Personal Data Processing Policy

This Privacy Policy (hereinafter — the “Privacy Policy”) applies to personal data received by the State Autonomous Cultural Institution of the Yaroslavl Region “Yaroslavl State Philharmonic” (OGRN: 1037600401222, INN: 7604001200, hereinafter — the “Operator”) from persons visiting the website at: yaagso.ru (hereinafter — the “User”) and using its services, programs and information products.

By using the services of the website at yaagso.ru, the User unconditionally agrees to the provisions of this Privacy Policy and the terms of personal data processing set out therein.

If the User does not agree with these terms, the User must refrain from and/or discontinue using the Site and its services.

1. DEFINITIONS AND TERMS

1.1. This Privacy Policy uses the following definitions and terms:

1.1.1. “Site Administration” — authorized employees managing the website yaagso.ru, acting in the interests of the Operator.

1.1.2. “Personal data” — any information relating directly or indirectly to a specific or identifiable individual (subject of personal data) — the User.

1.1.3. “Processing of personal data” — any action (operation) or set of actions (operations) performed on personal data, whether or not using 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.

1.1.4. “Operator” — the State Autonomous Cultural Institution of the Yaroslavl Region “Yaroslavl State Philharmonic” (OGRN: 1037600401222, INN: 7604001200), which, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

1.1.5. “Confidentiality of personal data” — a requirement binding on the Operator or any other person who has gained access to personal data not to permit their distribution without the consent of the data subject or another lawful basis.

1.1.6. “User” — a person who has access to the Site via the Internet information and telecommunications network and uses the Site, including its services.

1.1.7. “Site” — the website located at yaagso.ru on the Internet information and telecommunications network, including, but not limited to, its pages, services, programs and information products.

1.1.8. “Cookies” — a piece of data sent by a web server and stored on the User’s computer, which the web client or web browser resends to the web server in an HTTP request each time it attempts to open a page of the relevant website.

1.1.9. “IP address” — a unique network address of a node in a computer network built on the IP protocol.

1.2. Definitions and terms not reflected in clause 1.1 of Section 1 of this Privacy Policy shall be understood in the meaning given to them in Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006.

2. GENERAL PROVISIONS

2.1. The User’s use of the Site constitutes the User’s unconditional agreement with the provisions of this Privacy Policy and the terms of processing of his/her personal data set out therein.

2.2. If the User does not agree with the terms of the Privacy Policy, the User must immediately stop using the Site.

2.3. If the User withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the User’s consent where grounds exist under Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006.

2.4. This Privacy Policy applies only to the Site. The Operator and the Site Administration do not control and are not responsible for third-party websites that the User may access via links available on the Site.

2.5. The Operator does not verify the accuracy of the personal data provided by the User. The Operator assumes that the User provides accurate and sufficient personal data and keeps it up to date. Persons who provide inaccurate information about themselves, or information about another data subject without the latter’s consent, shall be liable in accordance with the legislation of the Russian Federation.

2.6. The legal basis for the Operator’s processing of Users’ personal data is Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006 (hereinafter — the “Law”).

3. SUBJECT OF THE PRIVACY POLICY

3.1. This Privacy Policy establishes the obligations to maintain confidentiality and ensure the protection of personal data that the User provides to the Operator upon registration on the Site and/or when submitting a request.

3.2. The User confirms the decision to provide personal data and consents to its processing, as well as to other actions provided for in clause 3 of Article 3 of Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006.

3.3. The personal data permitted for processing under this Privacy Policy are provided by the User by filling out a form on the Site and include the following information:

3.3.1. the User’s name;

3.3.2. the User’s contact phone number;

3.3.3. e-mail address.

4. PURPOSES OF COLLECTING THE USER’S PERSONAL DATA

4.1. The Operator may use the User’s personal data for the following purposes:

4.1.1. Identifying the User when submitting a request and/or concluding an Agreement.

4.1.2. Establishing feedback with the User, including processing the User’s enquiries and requests to conclude an Agreement.

4.1.3. Providing the User, with his/her consent, with information about special offers, newsletters and other information on behalf of the Operator.

4.1.4. Conducting statistical and other research based on depersonalized data; in particular, the Operator has the right to collect statistics using the “Yandex Metrica” service, an Internet service of Yandex intended for generating reports, recording the actions of Site visitors, tracking traffic sources and assessing the effectiveness of online and offline advertising.

4.1.5. Improving the quality of the Site’s operation.

5. METHODS AND TERMS OF PROCESSING PERSONAL DATA

5.1. The processing of the User’s personal data is carried out indefinitely, by any lawful means, including in personal data information systems, whether or not using automation tools.

5.2. The User’s personal data may be transferred to authorized state authorities of the Russian Federation only on the grounds and in the manner established by the current legislation of the Russian Federation.

5.3. The Operator takes legal, organizational and technical measures to protect the User’s personal data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties.

6. OBLIGATIONS OF THE PARTIES

6.1. The User is obliged to:

6.1.1. Provide the personal data necessary to achieve the purposes set out in Section 4 of this Privacy Policy.

6.2. The User has the right to:

6.2.1. Change, update or supplement his/her personal data at any time in the event of any changes.

6.2.2. Receive information regarding the processing of his/her personal data.

6.2.3. Withdraw consent to the processing of his/her personal data at any time. Withdrawal is carried out by contacting the Operator.

6.3. The Operator is obliged to:

6.3.1. Use the received information exclusively for the purposes specified in Section 4 of this Privacy Policy.

6.3.2. Ensure that confidential information is kept secret, not disclose it without the User’s prior written permission, and not sell, exchange, publish or otherwise disclose the User’s personal data that has been transferred.

6.3.3. Take measures to protect the confidentiality of the User’s personal data in accordance with the procedure generally used to protect this type of information in existing business practice.

6.3.4. Block the personal data relating to the relevant User from the moment of the User’s or his/her legal representative’s request based on a written notice, or based on a written request from the authorized body for the protection of the rights of personal data subjects, for the period of verification, if inaccurate personal data or unlawful actions are identified.

6.3.5. If the User withdraws his/her consent to the processing of personal data, immediately cease such processing, except in the cases specified in clause 2.3 of this Privacy Policy.

6.3.6. If the retention of Personal Data is no longer required for the purposes of its processing, the Operator is obliged to destroy such data by erasing it from the storage medium without destroying the medium itself.

6.3.7. Provide the User, upon his/her request, with information regarding the processing of his/her personal data.

6.4. The Operator has the right to:

6.4.1. The Operator has the right, without the User’s consent, to provide his/her personal data to authorized employees managing the website yaagso.ru, who act exclusively in the interests of the Operator and organize and/or carry out the processing of the User’s personal data.

7. LIABILITY OF THE PARTIES

7.1. An Operator that fails to fulfil its obligations to protect personal data shall be liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the current legislation of the Russian Federation, except for the cases provided for in clause 7.2 of this Privacy Policy.

7.2. In the event of loss or disclosure of personal data, the Operator shall not be liable if:

7.2.1. The personal data became publicly available before its loss or disclosure.

7.2.2. The personal data was obtained by a third party before it was received by the Operator.

7.2.3. The personal data was obtained by a third party with the User’s consent.

8. DISPUTE RESOLUTION

8.1. A mandatory pre-trial claim procedure applies — the submission of a claim (a written proposal for voluntary settlement of the dispute).

8.2. The recipient of a claim shall notify the claimant in writing of the results of its review within 30 calendar days of receipt.

8.3. If no agreement is reached, the dispute shall be referred to a court in accordance with the current legislation of the Russian Federation.

8.4. This Privacy Policy and the relationship between the User and the Operator are governed by the current legislation of the Russian Federation, including with respect to any matters not covered by this Privacy Policy.

9. ADDITIONAL TERMS

9.1. The Operator has the right to amend this Privacy Policy at its own discretion.

9.2. The new Privacy Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Privacy Policy.

9.3. The current Privacy Policy is posted on the Site page at yaagso.ru/privacy-policy/.