1.1. This Policy defines the procedure of personal data processing and measures of ensuring security of personal data published on the website at: www.ony.ru (hereinafter - the Website), which the operator, as well as visitors and users of the Website (within the limits allowed by the policy and complex of services of the Website) may receive about a user in course of using the Website, its services, programs and products in order to protect human and civil rights and freedoms when processing their personal data, including privacy rights protection. The Policy has been developed in accordance with the legislation of the Russian Federation in the field of personal data.
1.2. This Policy applies solely to the Website. The Operator does not control and is not responsible for third-party sites, which a User can reach through the links available on the Site.
1.3. The Operator's processing of personal data of other categories of personal data subjects is regulated by other local acts of the Operator.
1.4. This Policy comes into force from the moment of its approval, namely from 14 june 2022 and is valid for unlimited term, until it is replaced by a new Policy.
2.1. The following terms are used in this Policy:
2.1.1 Information system of personal data means a set of personal data and information technologies and technical means providing its processing, contained in databases.
2.1.2 Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.1.3. Depersonalization of personal data - actions, as a result of which it is impossible to determine without the use of additional information what personal data belongs to a particular user or other subject of personal data.
2.1.4. Personal data operator (operator) - Studio "ONY", Limited Liability Company (OGRN 1057747678890), including authorized employees of the Website management, acting on behalf of Studio "ONY" LLC, who organize and/or conduct personal data processing, as well as determine personal data processing purposes, composition of personal data subject to processing, actions (operations) performed with personal data;
2.1.5 Personal data - any information relating to a directly or indirectly identified or identifiable individual (personal data subject);
2.1.6. Website User (also User) - any person visiting the Website and using the information, materials and services of the Website.
2.1.7. Cookies - is a small piece of data, sent by a web-server and stored on the User's computer, which a web-client or a web-browser sends to a web-server in HTTP-request every time it tries to open a page of a corresponding site.
2.1.8. IP-address - the unique network address of the node in a computer network, through which the User gets access to the Site.
2.1.9 Website is an interactive service owned by the Owner, available at the unique address in the Internet www.ony.ru/.
2.1.10 “Owner” - Studio "ONY", Limited Liability Company (Moscow 123060, Marshala Rybalko str, 2, bld. 6, floor 11, place I, room 28, office 5), as well as its subsidiary and affiliated companies.
3.1. The legal basis for processing of personal data by the Operator/Owner are:
3.2. Users of the Site give their consent to processing of their personal data in the following cases:
3.3. If a User does not agree with the terms of this Policy, the use of the Site must be immediately terminated.
3.4. Personal information about Users of the Website is processed for the following purposes:
The User can always refuse to receive information messages by sending a letter to the Operator to the address firstname.lastname@example.org with the note "Refuse of notifications about new products and services and special offers".
3.5. The list of personal data of Users processed on the Site using automation tools:
3.6. To maintain statistics and analysis of the Website, the Operator processes with the use of the metric services Google Analytics and Yandex Metrika such data as:
3.7. The anonymized data of the Users, collected with the help of Internet statistics services, serves for collecting information about the User's actions on the Website, improving the quality of the Website and its content.
3.10. The processing of biometric personal data and special categories of personal data related to race, ethnicity, political views, religious or philosophical beliefs, health, intimate life is not carried out on the Website.
3.11. The operator doesn't check the reliability of the information provided by the User and assumes that the User provides reliable and sufficient information, controls its relevance.
3.12. The operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), blocking, removal, destruction.
3.13. Personal data shall be stored in a form that allows to identify the subject of personal data no longer than required by the purposes of personal data processing.
3.14. The condition for termination of personal data processing may be the achievement of the objectives of personal data processing, the expiration of the period of personal data processing, withdrawal of the Website user's consent to the processing of their personal data, as well as the detection of unlawful processing of personal data.
3.15. The term of storage of personal data of the Website Users is 5 years from the date of the last dispatch of data.
3.16. The period of processing of personal data is unlimited. The User may withdraw their consent to the processing of personal data at any time by sending a notice via e-mail to the Operator's e-mail address email@example.com with the note "Withdrawal of consent to the processing of personal data".
3.17. The User consents to receive sms, as well as other types of newsletters and notifications of informational nature (oral and written) from the Operator/Owner using any means of communication, including, but not limited to the following: email, phone, mailings. This consent is valid from the date of User registration on the Website. This consent may be withdrawn by the User at any time by sending a notice by email to firstname.lastname@example.org. Taking into account that this consent is necessary for the proper functioning of the Website, the User has the right to limit the access to the Website in case of withdrawal of the consent under this paragraph. The User gives their consent to receive text messages as well as other types of newsletters and notifications of advertising nature (oral and written) from the Operator/Owner using any means of communication, including, but not limited to the following: email, phone, mailings. The present consent is valid from the date of registration of the User on the Website/date of providing personal data. In this regard, the Operator/Owner assumes that when providing personal data on the Website the User:
4.1. Safety of personal data, processed by the Operator, is provided by implementation of legal, organizational, technical and software measures, necessary and sufficient for ensuring the requirements of the legislation of the Russian Federation.
4.2. Personal data of the User won't be transferred by the Operator to the third parties, except the cases, connected with fulfillment of the current legislation.
4.3. The operator takes the following measures to ensure the security of personal data:
5.1. The Website User has the right to receive information regarding the processing of his personal data, including
5.2. The User is entitled to demand from the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect his rights.
5.3. All questions regarding the processing of personal data should be reported to email@example.com.
6.1. The User is fully responsible for compliance with the requirements of the current legislation of the Russian Federation, including, but not limited to, the laws on advertising, on the protection of copyright and related rights, the protection of trademarks and service marks, including full responsibility for the content and form of materials, in case of quoting or otherwise using the information obtained in connection with the use of the Website complex services.
7.1 The operator processes personal data on the basis of the following principles:
7.2. The Operator carries out processing of personal data of Users (recording, systematization, accumulation, storage, clarification (update, change), extraction) with the use of databases on the territory of the Russian Federation.
7.3. Processing of personal data of Users is carried out by the Operator both with and without the use of automated means.
7.4. The Operator and other persons who obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
7.5. Personal data shall be stored during the period established by the legislation of the Russian Federation on education and archiving. The storage of personal data is carried out (depending on which event comes first)
7.6. The Operator has the right to transfer personal data in accordance with the requirements of the legislation of the Russian Federation or the consent of the subject of personal data processing to third parties, namely:
7.6.1 Partners, such as owners of sites and applications, advertising networks and other partners providing the Operator with services related to the placement and display of advertising on websites, programs, products or services owned or controlled by such partners;
7.6.2. Partners attracted by the Operator to provide services to the Users on the platform at www.ony.ru.
7.6.3. to Partners for providing the Users with specialized offers for conclusion of civil law contracts;
7.7. Transfer of personal data to third parties specified in paragraph 7.6 of the Policy is carried out under the following conditions:
8.1. The User of personal data has the right to demand from the Operator the clarification of their personal data, their blocking or destruction, if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights.
8.2. If the Personal Data User withdraws its consent to the processing of its personal data, the Operator shall discontinue the processing of personal data or ensure its cessation and, if the preservation of personal data is no longer required for the purposes of personal data processing, destroy personal data or ensure its destruction within a period not exceeding thirty days from the date of receipt of the said withdrawal.
8.3. If it is not possible to destroy personal data within the period specified in paragraphs 8.4, 8.5, 8.6 of this Policy, the Operator shall block such personal data or ensure the destruction of personal data within a period not exceeding six months, unless otherwise provided by federal laws.
8.4. Users' Requests:
8.4.1 Users shall be entitled to send their requests to the Operator, including requests regarding the use of their personal data under paragraph 8.1. of this Policy, in the form of an electronic document to the e-mail address: firstname.lastname@example.org.
8.4.2 The Operator undertakes to review and respond to the user's request within 30 days from the receipt of the request.
8.5. All correspondence received by the Operator from Users (requests in the electronic form) belongs to the information of limited access and is not disclosed without the written consent of the User. Personal data and other information about the User, who sent an inquiry, can't be used without the User's special consent, except for answering the question of the received inquiry or in cases, which are directly stipulated by the legislation.
9.1. The Operator shall have the right to amend this Policy unilaterally in case of changes in the regulatory legal acts of the Russian Federation, as well as at its own discretion.
9.2. Control of compliance with the requirements of this Policy shall be carried out by the person responsible for organizing the processing of personal data.
9.3. Persons guilty of violating the rules governing the processing and protection of personal data shall bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by the laws of the Russian Federation.
Studio "ONY" Limited Liability Company