Personal Data Processing Policy
This is an English translation provided for convenience. In case of any discrepancy, the Russian version of the document prevails.
1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by “Polygon. Concert Agency” LLC (hereinafter — the Operator).
1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family secrecy, as its most important goal and as a condition for carrying out its activities.
1.2. This policy of the Operator on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://polygon.fm.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://polygon.fm.
2.4. Personal data information system — the set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belong to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of the personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://polygon.fm.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which an unlimited group of persons has been given access by the personal data subject by giving consent to the processing of personal data permitted by the subject for dissemination in the manner provided by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://polygon.fm.
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 indefinite group of persons (transfer of personal data) or at making an unlimited group of persons familiar with personal data, including publication of personal data in the mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irrevocably destroyed, making it impossible to restore the content of the personal data in the personal data information system, and/or the physical media of personal data are destroyed.
3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
— to receive from the personal data subject accurate information and/or documents containing personal data;
— if the personal data subject withdraws consent to the processing of personal data or sends a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the personal data subject’s consent where the grounds specified in the Personal Data Law exist;
— to independently determine the composition and list of measures that are necessary and sufficient to ensure the performance of the duties provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— to provide the personal data subject, at their request, with information concerning the processing of their personal data;
— to organize the processing of personal data in the manner established by the applicable legislation of the Russian Federation;
— to respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to provide the authorized body for the protection of the rights of personal data subjects, at that body’s request, with the necessary information within 10 days of receiving such a request;
— to publish, or otherwise provide unrestricted access to, this Personal Data Processing Policy;
— to take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision or dissemination of personal data, and from other unlawful actions in respect of personal data;
— to stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— to perform other duties provided for by the Personal Data Law.
4. Main rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
— to receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— to demand that the operator clarify their personal data and block or destroy it if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take the measures provided by law to protect their rights;
— to set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
— to withdraw consent to the processing of personal data, and also to submit a demand to stop the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects, or in court, against unlawful actions or inaction of the Operator in processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— to provide the Operator with accurate data about themselves;
— to inform the Operator of any clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without that subject’s consent, bear liability in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data are processed on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predefined and lawful purposes. Processing of personal data that is incompatible with the purposes of its collection is not allowed.
5.3. Merging databases containing personal data that are processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meet the purposes of their processing may be processed.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of processing.
5.6. When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, their relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that makes it possible to identify the personal data subject for no longer than the purposes of processing require, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. The personal data processed are destroyed or depersonalized when the purposes of processing have been achieved or when the need to achieve those purposes is lost, unless otherwise provided by federal law.
6. Purposes of personal data processing
| Purpose of processing | informing the User by sending emails |
| Personal data |
|
| Legal grounds |
|
| Types of personal data processing |
|
7. Conditions of personal data processing
7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a court judgment, or of an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data are processed to which access by an unlimited group of persons has been given by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the collection, storage, transfer and other types of processing of personal data
The security of the personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User’s personal data will never, under any circumstances, be passed to third parties, except in cases connected with compliance with applicable legislation or where the personal data subject has given the Operator consent to pass the data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are found, the User can update them independently by sending the Operator a notice to the Operator’s email address tech@polygon.fm marked “Update of personal data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by an agreement or applicable legislation.
The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notice by email to the Operator’s email address tech@polygon.fm marked “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers named in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than providing access), as well as on the processing or conditions of processing (other than obtaining access) of personal data permitted for dissemination, do not apply in cases where personal data are processed in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than the purposes of processing require, unless the storage period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor.
8.9. The processing of personal data may be terminated upon the achievement of the purposes of processing, the expiry of the personal data subject’s consent, the withdrawal of consent by the personal data subject or a demand to stop processing, and also upon the discovery of unlawful processing of personal data.
9. List of actions performed by the Operator with the personal data received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained over information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before starting any cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such a notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to which cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User can obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator by email at tech@polygon.fm.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://polygon.fm/privacy.