Privacy policy

1. General Provisions

This personal data processing policy is drawn up 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 determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC “Digital.marketing pro” (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, as its most important goal and condition for its activities.

1.2. This policy of the Operator 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 websitehttps://www.austincontrarian.com/.

2. Basic 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 cessation 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, ensuring their availability on the internet athttps://www.austincontrarian.com/.

2.4. Information system of personal data – a set of personal data contained in databases and ensuring their processing of information technologies and technical means.

2.5. Depersonalization of personal data – actions, as a result of which it is impossible to determine without using additional information the belonging of personal data to a specific User or another subject of personal data.

2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such 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 – a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as 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 websitehttps://www.austincontrarian.com/.

2.9. Personal data allowed by the subject of personal data for dissemination – personal data to which an unlimited number of persons have access provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for dissemination).

2.10. User – any visitor to the websitehttps://www.austincontrarian.com/.

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

2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing oneself with personal data of an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunications 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, a foreign government authority, a foreign individual or a 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 the content of personal data in the information system of personal data and/or material carriers of personal data are destroyed.

3. Basic 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 subject of personal data;

— in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request to terminate the 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 adopted in accordance with it regulatory legal acts, 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, at his request, with information regarding the processing of his 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 from subjects of personal data 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 subjects of personal data at their request of the necessary information within 10 days from the date of receipt of such a 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 unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;

— cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for 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 regarding the processing of his personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, 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 from the operator the clarification of his personal data, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;

— put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services in the market;

— withdraw consent to the processing of personal data, as well as send a request to terminate the processing of personal data;

— appeal to the authorized body for the protection of the rights of subjects of personal data or in court the unlawful actions or inaction of the Operator in the processing of his 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 reliable data about themselves;

— inform the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data 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. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate goals. It is not allowed to process personal data incompatible with the purposes of collecting personal data.

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 meet the purposes of their processing are subject to processing.

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

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

5.7. Personal data are stored in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require, unless the period for storing personal data is established by federal law, a contract, a party to which, the beneficiary or guarantor under which is the subject of personal data. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes unless otherwise provided by federal law.

6. Purposes of personal data processing

7. Conditions for personal data processing

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.

7.3. 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.

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

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.

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

7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with 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 through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures that exclude access to personal data by unauthorized persons.

8.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except for 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 for the fulfillment of obligations under a civil law 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 addressinfo@austincontrarian.com marked “Updating personal data”.

8.4. The period for processing personal data is determined by the achievement of the purposes for which personal data were collected, unless otherwise provided by the contract or applicable law.
The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s email addressinfo@austincontrarian.com marked “Withdrawal of consent to the processing of personal data”.

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

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

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

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

8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of actions performed by the Operator with the 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 the receipt and/or transmission of the received information via information and telecommunications networks or without such.

10. Cross-border transfer of personal data

10.1. The Operator, before starting the activity of cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of subjects of personal data 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 is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom it is planned to transfer personal data cross-border.

11. Confidentiality of personal data

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

12. Final provisions

12.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via emailinfo@austincontrarian.com.
12.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced with a new version.

12.3. The current version of the Policy is freely available on the internet athttps://www.austincontrarian.com/privacy/.