Privacy Policy

1. General Provisions

1.1. This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 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 taken by GG Donations (hereinafter "the Operator").

1.2. The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets, as its most important goal and condition for its activities.

1.3. This Operator's policy regarding the processing of personal data (hereinafter "the Policy") applies to all information that the Operator may obtain about visitors to the website ggdonations.com.

2. Key Definitions 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 suspension of personal data processing (except when processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, that make them available on the internet at ggdonations.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 that make it impossible to determine, without additional information, the attribution of personal data 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 or without the use of automation on 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 body, municipal body, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of 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 ggdonations.com.

2.9. Personal data authorized by the data subject for distribution — personal data to which an unlimited number of persons are granted access by the data subject by giving consent to process personal data authorized for distribution in the manner prescribed by the Personal Data Law (hereinafter "personal data authorized for distribution").

2.10. User — any visitor to the website ggdonations.com.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication in mass 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 — transfer of personal data to the territory of a foreign state to a foreign government body, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further recovery of the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

3.1.1. Receive accurate information and/or documents containing personal data from the personal data subject.

3.1.2. In the event that the personal data subject withdraws consent to the processing of personal data, the Operator may continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law.

3.1.3. 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:

3.2.1. Provide the personal data subject, upon request, with information regarding the processing of their personal data.

3.2.2. Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation.

3.2.3. Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.

3.2.4. Report to the authorized body for the protection of the rights of personal data subjects, upon request of that body, the necessary information within 30 days from the date of receiving such request.

3.2.5. Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data.

3.2.6. Take 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 unlawful actions with respect to personal data.

3.2.7. Cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided by the Personal Data Law.

3.2.8. Fulfill other obligations provided by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

4.1.1. Receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it shall not contain personal data relating to other personal data subjects, except in cases where there are lawful grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law.

4.1.2. Require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights.

4.1.3. Impose a condition of prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market.

4.1.4. Withdraw consent to the processing of personal data.

4.1.5. 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 the processing of their personal data.

4.1.6. Exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obligated to:

4.2.1. Provide the Operator with accurate data about themselves.

4.2.2. Inform the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, are liable under the legislation of the Russian Federation.

5. Personal Data the Operator May Process

5.1. Last name, first name, patronymic, nickname.

5.2. Email address.

5.3. The website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others).

5.4. The above data is hereinafter collectively referred to as Personal Data in this Policy.

5.5. The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.

5.6. The processing of personal data authorized for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions provided by Article 10.1 of the Personal Data Law are observed.

5.7. The User's consent to the processing of personal data authorized for distribution is obtained separately from other consents to the processing of their personal data. The conditions provided by, in particular, Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.8. Consent to the processing of personal data authorized for distribution is provided by the User directly to the Operator.

5.9. The Operator is obligated, no later than three business days from the date of receiving the User's said consent, to publish information about the processing conditions, about the existence of prohibitions and conditions on the processing by an unlimited number of persons of personal data authorized for distribution.

5.10. The transfer (distribution, provision, access) of personal data authorized by the personal data subject for distribution must be ceased at any time at the request of the personal data subject. Such request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is to be ceased. The personal data specified in such request may only be processed by the Operator to whom it was directed.

5.11. Consent to the processing of personal data authorized for distribution ceases to be effective upon the Operator's receipt of the request specified in clause 5.10 of this Policy regarding the processing of personal data.

6. Principles of Personal Data Processing

6.1. The processing of personal data is carried out on a lawful and fair basis.

6.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

6.3. The combining of databases containing personal data processed for purposes that are incompatible with one another is not permitted.

6.4. Only personal data that meet the purposes of their processing are subject to processing.

6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data relative to the stated purposes is not permitted.

6.6. 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 necessary measures and/or ensures that incomplete or inaccurate data are deleted or clarified.

6.7. Personal data is stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in the event that the need to achieve those purposes is lost, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing

7.1. The purpose of processing the User's personal data:

7.1.1. Informing the User by sending emails.

7.1.2. Entering into, performing, and terminating civil law contracts.

7.1.3. Providing the User with access to services, information, and/or materials available on the website ggdonations.com.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may always opt out of receiving informational messages by sending the Operator an email at [email protected] with the subject "Opt out of notifications about new products, services, and special offers."

7.3. Anonymized User data collected through internet statistics services is used to gather information about User activity on the website and to improve the quality of the website and its content.

8. Legal Bases for Personal Data Processing

8.1. The legal bases for the Operator's processing of personal data are:

8.1.1. The Operator's charter (founding) documents.

8.1.2. Federal laws and other regulatory legal acts in the field of personal data protection.

8.1.3. User consent to the processing of their personal data and to the processing of personal data authorized for distribution.

8.2. The Operator processes the User's personal data only if they are filled in and/or submitted by the User independently through special forms on the website ggdonations.com or sent to the Operator by email. By filling in the corresponding forms and/or submitting their personal data to the Operator, the User expresses consent to this Policy.

8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (cookies are enabled and JavaScript technology is allowed).

8.4. The personal data subject independently decides on the provision of their personal data and gives consent freely, of their own will, and in their own interest.

9. Conditions for Personal Data Processing

9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

9.2. The processing of personal data is necessary for achieving the purposes provided by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

9.6. Processing is carried out on personal data that has been made publicly available by the personal data subject or at their request (hereinafter "publicly available personal data").

9.7. Processing is carried out on personal data that is subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

10.1. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

10.2. The Operator ensures the preservation of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

10.3. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or when the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.

10.4. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator's email address [email protected] with the subject "Update of personal data."

10.5. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided by a contract or current legislation.

10.6. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at [email protected] with the subject "Withdrawal of consent to the processing of personal data."

10.7. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by said entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or User is obligated to familiarize themselves with said documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

10.8. Prohibitions on transfer (other than providing access) and on processing or conditions of processing (other than obtaining access) of personal data authorized for distribution, established by the personal data subject, do not apply in cases where personal data is processed in state, public, and other public interests as defined by the legislation of the Russian Federation.

10.9. The Operator ensures the confidentiality of personal data during processing.

10.10. The conditions for ceasing the processing of personal data may include the achievement of the purposes of processing, the expiration of the personal data subject's consent or the withdrawal of consent by the personal data subject, as well as the identification of unlawful processing of personal data.

11. List of Actions Performed by the Operator with Personal Data

11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of information obtained via information and telecommunication networks or without such.

12. Cross-Border Transfer of Personal Data

12.1. Before carrying out cross-border transfer of personal data, the Operator is obligated to ensure that the foreign state to whose territory the personal data is intended to be transferred provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if the personal data subject has given written consent to the cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

13.1. The Operator and other persons who have gained access to personal data are obligated not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final Provisions

14.1. The User may obtain any clarifications on matters of interest regarding the processing of their personal data by contacting the Operator via email at [email protected].

14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is effective indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available on the internet at ggdonations.com.