1. General Provisions
This Privacy Policy regarding the processing of personal data has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by Gladkov Andrey Andreevich (hereinafter referred to as the “Operator”) to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of privacy and personal and family confidentiality, to be its highest priority and essential condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website
http://gladcowfilm.com.2. Basic Terms Used in the Policy2.1.
Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at
http://gladcowfilm.com.2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual independently or jointly organizing and/or carrying out the processing of personal data and determining the purposes of personal data processing, the composition of personal data subject to processing, and actions performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website
http://gladcowfilm.com.2.9. Personal data permitted for distribution by the personal data subject — personal data to which access is granted to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for distribution in accordance with the Personal Data Law.
2.10. User — any visitor to the website
http://gladcowfilm.com.2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons or familiarizing an unlimited group of persons with personal data, including publication in the media, posting in information and telecommunication networks, or granting 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 a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or destruction of physical media containing personal data.
3. Basic 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 personal data subject;
— continue processing personal data without the consent of the personal data subject in cases where the subject withdraws consent or submits a request to stop processing, provided there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations stipulated by the Personal Data Law and related regulations, unless otherwise provided by federal law.
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 in accordance with the legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of personal data subjects’ rights with the necessary information within 10 days of receiving a request;
— publish or otherwise ensure unrestricted access to this Policy;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
— stop the transfer, processing, and destroy personal data in cases предусмотренных by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Basic 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 by federal laws;
— demand clarification, blocking, or destruction of personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing;
— require prior consent for processing personal data for the purpose of promoting goods, works, and services;
— withdraw consent to the processing of personal data and request termination of processing;
— appeal unlawful actions or inaction of the Operator to the authorized body or in court;
— exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate personal data;
— inform the Operator about updates or changes to their personal data.
4.3.
Persons who provide inaccurate information about themselves or another personal data subject without their consent shall bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Processing is limited to achieving specific, predetermined, and lawful purposes.
5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data relevant to the purposes of processing shall be processed.
5.5. The content and scope of processed personal data must correspond to the stated purposes of processing.
5.6. The Operator ensures the accuracy, sufficiency, and relevance of personal data and takes necessary measures to update or delete incomplete or inaccurate data.
5.7. Personal data shall be stored in a form allowing identification of the subject no longer than required by the purposes of processing unless otherwise established by federal law or agreement.
6. Purposes of Personal Data ProcessingPurpose of Processing
Providing the User with access to services, information, and/or materials available on the website, as well as informing the User by sending emails.
Personal Data
— surname, first name, patronymic
— email address
— phone numbers
Legal Grounds
Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection”.
Types of Personal Data Processing
Sending informational emails to the User’s email address.
7. Conditions for Processing Personal Data
7.1. Personal data is processed with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided by international treaties or laws of the Russian Federation.
7.3. Processing is necessary for the administration of justice or execution of judicial acts.
7.4. Processing is necessary for the performance of a contract involving the personal data subject.
7.5. Processing is necessary to protect the legitimate interests of the Operator or third parties, provided the rights and freedoms of the subject are not violated.
7.6. Processing of publicly available personal data provided by the subject is permitted.
7.7. Processing of personal data subject to mandatory publication or disclosure under federal law is permitted.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with applicable legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. Personal data will never be transferred to third parties except as required by law or with the subject’s consent.
8.3. Users may update their personal data by notifying the Operator via email at
andy.gladkov@gmail.com with the subject line “Personal Data Update”.
8.4. The processing period for personal data is determined by the purposes for which the data was collected unless otherwise provided by law or agreement.
Users may withdraw consent at any time by sending an email to
andy.gladkov@gmail.com with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. Information collected by third-party services, including payment systems and communication providers, is processed according to their own agreements and privacy policies. The Operator is not responsible for the actions of such third parties.
8.6. Restrictions established by the personal data subject on the transfer or processing of publicly available personal data do not apply in cases provided by Russian legislation.
8.7. The Operator ensures confidentiality of personal data.
8.8. Personal data is stored no longer than required for the purposes of processing unless otherwise provided by federal law or agreement.
8.9. Termination of personal data processing may occur upon achievement of processing purposes, expiration of consent, withdrawal of consent, request to terminate processing, or detection of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, updating, extraction, use, transfer, depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without transfer via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before carrying out cross-border transfer of personal data, the Operator must notify the authorized body responsible for the protection of personal data subjects’ rights.
10.2. Before submitting such notification, the Operator must obtain relevant information from foreign authorities, individuals, or legal entities receiving the personal data.
11. Confidentiality of Personal Data
The Operator and other persons who have 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 federal law.
12. Final Provisions
12.1. Users may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at
andy.gladkov@gmail.com.12.2. Any changes to this Policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available at:
http://gladcowfilm.com/privacy_policy