Privacy Policy

1. General Provisions

This Personal Data Processing Policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Vereteno Alexandra Alexandrovna (hereinafter referred to as the Operator).
1.1. The Operator’s primary goal and condition for its activities is the protection of human and civil rights and freedoms during the processing of personal data, including the protection of privacy, personal, and family secrets.
1.2. This Operator’s Policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://neurobusinessvrtn.ru.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data — processing personal data using computing equipment.
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 graphical and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the address https://neurobusinessvrtn.ru.
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. Anonymization of personal data — actions that make it impossible to determine the owner of personal data without additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a government body, municipal body, legal or natural person, independently or jointly with others organizing and/or performing personal data processing, as well as determining the purposes of processing, the composition of personal data to be processed, and actions performed with personal data.
2.8. Personal data — any information directly or indirectly related to a specific or identifiable user of the website https://neurobusinessvrtn.ru.
2.9. Personal data permitted for dissemination — personal data to which unlimited access is granted by the subject of personal data by giving consent for its processing in accordance with the Personal Data Law.
2.10. User — any visitor to the website https://neurobusinessvrtn.ru.
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 unspecified circle of persons or making them available to the general public, including publishing in media, placing in telecommunication networks, or providing access by other means.
2.13. Cross-border transfer of personal data — transfer of personal data to a foreign country’s authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making recovery impossible, or destruction of the physical 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 data subject;
  • continue processing personal data without the subject’s consent if there are legal grounds provided by the Personal Data Law;
  • independently determine the necessary measures to fulfill obligations under the Personal Data Law, unless otherwise stipulated by law.
3.2. The Operator is obliged to:
  • provide the data subject with information about personal data processing upon request;
  • organize personal data processing in accordance with Russian Federation legislation;
  • respond to requests from data subjects and their legal representatives;
  • provide required information to the authorized body within 10 days of request;
  • publish or provide unrestricted access to this Policy;
  • take legal, organizational, and technical measures to protect personal data;
  • stop transfer, processing, and destroy personal data when required by law;
  • fulfill other obligations under the Personal Data Law.


4. Main Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:
  • receive information about the processing of their personal data, except as provided by law;
  • request clarification, blocking, or deletion of their personal data if incomplete, outdated, inaccurate, or illegally obtained;
  • set prior consent for processing for marketing purposes;
  • withdraw consent for personal data processing;
  • appeal against unlawful actions or inaction of the Operator;
  • exercise other rights under Russian law.
4.2. Data subjects are obliged to:
  • provide accurate personal data to the Operator;
  • inform the Operator about updates or changes to their personal data.
4.3. Persons providing inaccurate information or third-party data without consent are liable under Russian law.



5. Principles of Personal Data Processing

5.1. Processing is performed legally and fairly.
5.2. Processing is limited to specific, lawful purposes.
5.3. Combining databases with incompatible purposes is prohibited.
5.4. Only relevant personal data is processed.
5.5. Data processing must not be excessive relative to the purposes.
5.6. Accuracy and relevance of data must be ensured.
5.7. Storage is allowed only as long as necessary for the processing purposes; data must be destroyed or anonymized afterward.


6. Purposes of Personal Data Processing

  • Full name
  • Email address
  • Phone numbers
Legal basis: Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” of 27.07.2006
Types of processing: Collection, recording, systematization, accumulation, storage, destruction, anonymization; sending informational emails.


7. Conditions of Personal Data Processing

7.1. Processing is based on the data subject’s consent.
7.2. Processing is necessary to fulfill legal obligations or international treaties.
7.3. Processing is necessary for justice or execution of court acts.
7.4. Processing is necessary to execute contracts or related legal obligations.
7.5. Processing is necessary to protect legitimate interests or public goals without violating rights.
7.6. Processing of publicly accessible personal data.
7.7. Processing required by law for publication or disclosure.



8. Procedure for Collection, Storage, Transfer, and Other Processing

8.1. The Operator ensures data security and prevents unauthorized access.
8.2. Personal data will not be transferred to third parties except as required by law or with consent.
8.3. Users may update their personal data by notifying the Operator at vereteno_aa@mail.ru.
8.4. Processing duration is tied to the purpose; users may withdraw consent via email.
8.5. Data collected by third-party services is managed according to their policies.
8.6. Restrictions on processing of publicly available data do not apply for legal or public interest purposes.
8.7. The Operator ensures confidentiality.
8.8. Data storage is limited to the necessary period; afterwards data is anonymized or destroyed.
8.9. Processing stops upon reaching the purpose, withdrawal of consent, or unlawful processing detection.



9. Actions Performed by the Operator with Personal Data

9.1. Collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, anonymization, blocking, deletion, destruction.
9.2. Automated processing with information transfer via telecommunication networks or without.



10. Cross-Border Transfer of Personal Data

10.1. Prior notice to the authorized body is required before cross-border transfer.
10.2. The Operator must obtain relevant information from foreign authorities or recipients before transfer.



11. Confidentiality of Personal Data

The Operator and other persons with access must not disclose personal data without consent unless otherwise provided by law.



12. Final Provisions

12.1. Users may contact the Operator at vereteno_aa@mail.ru for clarifications.
12.2. Any changes to the Policy will be reflected in this document; the Policy is valid indefinitely until replaced.
12.3. The current version is available online at https://neurobusinessvrtn.ru/privacy.