PERSONAL DATA PROCESSING POLICY
1. General Provisions
This personal data processing policy has been compiled 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) and defines the personal data processing procedures and measures to ensure the security of personal data taken by Sole Proprietor Epremian Satenik Zhorovna (OGRNIP 321784700084380,
TIN 780109538125) (hereinafter referred to as the Operator).
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 protecting the rights to privacy, personal and family secrets.
1.2. This Operator 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://o-n-a.art

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 is the temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. A website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://o-n-a.art
2.4. An information system of personal data is a collection of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data means actions that make it impossible to determine, without the use of additional information, the attribution of personal data to a specific User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automated tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator means 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 processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the website https://o-n-a.art.
2.9. Personal data permitted for distribution by the personal data subject – personal data, access to which by the general public is granted by the personal data subject by consenting to the processing of personal data, permitted for distribution by the personal data subject in the manner prescribed by the Law on Personal Data (hereinafter, personal data permitted for distribution).
2.10. User – any visitor to the website https://o-n-a.art.
2.11. Provision of personal data – actions aimed at disclosing 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 making personal data available to an indefinite number of persons, including publishing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a foreign government agency, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently 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.
2.15. Personal data subject – any individual possessing the relevant personal data.
2.16. Categories of data subjects – subjects who are in contractual or other civil-law relations with the Operator, planning to conclude contracts or use the Operator’s services, and website visitors.

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 personal data subject;
– if the personal data subject revokes their consent to the processing of personal data, the Operator has the right to continue processing the personal data without the personal data subject's consent, provided there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations stipulated 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 obligated to:
– provide the personal data subject, upon request, with information regarding the processing of their personal data;
– organize the processing of personal data in accordance with the current legislation of the Russian Federation;
– respond to inquiries and requests from personal data subjects 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 personal data subjects, upon request, of the necessary information within ten business days of receipt of such request. This period may be extended, but not more than by five business days, if the operator sends a reasoned notice to the authorized body for the protection of the rights of personal data subjects, stating the reasons for the extension of the deadline for providing the requested information.;
– publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
– cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
– fulfill other obligations stipulated by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
– receive information regarding the processing of their personal data, except in cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data related to other personal data subjects, 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 Law on Personal Data;
– request that the Operator clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures stipulated by law to protect their rights;
– require prior consent when processing personal data for the purpose of promoting goods, works, and services;
– revoke consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator's unlawful actions or inactions in the processing of their personal data;
– exercise other rights provided for by Russian Federation law.
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. Persons who provide the Operator with inaccurate information about themselves or about another personal data subject without the latter's consent shall be liable in accordance with Russian Federation law.

5. The Operator may process the following personal data of the User:
5.1.
- Last name, first name, patronymic.
- Email address
- Telephone numbers
- Bank details
- Link to personal page on social media
5.2. The website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.3. The above data is hereinafter collectively referred to as "Personal Data."
5.4. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.5. The processing of personal data permitted for distribution, from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data, is permitted if the prohibitions and conditions stipulated in Article 10 are observed. 10.1 of the Personal Data Law.
5.6. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents for the processing of their personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.6.1 The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
5.6.2 The Operator is obliged, no later than three business days from the receipt of the User's consent, to publish information on the processing conditions, any prohibitions, and conditions for the processing of personal data permitted for distribution by an unlimited number of persons.
5.6.3 The transfer (distribution, provision, access) of personal data permitted for distribution by the personal data subject must be terminated at any time upon the request of the personal data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of the personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is addressed.
5.6.4 Consent to the processing of personal data permitted for distribution terminates upon receipt by the Operator of the request specified in the revocation of consent to the processing of personal data.

6. Principles of Personal Data Processing
6.1. Personal data shall be processed lawfully and fairly.
6.2. Personal data shall be processed only to achieve specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes for which it was collected is prohibited.
6.3. Databases containing personal data processed for incompatible purposes shall not be combined.
6.4. Only personal data that is relevant to the purposes for which it is processed shall be processed.
6.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Processed personal data shall not be excessive in relation to the stated purposes of processing.
6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes for which it is processed shall be ensured. The Operator shall take the necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identification of the data subject for no longer than required for the purposes of processing the personal data, unless the storage period is established by federal law or an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon the achievement of the processing purposes or when these purposes are no longer necessary, unless otherwise provided by federal law.

7. Purposes of Processing Personal Data
7.1. Purpose of Processing the User's Personal Data:
- Informing the User via email;
- Concluding, executing, and terminating civil contracts;
- Providing the User with access to services, information, and/or materials contained on the website https://o-n-a.art
- Collection and processing of anonymized data (including cookies) about visitors using internet statistics services. Categories of Personal Data: Data that is automatically transmitted depending on software settings, including, but not limited to: IP address, individual device network number (MAC address, device IC), electronic serial number (IMEI, MEID), cookies, information about the browser or other software used to access the Services, and the operating system; date and time of access to the Services; Collection and processing of anonymized visitor data (including cookies) using Yandex Metrica internet statistics services metrika.yandex.ru
- Categories of subjects whose personal data is processed: website visitors
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always unsubscribe from receiving informational messages by sending an email to the Operator at muse4.ru@gmail.com with the subject line "Unsubscribe from notifications about new products, services, and special offers."
7.3. Anonymized User data collected using internet statistics services is used to collect information about User actions on the website and to improve the quality of the website and its content.

8. Legal Basis for Processing Personal Data
8.1. The legal basis for processing personal data by the Operator are:
- The Civil Code of the Russian Federation;
- Federal Law "On Information, Information Technology, and Information Protection" dated July 27, 2006 No. 149-FZ;
- Resolution of the Government of the Russian Federation dated November 1, 2012 No. 1119 "On Approval of Requirements for the Protection of Personal Data When Processed in Personal Data Information Systems";
- Resolution of the Government of the Russian Federation dated September 15, 2008 No. 687 "On Approval of the Regulation on the Specifics of Processing Personal Data Carried Out Without the Use of Automation";
- Order of Roskomnadzor dated September 5, 2013 No. 996 "On Approval of Requirements and Methods for Depersonalizing Personal Data";
- Order of the Federal Service for Technical and Export Control of Russia dated February 18, 2013, No. 21 "On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data When Processed in Personal Data Information Systems";
- Other federal laws, as well as bylaws governing the processing of personal data;
- Local legal acts governing the processing of personal data;
- Consent to the processing of personal data;
- Agreements concluded between the Operator and the personal data subject (User).
8.2. The Operator processes the User's personal data only if the User completes and/or submits it independently through special forms located on the website https://o-n-a.art or sent to the Operator via email. By completing the relevant forms and/or submitting their personal data to the Operator, the User consents to this Policy.
8.3. 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).
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own free will, and in their own interests.

9. Terms of Personal Data Processing
9.1. Personal data shall be processed with the consent of the data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, or to exercise the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or the act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of an agreement to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement at the initiative of the data subject or an agreement under which the data subject will be a beneficiary or guarantor.
9.5. The 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 data subject are not violated in the process.
9.6. The processing of personal data is performed only if access to it is granted to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. The processing of personal data is performed only if it is subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data
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.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has consented to the Operator's transfer of data to a third party for the fulfillment of obligations under a civil law contract.
10.3. If inaccuracies are discovered in personal data, the User may update it independently by sending a notification to the Operator's email address project@o-n-a.art with the subject line "Updating personal data."
10.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to project@o-n-a.art with the subject "Revocation of consent to the processing of personal data."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User are obligated to review these documents promptly. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. Prohibitions on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for dissemination, established by the personal data subject, shall not apply in cases where personal data is processed in the state, public, or other public interests defined by Russian Federation law.
10.7. The Operator shall ensure the confidentiality of personal data when processing personal data.
10.8. The Operator shall store personal data in a form that allows identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor.
10.9. Termination of personal data processing may be conditional on the achievement of the personal data processing purposes, expiration of the personal data subject's consent or revocation of consent by the personal data subject, or the detection of unlawful processing of personal data.
10.10. If a personal data subject requests the Operator to cease processing personal data within a period not exceeding 10 business days from the date the Operator receives the corresponding request, the processing of the personal data will cease, except in cases stipulated by the Personal Data Law. This period may be extended, but not more than by five business days. To do so, the Operator must send the personal data subject a reasoned notice stating the reasons for the extension.
10.11. When collecting personal data, including via the Internet, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), and retrieval of personal data of citizens of the Russian Federation using databases located within the Russian Federation, except in cases stipulated by the Personal Data Law.

11. List of actions performed by the Operator with received personal data:
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.
11.3. If the Operator, Roskomnadzor, or another interested party detects an unauthorized or accidental transfer (provision, distribution) of personal data (access to personal data) that results in a violation of the rights of personal data subjects, the Operator:
- within 24 hours - notifies Roskomnadzor of the incident, the presumed causes that led to the violation of the rights of personal data subjects, the presumed harm caused to the rights of personal data subjects, and the measures taken to eliminate the consequences of the incident, and also provides information about the person authorized by the Operator to interact with Roskomnadzor on matters related to the incident;
- within 72 hours - notifies Roskomnadzor of the results of the internal investigation of the identified incident and provides information about the persons whose actions caused it (if any).
11.4. Procedure for the Destruction of Personal Data by the Operator.
11.4.1. Conditions and deadlines for destruction of personal data by the Operator:
- the purpose of personal data processing has been achieved or the need to achieve this purpose has ceased to be necessary - within 30 days;
- the maximum retention periods for documents containing personal data have been reached - within 30 days;
- the personal data subject (or their representative) provides confirmation that the personal data was obtained illegally or is not necessary for the stated processing purpose - within seven business days - revocation
11.5. Upon achievement of the purpose of personal data processing, as well as in the event of the personal data subject's consent to its processing, personal data shall be destroyed unless:
- otherwise provided by an agreement to which the personal data subject is a party, beneficiary, or guarantor;
- the Operator may not process personal data without the consent of the personal data subject on the grounds stipulated by the Personal Data Law or other federal laws;
- otherwise provided by another agreement between the Operator and the personal data subject.
11.6. Personal data destruction is carried out in the following manner:
– For paper personal data carriers – cutting, hydroprocessing, incineration, or mechanical destruction.
– For electronic personal data carriers – permanent erasure on the device, physical destruction of the microchips or disk.
11.7. The fact of destruction is documented in a report.

12. Information on Ensuring the Security of Personal Data in Compliance with the Personal Data Protection Requirements Established by the Government of the Russian Federation
12.1. The Operator has implemented the following measures:
- Storage locations for personal data (physical media) have been identified.
- Separate storage of personal data (physical media) processed for various purposes has been ensured. Physical media accounting has been ensured. Information security tools designed to ensure the security of personal data during its processing in information systems are in place.
- The possibility of unauthorized entry or presence of unauthorized persons in premises where personal data is processed is excluded.
- The safety of personal data storage devices and information security tools has been ensured.
- Identification of threats to the security of personal data during its processing in personal data information systems;
- Application of organizational and technical measures to ensure the security of
- Personal data during its processing in personal data information systems, necessary to meet the personal data protection requirements, the implementation of which ensures the levels of personal data protection established by the Government of the Russian Federation;
- Use of information security tools that have undergone the established compliance assessment procedure;
- Assessing the effectiveness of measures taken to ensure personal data security prior to the commissioning of the personal data information system;
- Maintaining records of personal data on machine-readable media;
- Detecting instances of unauthorized access to personal data and taking measures to prevent similar incidents in the future;
- Restoring personal data modified or destroyed due to unauthorized access;
- Establishing rules for accessing personal data processed in the personal data information system, as well as ensuring the registration and accounting of all actions performed with personal data in the personal data information system;
- Monitoring the measures taken to ensure the security of personal data and the level of protection of personal data information systems.
12.2. Protective Tools Used by the Operator:
- The Operator uses anti-virus information protection tools, user identification and authentication when logging into the information system using a temporary password of at least six alphanumeric characters; availability of tools to restore the personal data protection system.

13. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final Provisions
14.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Operator by email at project@o-n-a.art.
14.2. This document will reflect any changes to the Operator's personal data processing policy. This policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is publicly available online at https://o-n-a.art/privacy-policy-eng.