Operator Policy on Personal Data Processing
1. General Provisions
This Operator Policy on Personal Data Processing (hereinafter referred to as the «Policy») has been compiled in accordance with the requirements of Federal Law No. 152-FZ «On Personal Data» of July 27, 2006, and defines the procedure for processing personal data and the measures taken by Metafora LLC (hereinafter referred to as the Operator) to ensure the security of personal data.
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 the protection of their rights to privacy, personal and family secrets.
1.2. This Operator Policy on Personal Data Processing applies to all information the Operator may receive about visitors to the metafora-strategy.ru/ website.
2. 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 means temporarily suspending the processing of personal data (except in cases where processing is necessary to clarify the personal data);
2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, making them available online at the address metafora-strategy.ru/
2.4. Personal data information system means a collection of personal data contained in databases and the information technologies and technical means that enable their processing;
2.5. Anonymization of personal data means actions that make it impossible to determine the attribution of personal data to a specific User or other personal data subject without the use of additional information;
2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automated tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data;
2.7. Operator — a government agency, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition 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 an identified or identifiable User of the metafora-strategy.ru/ website.
2.9. User — any visitor to the metafora-strategy.ru/ website.
2.10. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons;
2.11. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including disclosing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data by any other means;
2.12. Cross-border transfer of personal data — the transfer of personal data to a foreign government agency, foreign individual, or foreign legal entity; 2.13. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the contents of the personal data in the personal data information system, and/or the destruction of tangible storage media for the personal data.
3. User's Personal Data
3.1. The Operator may process the following personal data of the User: Surname, first name, patronymic; Email address; Phone numbers.
3.2. The Website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others).
3.3. The above data is hereinafter collectively referred to as "Personal Data."
4. Purposes of Processing Personal Data
4.1. Purpose of Processing the User's Personal Data: User Identification; Establishing feedback with the User, including sending notifications, mailings, and requests regarding the use of the Website, provision of services, and processing requests and applications from the User. Carrying out advertising activities with the consent of the User.
4.2. Anonymized data of Users collected using internet statistics services is used to collect information and about Users' actions on the website, improving the quality of the website and its content.
5. Legal Basis for Processing Personal Data
5.1. The Operator processes the User's personal data only if the User completes and/or submits it independently through special forms located on the metafora-strategy.ru/ website. By completing the relevant forms and/or submitting their personal data to the Operator, the User consents to this Policy.
5.2. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (saving cookies and using JavaScript technology are enabled).
6. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
6.1. 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 on personal data protection.
6.2. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
6.3. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law.
6.4. If any inaccuracies in their personal data are discovered, the User may update them independently by sending a notification to the Operator's email address metafora@metafora-strategy.ru with the subject line "Update personal data."
6.5. The processing period for personal data is unlimited. The User may revoke their consent to the processing of their personal data at any time by sending a notification to the Operator's email address metafora@metafora-strategy.ru with the subject line "Revocation of consent to the processing of personal data."
7. Cross-border transfer of personal data
7.1. Before undertaking any cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to which the personal data is to be transferred ensures reliable protection of the rights of personal data subjects.
7.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out with the personal data subject's written consent to the cross-border transfer of their personal data and/or the execution of an agreement to which the personal data subject is a party.
8. Final Provisions
8.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator by email at metafora@metafora-strategy.ru.
8.2. The Operator reserves the right to amend this Policy without the User's consent.
8.3. This Policy shall be effective and binding on all Operator employees upon its approval.
8.4. The current version of the Policy is publicly available on the Internet at metafora-strategy.ru/privacy.