Personal Data Processing Policy

1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter - the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by the Individual Entrepreneur Bash'yan Philipp Garrievich (hereinafter - the Operator).
1.1. The Operator sets as its primary goal and condition for conducting its activities the observance of the rights and freedoms of a person and citizen when processing their personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Policy of the Operator in relation to personal data processing (hereinafter - the Policy) applies to all information that the Operator can obtain about visitors to the website https://doit.fit.

2. Main 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 - a temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website - a combination of graphic and informational materials, as well as computer software and databases, ensuring their availability on the internet at the network address https://doit.fit.
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 as a result of which it is impossible to determine without using additional information the affiliation of personal data to a specific User or another subject of personal data.
2.6. Personal data processing - any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or processing personal data, and also determining the purposes of personal data processing, the composition of personal data to be processed, 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://doit.fit.
Certainly! Here's the translation of the provided text into English:
2.9. Personal data allowed for dissemination by the subject of personal data** - personal data to which access by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data allowed for dissemination).

2.10. User - any visitor of the website https://doit.fit.

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 (transmission of personal data) or acquainting an unlimited number of persons with personal data, including publicizing personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other way.

2.13.Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the 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 irreversibly destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Primary rights and responsibilities of the Operator
3.1. The Operator has the right to:
- Receive accurate information and/or documents containing personal data from the subject of personal data;
- In case of withdrawal of consent to process personal data by the subject, as well as sending a request to stop processing personal data, the Operator is entitled to continue processing personal data without the consent of the subject if there are grounds specified in the Personal Data Law;
- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and 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 obligated to:
- Provide the subject of personal data, upon his request, with information regarding the processing of his personal data;
- Organize the processing of personal data in accordance with the current legislation of the Russian Federation;
- Respond to inquiries and requests of 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 from the date of receiving such a request;
- Publish or otherwise ensure unrestricted access to this Policy concerning personal data processing;
- Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions concerning personal data;
- Terminate the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- Fulfill other obligations stipulated by the Personal Data Law.

4. Primary rights and responsibilities of personal data subjects
4.1. Personal data subjects have the right to:
- Receive information related to the processing of their personal data, except in cases provided by federal laws. The information is provided by the Operator to the personal data subject in an accessible form and should not include personal data relating to other personal data subjects, except when there are legitimate reasons for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
- Demand that the operator clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purpose, and also take measures prescribed by law to protect their rights;
- Set a condition of preliminary consent when processing personal data for marketing purposes;
- Withdraw consent to the processing of personal data and also demand that the processing of personal data be stopped;
- Appeal to the authorized body for the protection of personal data subjects' rights or in court against the illegal actions or inaction of the Operator in processing their personal data;
- Exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obligated to:
- Provide the Operator with accurate information about themselves;
- Inform the Operator about the refinement (update, change) of their personal data.

4.3. Persons who provided the Operator with false information about themselves or information about another personal data subject without the latter's consent bear responsibility 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. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.
5.3. Merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that meets the processing objectives is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. Redundancy of the processed personal data relative to the stated processing objectives is not allowed.
5.6. The accuracy, sufficiency, and, when necessary, relevance of personal data to the processing purposes are ensured during personal data processing. The Operator takes necessary measures and/or ensures their adoption to delete or refine incomplete or inaccurate data.
5.7. Personal data is stored in a format that allows the identification of the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract in which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing objectives or if there is no longer a need to achieve these objectives unless otherwise provided by federal law.

6. Purposes of personal data processing
Processing purpose: To provide the User with access to services, information, and/or materials contained on the website.
Personal data: Surname, first name, patronymic, email address, year, month, date, and place of birth.
Legal grounds: Contracts concluded between the operator and the personal data subject.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.

7. Conditions for processing personal data
7.1. Personal data is processed with the consent of the personal data subject.
7.2. Personal data processing is necessary to achieve the goals set by an international treaty of the Russian Federation or by law, to perform functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a court decision, an act of another body or official, which must be executed according to the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is required for the execution of a contract where the personal data subject is a party, beneficiary, or guarantor. It is also necessary for concluding a contract initiated by the personal data subject or a contract in which the subject will be the beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. There is processing of personal data to which access has been provided by the personal data subject or upon his request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data that should be published or disclosed in accordance with federal law is conducted.

8. Procedure for collecting, storing, transferring, and other types of personal data processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

**8.2.** The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the implementation of current legislation or in the event that the personal data subject has given consent to the Operator to transfer data to a third party for fulfilling obligations under a civil contract.
**8.3.** If inaccuracies are found in the personal data, the User can update them independently by sending a notification to the Operator's email address help@doit.fit with the note "Updating personal data."
**8.4.** The personal data processing period is determined by achieving the purposes for which the personal data was collected, unless a different period is provided for by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification via email to the Operator's email address help@doit.fit with the note "Withdrawal of consent to personal data processing."
**8.5.** All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the said parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject agrees and/or is familiar with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
**8.6.** Restrictions set by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for access) of personal data allowed for distribution, are not valid in cases of processing personal data in state, public, and other public interests defined by Russian legislation.
**8.7.** The Operator ensures the confidentiality of personal data during processing.
**8.8.** The Operator stores personal data in a form that allows identifying the personal data subject, no longer than the purposes of personal data processing require unless the storage period for personal data is set by federal law or a contract in which the personal data subject is a party, beneficiary, or guarantor.
**8.9.** Conditions for terminating the processing of personal data may include achieving the purposes of personal data processing, the expiration of the personal data subject's consent period, withdrawal of consent by the personal data subject, or a requirement to stop processing personal data, as well as identifying the illegal processing of personal data.

**9. List of actions performed by the Operator with the received personal data**
**9.1.** The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
**9.2.** The Operator conducts automated processing of personal data with the receipt and/or transfer of received information via information and telecommunication networks or without such.

**10. Cross-border transfer of personal data**
**10.1.** Before starting cross-border data transfer activities, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notice of the intention to process personal data).
**10.2.** Before submitting the aforementioned notification, the Operator must obtain relevant information from the authorities of a foreign country, foreign individuals, and foreign legal entities to which the 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 obligated not to disclose to third parties and not to disseminate personal data 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 issues of interest related to the processing of their personal data by contacting the Operator via email at help@doit.fit.
**12.2.** Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
**12.3.** The current version of the Policy is freely available on the Internet at https://doit.fit/privacy.