This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for personal data processing and measures to ensure the security of personal data undertaken by Phoenix (hereinafter referred to as the “Operator”).
The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy and personal and family confidentiality, to be its most important objective and a mandatory condition for carrying out its activities.
This Personal Data Processing Policy of the Operator (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://phoenix.ink/.
Automated personal data processing — processing of personal data using computer equipment.
Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://phoenix.ink/.
Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine the ownership of personal data by a specific User or another personal data subject.
Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
Operator — a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing and determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://phoenix.ink/.
Personal data permitted by the personal data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law.
User — any visitor to the website https://phoenix.ink/.
Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons or making personal data available to an unlimited group of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual, or foreign legal entity.
Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed with no possibility of further restoration in the personal data information system and/or material carriers of personal data are destroyed.
— receive reliable information and/or documents containing personal data from the personal data subject;
— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of 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.
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize personal data processing in accordance with the procedure established by the legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects 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 with necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions;
— cease transfer (dissemination, provision, access), stop processing, and destroy personal data in cases and in the manner provided by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
— receive information regarding the processing of their personal data, except in cases provided for by federal laws;
— require clarification, blocking, or destruction of their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purpose;
— require prior consent for personal data processing for marketing purposes;
— withdraw consent to personal data processing and submit a request to terminate processing;
— appeal unlawful actions or inaction of the Operator to the authorized body or in court;
— exercise other rights provided by the legislation of the Russian Federation.
— provide accurate information about themselves;
— inform the Operator of updates or changes to their personal data.
Persons who provide false information about themselves or about another personal data subject without their consent shall be liable in accordance with the legislation of the Russian Federation.
Personal data are processed on a lawful and fair basis.
Processing is limited to achieving specific, predefined, and lawful purposes.
Databases containing personal data processed for incompatible purposes shall not be merged.
Only personal data relevant to the processing purposes are subject to processing.
The content and scope of processed personal data correspond to the stated purposes.
Accuracy, sufficiency, and relevance of personal data are ensured; necessary measures are taken to delete or update incomplete or inaccurate data.
Personal data are stored no longer than required for processing purposes, unless otherwise provided by law or contract.
| Purpose of processing | Personal data | Legal grounds | Types of personal data processing |
|---|---|---|---|
| informing the User by sending emails | philosophical beliefs | Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" | sending informational emails |
Personal data are processed with the consent of the personal data subject or in cases provided by law.
The Operator ensures personal data security through legal, organizational, and technical measures.
The User may update or withdraw consent by emailing info@phoenix.ink.
The Operator performs collection, storage, use, transfer, depersonalization, blocking, deletion, and destruction of personal data, including automated processing.
The Operator complies with notification requirements prior to cross-border transfers.
Personal data shall not be disclosed without consent unless otherwise provided by law.
Users may contact the Operator at info@phoenix.ink for clarifications.
The Policy is valid indefinitely until replaced.
The current version is available at https://phoenix.ink/privacy.