Personal data processing policy

1. General Provisions

• This Personal Data Processing Policy has been prepared in accordance with the applicable data protection legislation and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by SHO MEDIA (hereinafter referred to as the Operator).
• The Operator considers compliance with the rights and freedoms of individuals and citizens during the processing of their personal data to be a key objective and condition of its activities, including the protection of the right to privacy and personal and family confidentiality.
• This Operator’s Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website shoteam.media.

2. Key Terms Used in the Policy

• Automated processing of personal data — processing of personal data using computer technology.
• Blocking of personal data — temporary suspension of the processing of personal data (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 that ensure their availability on the Internet at the network address shoteam.media.
• Personal data information system — a set of personal data contained in databases, along with information technologies and technical means that ensure their processing.
• Anonymization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another personal data subject.

• Processing of personal data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

• Operator — a government 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 processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.

• Personal data — any information relating directly or indirectly to an identified or identifiable User of the website shoteam.media.

• Personal data permitted by the subject for distribution — 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 distribution in accordance with applicable data protection legislation.

• User — any visitor to the website shoteam.media.

• Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

• Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited number 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 resulting in the irreversible destruction of personal data without the possibility of further restoration of the content of personal data in the personal data information system and/or destruction of material carriers containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

• obtain reliable information and/or documents containing personal data from the personal data subject;
• in the event that the personal data subject withdraws their consent to the processing of personal data, continue processing the personal data without such consent if there are legal grounds provided by applicable data protection legislation;
• independently determine the scope and list of measures necessary and sufficient to ensure compliance with obligations established by personal data legislation and applicable regulatory legal acts, unless otherwise provided by applicable data protection legislation and/or other local and/or international laws.

3.2. The Operator is obliged to:

• provide the personal data subject, upon request, with information regarding the processing of their personal data;
• organize the processing of personal data;
• respond to inquiries and requests from personal data subjects and their legal representatives;
• provide the competent authority for the protection of personal data subjects’ rights with the necessary information upon its request;
• publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, or distribution, as well as from other unlawful actions involving personal data;
• cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and in cases предусмотренных applicable data protection legislation;
• fulfill other obligations established by applicable data protection legislation.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

• receive information regarding the processing of their personal data, except in cases provided for by applicable data protection legislation. Such information shall be provided by the Operator in an accessible form and must not include personal data relating to other personal data subjects, except where there are lawful grounds for the disclosure of such personal data;
• require the Operator to clarify, block, or delete their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided 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;
• request the deletion of their personal data and withdraw consent to the processing of personal data. To do so, a request must be sent to shoteam.media@gmail.com with the subject line “Deletion of Personal Data and Withdrawal of Consent to Their Processing”;
• appeal against unlawful actions or inaction of the Operator in the processing of their personal data to the competent authority for the protection of personal data subjects’ rights or in court;
• exercise other rights provided for by applicable data protection legislation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate information about themselves;
• inform the Operator of any clarification, update, or change to their personal data;
• independently monitor and review the current updates and amendments to this Policy.
• Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent shall bear responsibility in accordance with applicable law.

5. The Operator may process the following personal data:

email address;

phone numbers.

The website also collects and processes anonymized data about visitors (including cookie files) using web analytics services (such as Google Analytics and others).

The above-mentioned data are hereinafter collectively referred to in this Policy as Personal Data.

The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.

Processing of personal data permitted for distribution by the personal data subject from among special categories of personal data is allowed only if the prohibitions and conditions established by applicable data protection legislation are observed.

The User’s consent to the processing of personal data permitted for distribution shall be provided separately from other consents for the processing of their personal data.

The User provides such consent to the Operator directly.

The Operator shall within no later than three business days from the moment of receiving such consent publish information about the conditions of processing, as well as the existence of prohibitions and conditions for the processing of personal data permitted for distribution to an unlimited number of persons.

The transfer (distribution, provision, or access) of personal data permitted for distribution by the personal data subject must be terminated at any time upon the request of the personal data subject.

Such a request must include:

the surname, first name, and patronymic (if applicable) of the personal data subject;

contact information (phone number, email address, or postal address);

the list of personal data whose processing must be terminated.

The personal data specified in such a request may be processed only by the Operator to whom the request was addressed.

Consent to the processing of personal data permitted for distribution shall terminate upon receipt by the Operator of the request specified in clause 10.6 of this Personal Data Processing Policy.

6. Principles of Personal Data Processing

Personal data shall be processed on a lawful and fair basis.

The processing of personal data shall be limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.

It is not permitted to combine databases containing personal data whose processing is carried out for purposes that are incompatible with each other.

Only personal data that correspond to the purposes of their processing shall be processed.

The content and scope of processed personal data must correspond to the declared purposes of processing. Excessive personal data in relation to the stated purposes of processing shall not be permitted.

When processing personal data, accuracy, adequacy, and where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or correct incomplete or inaccurate data.

Personal data shall be stored in a form that allows identification of the personal data subject no longer than required by the purposes of personal data processing, unless a storage period is established by law. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or if the need to achieve those purposes no longer exists, unless otherwise provided by law.

7. Purposes of Personal Data Processing

7.1. The purposes of processing the User’s personal data include:

• informing the User by sending emails;
• providing the User with access to services, information, and/or materials available on the website shoteam.media.

The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may unsubscribe from such informational messages at any time by sending an email to shoteam.media@gmail.com with the subject line “Unsubscribe from notifications about new products, services, and special offers.”

Anonymized User data collected through web analytics services are used to gather information about Users’ actions on the website and to improve the quality of the website and its content.

8. Legal Grounds for the Processing of Personal Data

8.1. The legal grounds for the processing of personal data by the Operator are:

• the Operator’s constitutional (founding) documents;
• agreements concluded between the Operator and the personal data subject;
• applicable data protection legislation and other local and/or international regulatory legal acts in the field of personal data protection;
• Users’ consent to the processing of their personal data, including consent to the processing of personal data permitted for distribution.

The Operator processes the User’s personal data only if it is voluntarily filled in and/or submitted by the User through special forms located on the website shoteam.media or sent to the Operator via email. By filling out the relevant forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.

The Operator processes anonymized data about the User if this is permitted by the User’s browser settings (including the storage of cookies and the use of JavaScript technology).

The personal data subject independently decides whether to provide their personal data and gives consent freely, of their own will, and in their own interest.

9. Conditions for the Processing of Personal Data

Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.

The processing of personal data is necessary to achieve the purposes related to the performance of the Operator’s functions, powers, and obligations.

The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, 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.

The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

Personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data) may be processed.

Personal data that is subject to publication or mandatory disclosure in accordance with applicable legislation may also be processed.

10. Procedure for the Collection, Storage, Transfer, 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 necessary to fully comply with applicable data protection legislation.

The Operator ensures the protection of personal data and takes all reasonable measures to prevent unauthorized access to personal data.

The User’s personal data will never be transferred to third parties under any circumstances, except in cases related to compliance with applicable law or if the personal data subject has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.

If inaccuracies in personal data are identified, the User may update such data by sending a notification to the Operator at shoteam.media@gmail.com with the subject line “Personal Data Update.”

The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator at shoteam.media@gmail.com with the subject line “Withdrawal of Consent to the Processing of Personal Data.”

All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or User is responsible for reviewing these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

Restrictions 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 distribution, shall not apply in cases where personal data processing is carried out in state, public, or other public interests defined by applicable data protection legislation.

When processing personal data, the Operator ensures the confidentiality of personal data.

The Operator stores personal data in a form that allows identification of the personal data subject no longer than necessary for the purposes of personal data processing, unless a storage period is established by law.

The processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, or detection of unlawful processing of personal data. The User may also request the deletion of their personal data by sending a request to shoteam.media@gmail.com with the subject line “Deletion of Personal Data and Withdrawal of Consent to Their Processing.”

11. List of Actions Performed by the Operator with the Received Personal Data

The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

The Operator carries out automated processing of personal data, including the receipt and/or transfer of the obtained information through information and telecommunication networks or without such transfer.

12. Cross-Border Transfer of Personal Data

Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data will be transferred provides an adequate level of protection of the rights of personal data subjects.

The cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out if there is written consent from the personal data subject for such transfer and/or if it is necessary for the performance of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by applicable data protection legislation.

14. Final Provisions

The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at shoteam.media@gmail.com.

Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy shall remain valid indefinitely until it is replaced by a new version.

The current version of the Policy is publicly available on the Internet at:

https://shoteam.media/ru/politika-v-otnoshenii-obrabotki-personalnyh-dannyh/