1. General Provisions
This Personal Data Processing Policy is drafted 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 procedure for processing personal data and the measures taken by Nikita Alexandrovich Nebukin (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy, personal and family secrets, as its highest priority and essential condition for carrying out its activities.
1.2. This Policy applies to all information that the Operator may receive about visitors to the website http://fracturedsquare.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing using computing equipment.
2.2. Blocking of personal data — temporary suspension of data processing (except where processing is necessary to clarify data).
2.3. Website — a combination of graphic and information content, software, and databases accessible online at http://fracturedsquare.com.
2.4. Personal data information system — a set of personal data contained in databases and technology enabling their processing.
2.5. Depersonalization of personal data — actions that make it impossible to identify a data subject without additional information.
2.6. Processing of personal data — any operation or set of operations performed with or without automation on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
2.7. Operator — a state or municipal authority, legal or physical person that processes personal data and determines the purposes, scope, and operations performed with the data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website http://fracturedsquare.com.
2.9. Personal data permitted for dissemination by the subject — data made publicly accessible by the subject through explicit consent in accordance with the Law.
2.10. User — any visitor to the website http://fracturedsquare.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group.
2.12. Dissemination of personal data — actions aimed at disclosure to an indefinite circle of persons or making data publicly accessible, including via media or networks.
2.13. Cross-border data transfer — transfer of data to foreign entities, governments, or legal/physical persons.
2.14. Destruction of personal data — actions that render data irretrievable and/or destroy physical media.
3. Operator’s Main Rights and Obligations
3.1. The Operator has the right to:
4. Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
5. Principles of Personal Data Processing
5.1. Data processing must be lawful and fair.
5.2. Processing must pursue specific, legitimate goals.
5.3. Data must not be processed for incompatible purposes.
5.4. Only data necessary for the stated purposes is processed.
5.5. The volume and nature of data must match the purpose.
5.6. Data must be accurate and updated where necessary.
5.7. Data must not be stored longer than necessary unless otherwise required by law or contract.
6. Purpose of Processing Personal Data
The purpose is to inform the User via email.
Personal Data Processed:
Processing is based on the subject’s consent for responses, product and service information, and general interaction with the website.
Processing Activities:
7. Conditions for Personal Data Processing
7.1. Processing is carried out with the subject’s consent.
7.2. Processing is required under international treaties or laws.
7.3. Processing is needed for judicial or enforcement actions.
7.4. Processing is required for contract performance or its conclusion at the subject’s initiative.
7.5. Processing is necessary for legitimate interests of the Operator or third parties without infringing subject rights.
7.6. Processing applies to publicly available personal data.
7.7. Processing is required by law for publication or disclosure.
8. Data Collection, Storage, Transmission, and Processing Procedure
Security is ensured via legal, organizational, and technical measures in compliance with applicable data protection legislation.
8.1. The Operator protects personal data from unauthorized access.
8.2. Personal data will not be shared with third parties unless legally required or with the subject’s consent for contract fulfillment.
8.3. Users may update data by contacting info@fracturedsquare.com with the subject “Data Update.”
8.4. Data processing continues until goals are achieved or as required by law. Consent may be withdrawn by email with the subject “Consent Withdrawal.”
8.5. Third-party services (e.g., payment systems) process data under their own terms. The Operator is not responsible for such third parties.
8.6. Restrictions imposed by the subject on data dissemination do not apply in legally significant public interest cases.
8.7. The Operator ensures data confidentiality.
8.8. Data is stored only as long as necessary unless otherwise specified by law or contract.
8.9. Processing ends upon goal achievement, expiration or withdrawal of consent, or if processing is deemed unlawful.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, updating, extraction, usage, dissemination, depersonalization, blocking, deletion, and destruction.
9.2. Automated processing may involve transmission via telecom networks.
10. Cross-Border Personal Data Transfer
10.1. The Operator must notify the authorized regulatory body before any cross-border data transfer.
10.2. Prior to this notification, the Operator must obtain appropriate assurances from the foreign party receiving the data
11. Confidentiality of Personal Data
The Operator and other parties with access to personal data must not disclose or disseminate such data without the subject’s consent unless required by law.
12. Final Provisions
12.1. Users may contact the Operator for clarification via email at info@fracturedsquare.com.
12.2. Any changes to this Policy will be reflected in this document. The Policy is effective indefinitely until replaced.
12.3. The current version of the Policy is publicly available at http://fracturedsquare.com/privacy.
This Personal Data Processing Policy is drafted 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 procedure for processing personal data and the measures taken by Nikita Alexandrovich Nebukin (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy, personal and family secrets, as its highest priority and essential condition for carrying out its activities.
1.2. This Policy applies to all information that the Operator may receive about visitors to the website http://fracturedsquare.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing using computing equipment.
2.2. Blocking of personal data — temporary suspension of data processing (except where processing is necessary to clarify data).
2.3. Website — a combination of graphic and information content, software, and databases accessible online at http://fracturedsquare.com.
2.4. Personal data information system — a set of personal data contained in databases and technology enabling their processing.
2.5. Depersonalization of personal data — actions that make it impossible to identify a data subject without additional information.
2.6. Processing of personal data — any operation or set of operations performed with or without automation on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
2.7. Operator — a state or municipal authority, legal or physical person that processes personal data and determines the purposes, scope, and operations performed with the data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website http://fracturedsquare.com.
2.9. Personal data permitted for dissemination by the subject — data made publicly accessible by the subject through explicit consent in accordance with the Law.
2.10. User — any visitor to the website http://fracturedsquare.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group.
2.12. Dissemination of personal data — actions aimed at disclosure to an indefinite circle of persons or making data publicly accessible, including via media or networks.
2.13. Cross-border data transfer — transfer of data to foreign entities, governments, or legal/physical persons.
2.14. Destruction of personal data — actions that render data irretrievable and/or destroy physical media.
3. Operator’s Main Rights and Obligations
3.1. The Operator has the right to:
- Receive accurate personal data and/or documents from the data subject;
- Continue processing data without the subject’s consent in cases outlined in the Law;
- Determine independently the necessary and sufficient measures for fulfilling legal obligations unless otherwise prescribed by federal laws.
- Provide information about personal data processing upon request;
- Ensure processing complies with current Russian law;
- Respond to requests from data subjects or their legal representatives;
- Submit requested information to the authorized regulatory body within 10 days;
- Publicly disclose this Policy;
- Implement legal, organizational, and technical measures to protect data from unauthorized actions;
- Cease processing and destroy data in accordance with the Law;
- Fulfill other legal obligations.
4. Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
- Receive information about data processing, except as limited by law;
- Demand corrections, blocking, or deletion of incomplete, outdated, inaccurate, or illegally obtained data;
- Require prior consent for marketing-related data use;
- Withdraw consent or demand termination of data processing;
- Lodge complaints with regulatory authorities or courts;
- Exercise other rights under Russian law.
- Provide accurate data to the Operator;
- Notify the Operator of any data updates.
5. Principles of Personal Data Processing
5.1. Data processing must be lawful and fair.
5.2. Processing must pursue specific, legitimate goals.
5.3. Data must not be processed for incompatible purposes.
5.4. Only data necessary for the stated purposes is processed.
5.5. The volume and nature of data must match the purpose.
5.6. Data must be accurate and updated where necessary.
5.7. Data must not be stored longer than necessary unless otherwise required by law or contract.
6. Purpose of Processing Personal Data
The purpose is to inform the User via email.
Personal Data Processed:
- Full name
- Email address
Processing is based on the subject’s consent for responses, product and service information, and general interaction with the website.
Processing Activities:
- Collection, recording, systematization, accumulation, storage, destruction, depersonalization
- Email communication
7. Conditions for Personal Data Processing
7.1. Processing is carried out with the subject’s consent.
7.2. Processing is required under international treaties or laws.
7.3. Processing is needed for judicial or enforcement actions.
7.4. Processing is required for contract performance or its conclusion at the subject’s initiative.
7.5. Processing is necessary for legitimate interests of the Operator or third parties without infringing subject rights.
7.6. Processing applies to publicly available personal data.
7.7. Processing is required by law for publication or disclosure.
8. Data Collection, Storage, Transmission, and Processing Procedure
Security is ensured via legal, organizational, and technical measures in compliance with applicable data protection legislation.
8.1. The Operator protects personal data from unauthorized access.
8.2. Personal data will not be shared with third parties unless legally required or with the subject’s consent for contract fulfillment.
8.3. Users may update data by contacting info@fracturedsquare.com with the subject “Data Update.”
8.4. Data processing continues until goals are achieved or as required by law. Consent may be withdrawn by email with the subject “Consent Withdrawal.”
8.5. Third-party services (e.g., payment systems) process data under their own terms. The Operator is not responsible for such third parties.
8.6. Restrictions imposed by the subject on data dissemination do not apply in legally significant public interest cases.
8.7. The Operator ensures data confidentiality.
8.8. Data is stored only as long as necessary unless otherwise specified by law or contract.
8.9. Processing ends upon goal achievement, expiration or withdrawal of consent, or if processing is deemed unlawful.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, updating, extraction, usage, dissemination, depersonalization, blocking, deletion, and destruction.
9.2. Automated processing may involve transmission via telecom networks.
10. Cross-Border Personal Data Transfer
10.1. The Operator must notify the authorized regulatory body before any cross-border data transfer.
10.2. Prior to this notification, the Operator must obtain appropriate assurances from the foreign party receiving the data
11. Confidentiality of Personal Data
The Operator and other parties with access to personal data must not disclose or disseminate such data without the subject’s consent unless required by law.
12. Final Provisions
12.1. Users may contact the Operator for clarification via email at info@fracturedsquare.com.
12.2. Any changes to this Policy will be reflected in this document. The Policy is effective indefinitely until replaced.
12.3. The current version of the Policy is publicly available at http://fracturedsquare.com/privacy.
Personal Data Processing Policy
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