IVANY GALLERY

1. General Provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Gleb Alexandrovich Ivaniy (hereinafter — the Operator).
1.1. The Operator’s primary goal and condition for carrying out its activities is the observance of human and civil rights and freedoms when processing personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://ivanygallery.com.

2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://ivanygallery.com.
2.4. Personal data information system — a set of personal data contained in databases and the technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without additional information, the принадлежность of personal data to a specific user or subject.
2.6. Processing of personal data — any action (operation) or set of actions performed with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
2.7. Operator — a state body, municipal body, legal entity, or individual organizing and/or carrying out personal data processing and determining the purposes and scope of such processing.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable user of the website.
2.9. Personal data permitted for distribution — personal data made publicly accessible by the subject with consent in accordance with the Personal Data Law.
2.10. User — any visitor of the website https://ivanygallery.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group.
2.12. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite number of persons or making it publicly available.
2.13. Cross-border transfer — transfer of personal data to a foreign state or foreign entity.
2.14. Destruction of personal data — actions resulting in irreversible deletion of personal data.

3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information/documents containing personal data;
— continue processing without consent where legally permitted;
— independently determine necessary protection measures.
3.2. The Operator is obliged to:
— provide information on personal data processing upon request;
— organize processing in accordance with Russian law;
— respond to requests from data subjects;
— provide information to authorities within 10 days;
— ensure public access to this Policy;
— implement legal, organizational, and technical protection measures;
— stop processing and destroy data when required;
— fulfill other legal obligations.

4. Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
— receive information about processing;
— request correction, blocking, or deletion;
— require prior consent for marketing use;
— withdraw consent;
— appeal unlawful actions;
— exercise other legal rights.
4.2. Data subjects are obliged to:
— provide accurate data;
— update their data when necessary.
4.3. Individuals providing false data are liable under Russian law.

5. Principles of Personal Data Processing
5.1. Processing is lawful and fair.
5.2. Processing is limited to specific, legitimate purposes.
5.3. Incompatible databases are not merged.
5.4. Only relevant data is processed.
5.5. Data volume must match processing purposes.
5.6. Accuracy and relevance must be ensured.
5.7. Data is stored no longer than necessary.

6. Purposes of Personal Data Processing
Purpose:
Informing users via email.
Personal Data:
Name, Email address.
Legal Basis:
Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection”.
Processing Actions:
Collection, storage, systematization, deletion, depersonalization, and email communication.

7. Conditions for Processing Personal Data
Processing is carried out:
— with consent;
— to fulfill legal obligations;
— for judicial purposes;
— for contract execution;
— for legitimate interests;
— for publicly available data;
— when required by law.

8. Procedure for Collection, Storage, and Transfer
8.1. The Operator ensures data security.
8.2. Data is not shared with third parties except by law or consent.
8.3. Users can update data via info@ivanygallery.com.
8.4. Users can withdraw consent at any time.
8.5. Third-party services process data under their own policies.
8.6. Restrictions do not apply in public interest cases.
8.7. Confidentiality is maintained.
8.8. Data is stored only as long as necessary.
8.9. Processing stops upon achieving purposes or withdrawal of consent.

9. Actions Performed with Personal Data
The Operator performs collection, storage, use, transfer, depersonalization, blocking, deletion, and destruction of personal data, including automated processing.

10. Cross-Border Data Transfer
10.1. The Operator must notify authorities before cross-border transfers.
10.2. Necessary information must be obtained from foreign recipients in advance.

11. Confidentiality of Personal Data
Personal data must not be disclosed without consent unless required by law.

12. Final Provisions
12.1. Users may request clarification via info@ivanygallery.com.
12.2. Changes to the Policy will be reflected in this document.
12.3. The current version is available at: https://ivanygallery.com#privacy.