Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been 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 to ensure the security of personal data by Ivan Sergeevich Mikhailov (hereinafter referred to as the Operator).
1.1. The Operator's utmost goal and condition for carrying out its activities is the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's Policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website [https://www.henrymr.com](https://www.henrymr.com/).
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address [https://www.henrymr.com](https://www.henrymr.com/).
2.4. Personal data information system – a collection of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions as a result of which it becomes impossible to determine, without using additional information, the ownership of personal data to a specific User or other personal data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website [https://www.henrymr.com/](https://www.henrymr.com/).
2.9. Personal data permitted for dissemination by the personal data subject – personal data to which access is granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User – any visitor to the website [https://www.henrymr.com/](https://www.henrymr.com/).
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or making personal data known to an unlimited circle of persons, including publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data is irretrievably destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and/or the material carriers of the personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right:
- To receive from the personal data subject reliable information and/or documents containing personal data;
- In the event the personal data subject withdraws consent for the processing of personal data, or submits a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if grounds exist as specified in the Personal Data Law;
- To independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with 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 their request, with information concerning the processing of their personal data;
- Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- Respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- Report to the authorized body for the protection of the rights of personal data subjects, upon request from that body, the necessary information within 10 days from the date of receiving such request;
- Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
- Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions concerning personal data;
- Cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- Fulfill other duties stipulated by the Personal Data Law.
4. Basic 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 to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- Demand that the Operator clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
- Impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
- Withdraw consent to the processing of personal data, and also submit a request to cease processing personal data;
- Appeal the unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
- 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 data about themselves;
- Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with false information about themselves, or information about another personal data subject without the latter's consent, shall be held liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not permitted.
5.3. Merging databases containing personal data processed for purposes incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, in necessary cases, relevance concerning the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or in the event of losing the necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of processing | Informing the User by sending emails |
| :--- | :--- |
| Personal data | surname, first name, patronymic; phone numbers |
| Legal grounds | Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection" |
| Types of personal data processing | Sending informational letters to the email address |
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals 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. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the 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. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data is carried out, access to which is granted to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, 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 safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the purpose of fulfilling obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator via email at henry@henrymr.com, marked "Updating personal data".
8.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected, unless a different period is provided for by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email at henry@henrymr.com, marked "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is recommended to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of personal data processing in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of processing the personal data, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The conditions for terminating the processing of personal data may include achieving the purposes of processing personal data, expiration of the consent period of the personal data subject, withdrawal of consent by the personal data subject, or a request to cease processing personal data, as well as the discovery of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the obtained information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities for the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from the foreign state authorities, foreign individuals, and foreign legal entities to whom 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 are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator via email at henry@henrymr.com.
12.2. 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.
12.3. The current version of the Policy is freely available on the internet at [https://www.henrymr.com/privacy-policy/](https://www.henrymr.com/privacy-policy/).