Personal Data Processing Policy

This personal data processing policy has been prepared in accordance with the requirements of 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 taken by Vedunya LLC (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including 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 may receive about visitors to the website https://vedunya.ai.

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

2.2. Blocking of personal data — temporary cessation of personal data processing (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 https://vedunya.ai.

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 belonging of personal data to a specific User or other personal data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without 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 — a state body, municipal body, legal entity or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, 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 website https://vedunya.ai.

2.9. Personal data permitted by the personal data subject for distribution — personal data to which unlimited access is 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 (hereinafter referred to as personal data permitted for distribution).

2.10. User — any visitor to the website https://vedunya.ai.

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

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — 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 irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3.1. The Operator has the right to:

• — receive reliable information and/or documents containing personal data from the personal data subject;
• — in case of withdrawal by the personal data subject of consent to the processing of personal data, as well as sending a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject 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 personal data subject, at his request, with information regarding the processing of his personal data;
• — organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• — respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• — report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, 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 to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
• — stop the transfer (distribution, provision, access) of personal data, stop 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.

4.1. Personal data subjects have the right to:

• — receive information regarding the processing of his personal data, except in cases provided for by federal laws. 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 disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• — require the operator to clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
• — put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
• — withdraw consent to the processing of personal data, as well as send a request to stop the processing of personal data;
• — appeal to the authorized body for the protection of the rights of personal data subjects or in court the unlawful actions or inaction of the Operator when processing 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 (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.

5.1. Processing of personal data is carried out on a lawful and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. 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 their processing are subject to processing.

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

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing is ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achievement of processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

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

7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to implement the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, 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. Processing of personal data is necessary to fulfill a contract to which the personal data subject is a party, beneficiary or guarantor, as well as to conclude a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. 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 personal data subject are not violated.

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

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

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 safety of personal data and takes all possible measures that exclude 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 implementation 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 law contract.

8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address m@vedunya.ai marked 'Personal data update'.

8.4. The period of personal data processing 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 can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address m@vedunya.ai marked 'Withdrawal of consent to personal data processing'.

8.5. All information collected by third-party services, including payment systems, communication tools 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 with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. Prohibitions on transfer (except for providing access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, established by the personal data subject, 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. When processing personal data, the Operator ensures the confidentiality 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 personal data processing, unless the storage period of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor.

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

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

9.2. The Operator carries out automated processing of personal data with receipt and/or transmission of received information via information and telecommunication networks or without it.

10.1. Before starting activities for cross-border transfer of personal data, the Operator is obliged to 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 the intention to process personal data).

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

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.

12.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email m@vedunya.ai.

12.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://vedunya.ai/privacy.