Policy Regarding the Processing of Personal Data
1. General Provisions
This policy for the processing of personal data is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”). It defines the procedures for processing personal data and the measures taken by the electronic version of the journal “ANRI” (hereinafter referred to as the “Operator”) to ensure the security of such data.
1.1. The Operator’s primary objective and a fundamental condition for its operations is the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy and the confidentiality of personal and family life.
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 obtain about visitors to the website https://anry.pro/.

 

2. Key Terms Used in the Policy
2.1. Automated processing of personal data — the processing of personal data using computing equipment.
2.2. Blocking of personal data — the temporary cessation of personal data processing (except in cases where such processing is necessary for the purpose of updating or clarifying the personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer software and databases, made accessible on the Internet at the network address https://anry.pro/.
2.4. Personal data information system — a collection of personal data contained in databases, along with the information technologies and technical means used to process such data.
2.5. Anonymization (depersonalization) of personal data — actions that render it impossible to determine, without the use of additional information, which specific User or other data subject the personal data belongs to.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, granting access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who, independently or jointly with others, organizes and/or carries out the processing of personal data, and who determines the purposes of such processing, the scope of the personal data to be processed, and the actions (operations) to be performed on the personal data.
2.8. Personal data — any information relating, directly or indirectly, to a specific or identifiable user of the website https://anry.pro/.
2.9. Personal data authorized by the data subject for dissemination — personal data to which the data subject has granted access to an unlimited number of persons by providing consent for the processing of such data, in accordance with the procedures established by the Law on Personal Data (hereinafter referred to as “personal data authorized for dissemination”).
2.10. User — any visitor to the website https://anry.pro/.
2.11. Provision of personal data — actions intended to disclose personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an indefinite number of persons, including the publication of personal data in the mass media, posting it on information and telecommunication 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 to a foreign public authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data, making it impossible to subsequently restore the content of such data within an information system for personal data, and/or the destruction of the physical media on which the personal data is stored.

 

3. Key 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;
— continue processing personal data without the subject’s consent—in the event that the subject withdraws their consent or submits a request to cease such processing—provided that grounds for doing so exist under the Personal Data Law;
— independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and the regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated 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 the procedures established by the current legislation of the Russian Federation;
— respond to inquiries and requests from personal data subjects and their legal representatives in compliance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects with necessary information, upon its request, within 10 days of receiving such a request;
— publish this Policy on the processing of personal data or otherwise ensure unrestricted access to it;
— implement legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, or dissemination, as well as against any other unlawful actions involving personal data. — to cease the transfer (dissemination, provision, granting of access) of personal data, to cease the processing of personal data, and to destroy personal data in the manner and in the cases provided for by the Law on Personal Data;
— to fulfill other obligations provided for by the Law on Personal Data.

 

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— obtain information regarding the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the personal data subject by the Operator in an accessible format and shall not contain personal data pertaining to other personal data subjects, unless there are legal grounds for disclosing such data. The scope of information and the procedure for obtaining it are established by the Law on Personal Data;
— request that the Operator clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, obtained unlawfully, or is not necessary for the stated purpose of processing; and to take measures provided for by law to protect their rights;
— stipulate a requirement for prior consent when their personal data is processed for the purpose of promoting goods, works, or services in the market;
— withdraw their consent to the processing of their personal data, as well as submit a request to cease the processing of their personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court regarding any unlawful actions or omissions by the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obligated to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarifications (updates, changes) to their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, shall be held liable in accordance with the legislation of the Russian Federation.

 

5. Principles of Personal Data Processing
5.1. Personal data processing shall be carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing personal data in a manner incompatible with the purposes for which it was collected is not permitted.
5.3. It is not permitted to combine databases containing personal data that are processed for purposes that are incompatible with one another.
5.4. Only personal data that are relevant to the purposes of their processing may be processed.
5.5. The content and volume of the personal data being processed must correspond to the stated purposes of such processing. The personal data processed must not be excessive in relation to the stated purposes for which they are processed.
5.6. During the processing of personal data, the data must be accurate, sufficient, and—where necessary—up-to-date in relation to the purposes for which they are processed. The operator shall take, or ensure the taking of, necessary measures to delete or rectify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows for the identification of the data subject for no longer than is required by the purposes for which the data are processed, unless a different retention period is established by federal law or by a contract to which the data subject is a party, a beneficiary, or a guarantor. Once the purposes of processing have been achieved, or if there is no longer a need to achieve such purposes, the personal data being processed shall be destroyed or anonymized, unless otherwise provided for by federal law.

 

6. Purposes of Personal Data Processing

Purpose of processing	Providing the User with access to services, information, and/or materials contained on the website
Personal data	• Full name (surname, first name, patronymic) • Email address • Phone numbers
Legal grounds	• The Operator’s charter (founding/constitutive) documents
Types of personal data processing	• Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data • Sending informational emails to the provided email address

 

7. Conditions for the Processing of Personal Data
7.1. Personal data shall be processed with the consent of the personal data subject.
7.2. Personal data shall be processed when necessary to achieve objectives stipulated by an international treaty of the Russian Federation or by law, or to carry out the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Personal data shall be processed when necessary for the administration of justice or for the execution of a judicial act, or an act of another body or official, which is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data shall be processed when necessary for the performance of a contract to which the personal data subject is a party, a beneficiary, or a guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject, or a contract under which the personal data subject will be a beneficiary or a guarantor.
7.5. Personal data shall be processed when necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant objectives, provided that such processing does not violate the rights and freedoms of the personal data subject.
7.6. Personal data that have been made accessible to an unlimited number of persons by the personal data subject, or at their request, shall be processed (hereinafter referred to as “publicly available personal data”).
7.7. Personal data that are subject to publication or mandatory disclosure in accordance with federal law shall be processed.

8. Procedure for the Collection, Storage, Transfer, and Other Forms of 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 fully comply with the requirements of current legislation regarding the protection of personal data.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to such data.
8.2. A User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases required by applicable law, or where the data subject has provided consent to the Operator for the transfer of such data to a third party for the purpose of fulfilling obligations under a civil-law contract.
8.3. In the event that inaccuracies in personal data are identified, the User may update them by sending a notification to the Operator at the email address anry@doza.ru, with the subject line “Personal Data Update.”
8.4. The duration for which personal data is processed is determined by the time required to achieve the purposes for which the data was collected, unless a different period is specified by a contract or applicable law.
A User may withdraw their consent to the processing of their personal data at any time by sending a notification to the Operator via email at anry@doza.ru, with the subject line “Withdrawal of Consent for Personal Data Processing.”
8.5. All information collected by third-party services—including payment systems, communication providers, and other service providers—is stored and processed by said entities (Operators) in accordance with their own User Agreements and Privacy Policies. The data subject is responsible for reviewing such documents. The Operator bears no liability for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by a personal data subject regarding the transfer (excluding the provision of access to) of personal data, as well as restrictions on the processing—or conditions for the processing—of personal data authorized for dissemination (excluding the granting of access), shall not apply in cases where personal data is processed in the public, societal, or other interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the operator shall ensure the confidentiality of such data.
8.8. The operator shall store personal data in a form that allows for the identification of the personal data subject for no longer than is necessary for the purposes for which the data is processed, unless a different storage period is established by federal law or by a contract to which the personal data subject is a party, a beneficiary, or a guarantor.
8.9. The processing of personal data may be terminated upon the achievement of the purposes for which the data is processed, the expiration of the personal data subject’s consent, the withdrawal of such consent by the subject, a request to cease processing, or the discovery of unlawful personal data processing.

9. List of actions performed by the Operator with the personal data received
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, granting access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data, which may involve the receipt and/or transmission of the obtained information via information and telecommunication networks.

10. Cross-border transfer of personal data
10.1. Before commencing any cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfers (this notification shall be submitted separately from the notification regarding the intent to process personal data).
10.2. Prior to submitting the aforementioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, or from the foreign individuals or legal entities to whom the personal data is intended to be transferred.

11. Confidentiality of personal data
The Operator and any other parties who have gained access to personal data are obligated not to disclose such data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided for by federal law.

12. Final provisions
12.1. Users may obtain clarification on any questions regarding the processing of their personal data by contacting the Operator via email at anry@doza.ru.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. This policy remains in effect indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://anry.pro/privacy-policy/