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FAQ
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1. General Provisions This Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been drafted in accordance with Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and establishes the procedure for processing personal data and the measures taken to ensure the security of personal data by Fantin Vladimir Ilyich (hereinafter referred to as the “Operator”). 1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal and family secrets, as a priority and essential condition for its activities. 1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://henrygrowth.com/. 2. Basic Terms Used in the Policy 2.1. Automated processing of personal data — processing of personal data using computing technology. 2.2. Blocking of personal data — temporary suspension 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 https://henrygrowth.com/. 2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing. 2.5. Depersonalization of personal data — actions resulting in the inability to identify the personal data owner without additional information. 2.6. Processing of personal data — any operation or set of operations performed with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data. 2.7. Operator — a state, municipal body, legal or natural person that organizes and/or performs the processing of personal data and determines the purposes and scope of the data processed. 2.8. Personal data — any information relating directly or indirectly to an identified or identifiable user of the website https://henrygrowth.com/. 2.9. Personal data made publicly available by the data subject — data to which the subject has granted access to an unlimited number of persons by giving consent as per the Personal Data Law. 2.10. User — any visitor of the website https://henrygrowth.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 — any actions aimed at disclosing data to an indefinite group, including publication or online distribution. 2.13. Cross-border data transfer — transfer of personal data to the territory of a foreign state to a foreign authority or legal/natural person. 2.14. Destruction of personal data — actions that result in the irreversible destruction of personal data without the possibility of recovery. 3. Rights and Obligations of the Operator 3.1. The Operator has the right to:
receive accurate data and/or documents from the personal data subject;
continue data processing without consent if permitted by the Personal Data Law;
independently determine the scope of measures to ensure compliance with the Personal Data Law.
3.2. The Operator is obliged to:
provide information about personal data processing upon request;
organize processing in accordance with Russian law;
respond to data subject inquiries;
provide requested data to the authorized data protection body within 10 days;
publish this Policy publicly;
implement legal, organizational, and technical measures for data protection;
cease data dissemination and processing when required by law;
fulfill other legal obligations.
4. Rights and Obligations of Data Subjects 4.1. Data subjects have the right to:
access information on personal data processing;
request clarification, blocking, or destruction of inaccurate or unlawfully processed data;
require prior consent for marketing processing;
withdraw consent and request processing cessation;
appeal unlawful processing to the authorized body or court;
exercise other rights granted by Russian law.
4.2. Data subjects must:
provide accurate personal data;
inform the Operator of any updates to their data.
4.3. Persons who provide false information or data on other individuals without consent bear legal liability. 5. Principles of Personal Data Processing 5.1. Lawfulness and fairness. 5.2. Limitation to specific, lawful purposes. 5.3. Incompatibility of different processing purposes is prohibited. 5.4. Only data relevant to stated purposes is processed. 5.5. The scope of data must match the processing purposes. 5.6. Data must be accurate and kept up to date. 5.7. Data is stored only as long as necessary and destroyed or depersonalized afterward. 6. Purpose of Personal Data Processing
Purpose: Informing the User via email.
Personal Data: Full name, email address, phone numbers.
Legal Basis: Contracts between the Operator and the data subject.
Types of Processing: Transfer of personal data.
7. Conditions for Personal Data Processing 7.1. Consent from the data subject. 7.2. Processing required by law or international agreement. 7.3. Processing for legal/judicial purposes. 7.4. Processing for contract performance. 7.5. Processing for the Operator’s or third parties’ legitimate interests, without violating rights. 7.6. Publicly available data. 7.7. Data subject to mandatory publication or disclosure under federal law. 8. Procedure for Collection, Storage, Transfer, and Other Processing The Operator ensures personal data security through legal, organizational, and technical measures. 8.1. Access to data by unauthorized persons is prevented. 8.2. Data is never transferred to third parties unless legally required or authorized by the subject. 8.3. Users may update their data via email to martingrosso195@gmail.com with the subject “Personal Data Update.” 8.4. Data is stored until the processing purpose is achieved, unless otherwise provided by law or contract. Consent may be withdrawn by emailing “Withdrawal of Consent to Personal Data Processing” to martingrosso195@gmail.com. 8.5. Third-party services (e.g. payment systems) store/process data in accordance with their own policies. The Operator is not responsible for their actions. 8.6. Restrictions on dissemination do not apply when data is processed for public interest under Russian law. 8.7. Confidentiality is ensured during processing. 8.8. Data is not retained longer than necessary. 8.9. Processing is terminated upon achieving the purpose, withdrawal of consent, or discovery of unlawful processing. 9. List of Processing Activities Performed by the Operator 9.1. Collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, depersonalization, blocking, deletion, and destruction. 9.2. Automated processing with or without telecommunication networks. 10. Cross-Border Transfer of Personal Data 10.1. The Operator must notify the authorized body before transferring data abroad. 10.2. The Operator must collect relevant information from foreign entities before notification. 11. Confidentiality of Personal Data The Operator and any persons with access to data must not disclose or distribute it without consent, unless required by law. 12. Final Provisions 12.1. Users may contact the Operator at martingrosso195@gmail.com for questions about personal data processing. 12.2. Changes to this Policy will be reflected in the document. The Policy is valid indefinitely until replaced. 12.3. The current version is publicly available at https://henrygrowth.com/.