Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter, the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Ivan Sergeevich Mikhailov (hereinafter, the Operator) to ensure the security of personal data.

1.1. The Operator considers respect for the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy and personal and family confidentiality, to be its most important objective and a prerequisite for its activities.

1.2. This Operator's Personal Data Processing Policy (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website https://dete-bg.com.

2. Key Terms Used in the Policy

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

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify personal data.

2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, that make them available on the Internet at the network address https://dete-bg.com.

2.4. Personal data information system means a set of personal data contained in databases and the information technologies and technical means used to process such data.

2.5. Depersonalization of personal data means actions that make it impossible, without additional information, to determine that personal data belongs to a specific User or other personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out personal data processing and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://dete-bg.com.

2.9. Personal data authorized by the personal data subject for distribution means personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure provided for by the Personal Data Law (hereinafter, personal data authorized for distribution).

2.10. User means any visitor to the website https://dete-bg.com.

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

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including publication of personal data in the media, placement in information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed so that the content of personal data cannot subsequently be restored in the personal data information system and/or physical media containing personal data are destroyed.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

obtain from the personal data subject reliable information and/or documents containing personal data;
if the personal data subject withdraws consent to personal data processing or submits a request to stop personal data processing, the Operator may continue to process personal data without the consent of the personal data subject where grounds specified in the Personal Data Law exist;
independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations provided for by the Personal Data Law and regulations adopted pursuant to 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, upon request, with information concerning the processing of their personal data;
organize personal data processing in accordance with the procedure 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;
provide the authorized body for the protection of personal data subjects' rights, at that body's request, with the necessary information within 10 days from the date such request is received;
publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions involving 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;
perform other obligations provided for by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator to the personal data subject in an accessible form and must not contain personal data relating to other personal 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;
require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
require prior consent as a condition for processing personal data for the purpose of promoting goods, works, and services in the market;
withdraw consent to personal data processing and submit a request to stop personal data processing;
appeal to the authorized body for the protection of personal data subjects' rights or to a court against unlawful actions or inaction of the Operator when processing their 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 information about themselves;
inform the Operator of any clarification (update or change) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes for which the personal data was collected is not permitted.

5.3. Databases containing personal data processed for mutually incompatible purposes may not be combined.

5.4. Only personal data that meets the purposes of its processing may be processed.

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

5.6. When personal data is processed, the accuracy and sufficiency of personal data and, where necessary, its relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that such measures are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows the personal data subject to be identified no longer than required by the purposes of personal data processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized once the purposes of processing have been achieved or when there is no longer a need to achieve those purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: informing the User by sending emails

Personal data

philosophical beliefs

Legal grounds

Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”

Types of personal data processing

Transfer of personal data

7. Conditions for Personal Data Processing

7.1. Personal data is processed with the consent of the personal 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, and to perform the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.

7.3. Personal data processing is necessary for the administration of justice or enforcement of a judicial act or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary for performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding 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. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data is processed where the personal data subject, or at their request, has provided access to an unlimited number of persons (hereinafter, publicly available personal data).

7.7. Personal data subject to publication or mandatory disclosure under federal law is processed.

8. Procedure for Collecting, Storing, Transferring, and Other 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 on personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

8.2. Under no circumstances will the User's personal data be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has consented to the Operator transferring data to a third party for performance of obligations under a civil-law contract.

8.3. If inaccuracies are identified in personal data, the User may update them independently by sending a notification to the Operator's email address support-games@dete-bg.com marked “Personal Data Update”.

8.4. The period of personal data processing is determined by achievement of the purposes for which the personal data was collected, unless another period is provided for by a contract or current legislation.

The User may withdraw consent to personal data processing at any time by sending the Operator a notification by email to support-games@dete-bg.com marked “Withdrawal of Consent to Personal Data Processing”.

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

8.6. Restrictions imposed by the personal data subject on transfer (except providing access), as well as on processing or processing conditions (except obtaining access), of personal data authorized for distribution do not apply where personal data is processed in state, public, or other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing it.

8.8. The Operator stores personal data in a form that allows the personal data subject to be identified no longer than required by the purposes of personal data processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Personal data processing may be terminated upon achievement of the purposes of personal data processing, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject or a request to stop processing personal data, as well as upon detection of unlawful personal data processing.

9. List of Actions Performed by the Operator with the Personal Data Received

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the information obtained via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before beginning activities involving the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights of its intention to carry out cross-border transfer of personal data (this notification is sent separately from the notification of intent to process personal data).

10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data must not disclose personal data to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator by email at support-games@dete-bg.com.

12.2. This document will reflect any changes to the Operator's Personal Data Processing Policy. The Policy remains in force indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://dete-bg.com/privacy/.