1. General Provisions
This personal data processing policy has been drafted in accordance with the requirements of the 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 measures to ensure the security of personal data undertaken by Jane Sabic (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms, including the rights to privacy, personal, and family confidentiality, as a fundamental objective and condition for conducting its activities when processing personal data.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://jane-sabic.tilda.ws/.
2Key Terms 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 when processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://jane-sabic.tilda.ws/.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical tools that ensure their processing.
2.5. Depersonalization of personal data – actions that make it impossible to determine, without additional information, the affiliation of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or a combination of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information directly or indirectly related to an identified or identifiable User of the website https://jane-sabic.tilda.ws/.
2.9. Personal data allowed by the subject of personal data for dissemination – personal data to which the subject of personal data provides access to an unlimited number of persons by granting consent for the processing of personal data permitted by the subject of personal data for dissemination under the procedure established by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User – any visitor to the website https://jane-sabic.tilda.ws/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data by any other means.
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 that result in the irreversible destruction of personal data with no possibility of further restoration of personal data content in the personal data information system and/or the destruction of the physical storage media containing personal data.
3.Main Rights and Obligations of the Operator
3.1. The Operator has the right to:

• Receive accurate information and/or documents containing personal data from the subject of personal data;
• In the event of the withdrawal of consent by the subject of personal data for the processing of personal data, as well as the submission of a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
• Independently determine the scope 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 subject of personal data, upon request, with information regarding 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 requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
• Provide the authorized body for the protection of the rights of personal data subjects, upon request, with the necessary information within 10 days from the date of receipt of such a 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, and other unlawful actions related to personal data;
• Cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
• Fulfill other obligations stipulated by the Personal Data Law.

4.Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

• Obtain information regarding the processing of their personal data, except in cases provided by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except in cases where 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;
• Request that the Operator clarify, block, or destroy their personal data if such personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures prescribed by law to protect their rights;
• Require prior consent for the processing of personal data for the purposes of promoting goods, works, and services on the market;
• Withdraw consent for the processing of personal data and submit a request to cease the processing of personal data;
• Appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction by the Operator in the processing of their personal data;
• Exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• Provide the Operator with accurate information about themselves;
• Notify the Operator of any clarification (updates, changes) of their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without their consent are liable in accordance with the legislation of the Russian Federation.
5.Principles of Personal Data Processing
5.1. Personal data processing 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. The processing of personal data that is incompatible with the purposes of data collection is not allowed.
5.3. The merging of databases containing personal data, the processing of which is conducted for purposes incompatible with each other, is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the declared purposes of processing. Excessive personal data processing in relation to the declared purposes is not allowed.
5.6. The accuracy, sufficiency, and, when necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures the removal or clarification of incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the personal data subject no longer than required by the purposes of processing, unless a storage period is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if the necessity of achieving these purposes is lost, unless otherwise provided by federal law.
6.Purposes of Personal Data Processing
Purpose of processing
Conclusion, execution, and termination of civil law contracts
Personal data
Last name, first name, patronymic
Email address
Phone numbers
Legal grounds
Constitutive (founding) documents of the Operator
Contracts concluded between the Operator and the personal data subject
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

• Sending informational emails to the email address

7.Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve purposes established by an international treaty of the Russian Federation or by law, or to perform functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, or an act of another authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of 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 for the exercise of the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data that has been made publicly available by the personal data subject or at their request is processed (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is carried out when required to be published or disclosed under federal law.
8.Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures required to fully comply with current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given their consent for the transfer of data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address info@janesabic.com with the subject “Updating Personal Data.”
8.4. The period of personal data processing is determined by achieving the purposes for which the personal data was collected unless otherwise specified by the contract or applicable law. The User may withdraw their consent for the processing of personal data at any time by sending a notification to the Operator’s email address info@janesabic.com with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including those mentioned in this clause.
8.6. Restrictions imposed by the personal data subject on the transfer (except for granting access), processing, or conditions of processing (except for granting access) of personal data permitted for dissemination do not apply in cases of processing personal data for state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than is required for 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.
8.9. The conditions for terminating the processing of personal data may include achieving the purposes of personal data processing, the expiration of the personal data subject's consent, withdrawal of consent by the personal data subject, a request to cease processing personal data, or the discovery of unlawful processing of personal data.
9.List of Actions Performed by the Operator with Collected Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator conducts automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such networks.
10.Cross-Border Transfer of Personal Data
10.1. Before initiating activities related to 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 about 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. Prior to submitting the aforementioned notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or 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 required not to disclose or disseminate personal data to third parties 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 questions of interest related to the processing of their personal data by contacting the Operator via email at info@janesabic.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://jane-sabic.tilda.ws/privacy-policy.