availability on the internet at the network address https://drills.imaginal.dev.
• Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
• Depersonalization of personal data — actions that result in the impossibility of determining, without using additional information, the ownership of personal data by a specific User or other personal data subject.
• Processing of personal data — any action (operation) or sequence of actions (operations) performed with or without automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
• Operator — a state body, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or performs 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.
• Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://drills.imaginal.dev.
• Personal data permitted by the personal data subject for distribution — personal data to which an unlimited number of persons have access granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Personal Data Law.
• User — any visitor to the website https://drills.imaginal.dev.
• Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
• Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or acquainting an unlimited circle of persons with personal data, including publication in media, placement in telecommunications networks, or providing access in any other way.
• Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
• Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the information system and/or the destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive accurate information and/or documents containing personal data from the personal data subject;
• in the event of withdrawal of consent to personal data processing by the personal data subject, as well as upon receipt of a request to terminate personal data processing, continue personal data processing without the subject's consent if grounds specified in the Personal Data Law exist;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and adopted regulatory legal acts, unless otherwise provided by federal law.

3.2. The Operator is obliged to:

• provide the personal data subject upon their request with information regarding the processing of their personal data;
• organize the processing of personal data in accordance with current legislation;
• respond to appeals and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• inform the authorized body for the protection of the rights of personal data subjects upon request within 10 days from receipt of such request;
• publish or otherwise provide unrestricted access to this Policy regarding personal data processing;
• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, or other unlawful actions;
• cease transfer (distribution, provision, access), cease processing, and destroy personal data in the cases and manner prescribed by the Personal Data Law;
• fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided in an accessible form and must not contain personal data relating to other subjects, unless lawful grounds exist;
• require the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and take statutory measures to protect their rights;
• put forward a condition of prior consent when processing personal data for marketing purposes;
• withdraw consent to personal data processing and submit a demand to terminate personal data processing;
• appeal against unlawful actions or omissions of the Operator to the authorized supervisory authority or in court;
• exercise other rights provided by law.

4.2. Personal data subjects are obliged to:

• provide the Operator with reliable personal data about themselves;
• notify the Operator of any clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another subject without the latter's consent, bear responsibility in accordance with applicable law.

5. Principles of Personal Data Processing

• 5.1. Personal data processing is carried out on a lawful and fair basis.
• 5.2. Personal data processing is limited to achieving specific, predetermined, and legitimate purposes. Processing incompatible with the purposes of personal data collection is not permitted.
• 5.3. Merging databases containing personal data processed for mutually incompatible purposes is not permitted.
• 5.4. Only personal data that meets the purposes of processing is subject to processing.
• 5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes is not permitted.
• 5.6. The accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
• 5.7. Storage of personal data is carried out in a form that allows identifying the subject for no longer than required by the purposes of processing, unless a storage period is established by law or contract. Processed data is destroyed or depersonalized upon achieving the processing purposes or loss of necessity to achieve them.

6. Purposes of Personal Data Processing

The Operator processes the User's personal data for the following purposes:

7. Conditions of Personal Data Processing

• 7.1. Processing is carried out with the consent of the subject to the processing of their personal data.
• 7.2. Processing is necessary to achieve goals stipulated by international treaties or law, or to carry out powers and duties imposed on the operator by law.
• 7.3. Processing is necessary for the administration of justice or execution of a judicial act.
• 7.4. Processing is necessary for the execution of a contract to which the subject is a party, beneficiary, or guarantor, or for concluding a contract at the initiative of the subject.
• 7.5. Processing is necessary for the exercise of rights and legitimate interests of the operator or third parties, provided that the rights and freedoms of the subject are not violated.
• 7.6. Processing of personal data made publicly available by the subject or at their request is carried out.
• 7.7. Processing of personal data subject to mandatory publication or disclosure under federal law is carried out.

8. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to comply in full with statutory personal data protection requirements.

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

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting information via telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing cross-border personal data transfer, the Operator is obliged to notify the authorized supervisory authority of its intention to carry out cross-border transfer (sent separately from the general processing notification).

10.2. Prior to submitting the aforementioned notification, the Operator is obliged to obtain relevant information from foreign authorities, foreign individuals, or foreign legal entities to which cross-border transfer is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject, unless otherwise provided for by federal law.

12. Final Provisions

12.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at bmo@imaginal.dev.

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

12.3. The current version of the Policy is freely available on the Internet at https://drills.imaginal.dev/privacy-policy.