Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152‑FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and Order No. 996 of Roskomnadzor dated 24.02.2021. It defines the procedure for processing personal data and the measures taken by Individual Entrepreneur Khitrov D. L. (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers it its most important goal and a prerequisite for carrying out its activities to respect the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy and to personal and family secrets.
1.2. This Operator’s Policy on Personal Data Processing (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://poehaliexpo.ru/eng
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to update 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 via the network address https://poehaliexpo.ru/eng.
2.4. Personal data information system — a combination of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymisation of personal data — actions as a result of which it becomes impossible to identify the owner of the personal data without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who, alone or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) to be performed with the personal data.
2.8. Personal data — any information directly or indirectly relating to a specific or identifiable user of the website https://poehaliexpo.ru/eng.
2.9. Personal data authorised by the data subject for distribution — personal data to which an unlimited number of persons have been granted access by the data subject by giving consent to the processing of personal data authorised for distribution, in accordance with the procedure provided for in the Personal Data Law (hereinafter referred to as “personal data authorised for distribution”).
2.10. User — any visitor to the website https://poehaliexpo.ru/eng.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the media, posting in information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross‑border transfer of personal data — transfer of personal data to the territory of a foreign state to a government 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 are permanently destroyed and cannot be recovered in the personal data information system and/or the physical media containing the personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
4. Main Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. Personal data processing shall be limited to achieving specific, predefined, and lawful purposes. Processing of personal data incompatible with the purposes for which the personal data were collected is not permitted.
5.3. Merging databases containing personal data that are processed for incompatible purposes is not permitted.
5.4. Only personal data that correspond to the purposes of their processing shall be processed.
5.5. The content and volume of the personal data being processed shall correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of processing shall not be processed.
5.6. During personal data processing, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than is required for the purposes of personal data processing, unless the retention period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymised upon achievement of the processing purposes or if there is no further need to achieve these purposes, unless otherwise provided for by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails.
Categories of data:
Types of personal data processing:
7. Conditions for Personal Data Processing
7.1. Personal data shall be processed with the consent of the data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties vested in the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court order, or an act of another body or official that is subject to enforcement in accordance with the enforcement proceedings legislation of the Russian Federation.
7.4. Personal data processing is necessary to perform a contract to which the data subject is a party, beneficiary, or guarantor, as well as to conclude a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant objectives, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out for personal data to which unrestricted access has been granted by the data subject or at their request (hereinafter referred to as “publicly available personal data”).
7.7. Processing is carried out for personal data that must be published or disclosed in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data
ProcessingThe security of the personal data processed by the Operator is ensured by implementing legal, organisational, 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 integrity of personal data and takes all possible measures to prevent unauthorised persons from accessing the personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to the Operator’s email address runningcool1340@gmail.com with the subject line “Updating Personal Data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator’s email address runningcool1340@gmail.com with the subject line “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, shall be stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject is obliged to familiarise themselves with these documents independently. The Operator shall not be liable for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions imposed by the data subject on the transfer (except for granting access), as well as on the processing or conditions for processing (except for obtaining access) of personal data authorised for distribution, shall not apply in cases of personal data processing in the state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during processing.
8.8. The Operator shall store personal data in a form that allows identification of the data subject for no longer than required for the purposes of personal data processing, unless the retention period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the processing purposes, expiration of the data subject’s consent, withdrawal of consent by the data subject or submission of a request to terminate processing, or identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Obtained Personal Data
9.1. The Operator performs the collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without obtaining and/or transferring the resulting information via information and telecommunications networks.
10. Cross‑Border Transfer of Personal Data
10.1. Before commencing activities involving the cross‑border transfer of personal data, the Operator is obliged to notify the authorised body for the protection of data subjects’ rights of its intention to carry out such transfer (this notification shall be submitted separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the government authorities of a foreign state, foreign individuals, or foreign legal entities to whom the cross‑border transfer of personal data is planned.
11. Use of Cookies and Web Analytics Tools
11.1. In order to improve the operation of the Website https://poehaliexpo.ru/eng, enhance user convenience, and collect statistical information, the Operator uses cookies (cookie files) and third‑party web analytics services (including Yandex.Metrica and similar automated systems).
11.2. Cookies are small pieces of data sent by the web server and stored on the User’s device (computer, mobile phone, tablet) when visiting the Website.
11.3. The Operator processes the following information obtained using cookies and web analytics systems:
11.5. The User may change their browser settings at any time to block the storage of cookies or to configure notifications about their sending. If cookies are disabled, certain Website functions may not work correctly or may become unavailable.
11.6. By continuing to use the Website without changing browser settings, the User expresses their consent to the processing of the above data using cookies and web analytics systems under the terms described in this Policy.
12. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided for by federal law.
13. Final Provisions
13.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at runningcool1340@gmail.com.
13.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
13.3. The current version of the Policy is freely available on the Internet at
Operator’s Details
Individual Entrepreneur Dmitri Lvovich Khitrov
TIN (Tax Identification Number): 773610888435
OGRNIP: 324774600537140
Address: Moscow, Mosfilmovskaya St., 11, bldg. 3, apt. 39
1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of Federal Law No. 152‑FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and Order No. 996 of Roskomnadzor dated 24.02.2021. It defines the procedure for processing personal data and the measures taken by Individual Entrepreneur Khitrov D. L. (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers it its most important goal and a prerequisite for carrying out its activities to respect the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy and to personal and family secrets.
1.2. This Operator’s Policy on Personal Data Processing (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://poehaliexpo.ru/eng
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to update 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 via the network address https://poehaliexpo.ru/eng.
2.4. Personal data information system — a combination of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Anonymisation of personal data — actions as a result of which it becomes impossible to identify the owner of the personal data without using additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who, alone or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) to be performed with the personal data.
2.8. Personal data — any information directly or indirectly relating to a specific or identifiable user of the website https://poehaliexpo.ru/eng.
2.9. Personal data authorised by the data subject for distribution — personal data to which an unlimited number of persons have been granted access by the data subject by giving consent to the processing of personal data authorised for distribution, in accordance with the procedure provided for in the Personal Data Law (hereinafter referred to as “personal data authorised for distribution”).
2.10. User — any visitor to the website https://poehaliexpo.ru/eng.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the media, posting in information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross‑border transfer of personal data — transfer of personal data to the territory of a foreign state to a government 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 are permanently destroyed and cannot be recovered in the personal data information system and/or the physical media containing the personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
- obtain reliable information and/or documents containing personal data from the data subject;
- continue processing personal data without the data subject’s consent if the data subject revokes consent to process personal data or submits a request to terminate processing, provided there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for in the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.
- provide the data subject, upon request, with information regarding the processing of their personal data;
- organise the processing of personal data in accordance with the current legislation of the Russian Federation;
- respond to requests and appeals from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorised body for the protection of data subjects’ rights with the necessary information within 10 days from the date of receipt of such a request;
- publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
- take legal, organisational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions regarding personal data;
- terminate the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for in the Personal Data Law;
- fulfil other obligations provided for in the Personal Data Law.
4. Main Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the data subject by the Operator in an accessible form and shall not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- request that the Operator clarify, block, or destroy their personal data if the data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
- impose a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
- withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
- appeal against unlawful actions or inaction of the Operator in the processing of their personal data to the authorised body for the protection of data subjects’ rights or to a court;
- establish prohibitions on the transfer (except for granting access) of personal data authorised by the data subject for distribution to an unlimited number of persons, as well as conditions and prohibitions on the processing (except for obtaining access) of such personal data;
- request the termination of the transfer (distribution, provision, access) of personal data previously authorised for distribution at any time (consent shall be deemed withdrawn from the moment the Operator receives the corresponding request);
- exercise other rights provided for by the legislation of the Russian Federation.
- provide the Operator with reliable data about themselves;
- inform the Operator about the clarification (updating, modification) of their personal data.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. Personal data processing shall be limited to achieving specific, predefined, and lawful purposes. Processing of personal data incompatible with the purposes for which the personal data were collected is not permitted.
5.3. Merging databases containing personal data that are processed for incompatible purposes is not permitted.
5.4. Only personal data that correspond to the purposes of their processing shall be processed.
5.5. The content and volume of the personal data being processed shall correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of processing shall not be processed.
5.6. During personal data processing, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than is required for the purposes of personal data processing, unless the retention period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymised upon achievement of the processing purposes or if there is no further need to achieve these purposes, unless otherwise provided for by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails.
Categories of data:
- surname, name, patronymic;
- email address;
- phone numbers;
- year, month, date, and place of birth.
Types of personal data processing:
- collection, recording, systematisation, accumulation, storage, destruction, and anonymisation of personal data;
- sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data shall be processed with the consent of the data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties vested in the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court order, or an act of another body or official that is subject to enforcement in accordance with the enforcement proceedings legislation of the Russian Federation.
7.4. Personal data processing is necessary to perform a contract to which the data subject is a party, beneficiary, or guarantor, as well as to conclude a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant objectives, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out for personal data to which unrestricted access has been granted by the data subject or at their request (hereinafter referred to as “publicly available personal data”).
7.7. Processing is carried out for personal data that must be published or disclosed in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data
ProcessingThe security of the personal data processed by the Operator is ensured by implementing legal, organisational, 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 integrity of personal data and takes all possible measures to prevent unauthorised persons from accessing the personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to the Operator’s email address runningcool1340@gmail.com with the subject line “Updating Personal Data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator’s email address runningcool1340@gmail.com with the subject line “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, shall be stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject is obliged to familiarise themselves with these documents independently. The Operator shall not be liable for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions imposed by the data subject on the transfer (except for granting access), as well as on the processing or conditions for processing (except for obtaining access) of personal data authorised for distribution, shall not apply in cases of personal data processing in the state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data during processing.
8.8. The Operator shall store personal data in a form that allows identification of the data subject for no longer than required for the purposes of personal data processing, unless the retention period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the processing purposes, expiration of the data subject’s consent, withdrawal of consent by the data subject or submission of a request to terminate processing, or identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Obtained Personal Data
9.1. The Operator performs the collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without obtaining and/or transferring the resulting information via information and telecommunications networks.
10. Cross‑Border Transfer of Personal Data
10.1. Before commencing activities involving the cross‑border transfer of personal data, the Operator is obliged to notify the authorised body for the protection of data subjects’ rights of its intention to carry out such transfer (this notification shall be submitted separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the government authorities of a foreign state, foreign individuals, or foreign legal entities to whom the cross‑border transfer of personal data is planned.
11. Use of Cookies and Web Analytics Tools
11.1. In order to improve the operation of the Website https://poehaliexpo.ru/eng, enhance user convenience, and collect statistical information, the Operator uses cookies (cookie files) and third‑party web analytics services (including Yandex.Metrica and similar automated systems).
11.2. Cookies are small pieces of data sent by the web server and stored on the User’s device (computer, mobile phone, tablet) when visiting the Website.
11.3. The Operator processes the following information obtained using cookies and web analytics systems:
- the User’s device IP address;
- data about the User’s equipment (device type, model, screen resolution, operating system version);
- data about the web browser (type, version, installed plugins);
- date, time, and duration of the session;
- addresses of requested pages and sources of referral to the Website;
- geographical location (at the country and city level);
- behavioural factors (clicks, cursor movements, page views).
11.5. The User may change their browser settings at any time to block the storage of cookies or to configure notifications about their sending. If cookies are disabled, certain Website functions may not work correctly or may become unavailable.
11.6. By continuing to use the Website without changing browser settings, the User expresses their consent to the processing of the above data using cookies and web analytics systems under the terms described in this Policy.
12. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided for by federal law.
13. Final Provisions
13.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at runningcool1340@gmail.com.
13.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
13.3. The current version of the Policy is freely available on the Internet at
Operator’s Details
Individual Entrepreneur Dmitri Lvovich Khitrov
TIN (Tax Identification Number): 773610888435
OGRNIP: 324774600537140
Address: Moscow, Mosfilmovskaya St., 11, bldg. 3, apt. 39