Privacy Policy Regarding the Processing of Personal Data1. General ProvisionsThis Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152‑FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the “Personal Data Law”) and establishes the procedure for processing personal data and the measures taken by Vadim Moiseevich Abramov (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the respect for the rights and freedoms of individuals during personal data processing—including the protection of private life, personal and family secrets—as a paramount goal and a fundamental condition of its activity.
1.2. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the website
https://vadimabramoffmusic.com.
2. Key Definitions Used in the Policy2.1. Automated personal data processing – processing using computer technology.
2.2. Blocking of personal data – temporary suspension of processing (except when needed to clarify the data).
2.3. Website – a set of graphic and informational materials, as well as software and databases, accessible online at
https://vadimabramoffmusic.com.
2.4. Personal Data Information System – a set of databases containing personal data and the technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions making it impossible to identify the specific user without additional information.
2.6. Personal data processing – any action or set of actions with personal data, automated or otherwise, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction.
2.7. Operator – a government body, municipal entity, legal or natural person, alone or jointly organizing and/or performing personal data processing, and determining the purposes, content, and scope of processing.
2.8. Personal data – any information directly or indirectly relating to an identified or identifiable visitor of the website.
2.9. Personal data made publicly available by the data subject – data to which the subject has given unrestricted access via consent in accordance with the Personal Data Law.
2.10. User – any visitor to
https://vadimabramoffmusic.com.
2.11. Provision of personal data – disclosure of personal data to a specific person or group.
2.12. Distribution of personal data – disclosure to an undefined group or general public, including publication in media, telecommunication networks, or other means.
2.13. Cross-border transfer of personal data – transfer to a foreign country’s authority, individual, or legal entity.
2.14. Destruction of personal data – irreversible actions destroying data in an information system or material media without possibility of recovery.
3. Operator’s Basic Rights and Obligations3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the data subject;
— continue processing personal data without consent if the subject revokes consent but legal grounds permit continued processing under the Personal Data Law;
— independently determine necessary measures to fulfill obligations under the law, unless otherwise provided by law.
3.2. The Operator must:
— provide the data subject, upon request, with information about data processing;
— organize processing in compliance with Russian legislation;
— respond to subject requests in accordance with law;
— submit requested information to the authorized personal data protection agency within 10 days;
— publish or otherwise ensure unlimited access to this Policy;
— implement legal, organizational, and technical measures to protect data from unauthorized access and unlawful actions;
— cease transfer or processing and destroy data in accordance with the Personal Data Law;
— fulfill other obligations as per the law.
4. Basic Rights and Obligations of Data Subjects4.1. Data subjects have the right to:
— receive information about their personal data processing, except where restricted by law;
— request clarification, blocking, or destruction of inaccurate, outdated, illegally obtained, or unnecessary data;
— impose conditions for consent when data is processed for marketing;
— revoke consent or demand cessation of processing;
— appeal unlawful actions or inaction by the Operator to the authorized agency or a court;
— exercise other rights under Russian law.
4.2. Data subjects must:
— provide accurate personal data;
— inform the Operator of any updates or changes.
4.3. Persons providing false data or data about others without consent bear liability under Russian law.
5. Principles of Personal Data Processing5.1. Processing must be lawful and fair.
5.2. Processing should be limited to specific, lawful purposes.
5.3. Databases with incompatible purposes should not be merged.
5.4. Only data relevant to stated purposes should be processed.
5.5. The content and volume of data should match processing objectives; excessive data is not permitted.
5.6. Accuracy and relevance should be ensured and corrected as needed.
5.7. Data retention must not exceed what's necessary for processing purposes, and must comply with law; after which data is destroyed or anonymized.
6. Purposes of Personal Data ProcessingPurpose | Data Collected | Legal Basis | Processing Type |
Informing users via email | Surname, first name, patronymic, email address | Charter documents of the Operator | Sending informational emails |
7. Conditions for Processing7.1. Processing is carried out with data subject consent.
7.2–7.5. Processing may also be based on international treaties, execution of legal obligations, contract performance, protection of legal interests, and public interest, provided rights and freedoms are not violated.
7.6–7.7. Publicly disclosed or legally required data may be processed.
8. Procedure for Collection, Storage, Transfer, etc.Data security is ensured through legal, organizational, and technical measures.
8.1. The Operator protects data from unauthorized access.
8.2. Data will not be shared with third parties except as required by law or with the subject’s consent under a civil-law contract.
8.3. Users may update their data by emailing
ART@VADIMABRAMOFF.DE with the subject “Updating Personal Data.”
8.4. Retention depends on processing purposes, contractual or legal terms. Consent may be withdrawn at any time via email with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. Information collected by third-party services (payment systems, communication providers, etc.) is handled in accordance with their user agreements and privacy policies; the Operator is not responsible for their actions.
8.6. Restrictions imposed by subjects on processing consensually public data do not apply when data is processed in public interest as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. Data is stored only as long as necessary for processing purposes unless otherwise required by law or contract.
8.9. Processing ceases upon achieving purposes, consent expiry or withdrawal, a cessation request, or unlawful processing.
9. List of Operations Performed by the Operator9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, anonymization, blocking, deletion, and destruction.
9.2. Automated processing may involve information transmission via telecommunications or otherwise.
10. Cross-Border Data Transfer10.1. Before initiating cross-border transfer, the Operator must notify the authorized personal data protection agency separately from its general processing notification.
10.2. Before notification, the Operator must obtain relevant information from foreign authorities or entities receiving the data.
11. Confidentiality of Personal DataThe Operator and any persons granted access must not disclose or distribute personal data to third parties without consent, unless required by federal law.
12. Concluding Provisions12.1. Users may request clarification regarding personal data processing via email at
ART@VADIMABRAMOFF.DE.
12.2. Any changes to this Policy will be published. The Policy remains in effect indefinitely until replaced.
12.3. The current version is publicly available at
https://vadimabramoffmusic.com/privacy.
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