Privacy Policy

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by IP Grinko Kristina Olegovna (hereinafter referred to as the Operator).
1.1. The Operator sets compliance with the rights and freedoms of individuals as the most important goal and condition for carrying out its activities in processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Operator's policy 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 https://grinchristin.com.

1. Key Concepts 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 the processing of personal data (except in cases where processing is necessary to clarify 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://grinchristin.com.
2.4. Personal data information system - a set of personal data contained in databases and ensuring their processing by information technology and technical means.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine the belonging of personal data to a specific User or other subject of personal data without using additional information.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, 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 carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or determinable User of the website https://grinchristin.com.
2.9. Personal data allowed for distribution by the subject of personal data - personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent to the processing of personal data allowed for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.10. User - any visitor to the website https://grinchristin.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 acquainting an unlimited number of persons with personal data, including disclosure of personal data in the media, placing in information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual, or foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data are destroyed irreversibly with the impossibility of further restoring the content of personal data in the personal data information system and/or personal data material carriers being destroyed.

1. Operator's Rights and Obligations

3.1. The Operator has the right to:

• receive from the data subject accurate information and/or documents containing personal data;
• in the event of the data subject's withdrawal of consent to the processing of personal data, as well as the submission of a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
• 3.2. The Operator is obliged to:
• provide the data subject, upon request, with information regarding the processing of their personal data;
• organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the necessary information to the authorized body for the protection of the rights of data subjects upon request of this body within 10 days from the date of receipt of such request;
• publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
• cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedures and cases provided for by the Personal Data Law;
• fulfill other obligations provided for by the Personal Data Law.

4. 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 for by federal laws. The information is provided to the data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• demand from the operator the clarification of their personal data, their blocking, or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take legal measures provided by law to protect their rights;
• impose a condition of prior consent when processing personal data for the purpose of marketing goods, works, and services;
• withdraw consent to the processing of personal data, as well as submit a request to stop the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or through legal proceedings against the unlawful actions or inaction of the Operator in the processing of their personal data;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate information about themselves;
• inform the Operator of any clarification (update, change) of their personal data.

4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another personal data subject without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that corresponds to the purposes of their processing shall be subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured during the processing of personal data. The Operator takes necessary measures and/or ensures their adoption to delete or rectify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, the party to which, the beneficiary or guarantor of which is the data subject. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of Processing
Processing user responses for further communication and collaboration.

Personal Data
Surname, first name, patronymic
Email address
Nickname on Telegram (https://telegram.org/)


Legal Basis

• Federal Law "On Information, Information Technologies, and Information Protection" dated July 27, 2006, No. 149-FZ

Types of Personal Data Processing

• Transfer of personal data

7. Terms of Personal Data Processing
7.1. Personal data processing is carried out with the consent of the data subject for the processing of their personal data.
7.2. Processing of personal data is necessary for the achievement of purposes provided for 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.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract, the party to which, the beneficiary, or the guarantor of which is the data subject, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be the beneficiary or the guarantor.
7.5. 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 goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing of personal data is carried out for personal data made publicly available by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure is carried out in accordance with federal law.

8. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. User's personal data will never be transferred to third parties under any circumstances, except in cases related to the execution of current legislation or if the data subject has given consent to the Operator for the transfer of data to a third party for the performance of obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator via email to the Operator's email address grinkodesign@gmail.com with the subject "Updating Personal Data."
8.4. The processing period of personal data is determined by the achievement of the purposes for which the personal data were collected, unless otherwise provided by a contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address grinkodesign@gmail.com with the subject "Withdrawal of Consent to the Processing of Personal Data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The data subject is bound by the terms of these documents. The Operator is not responsible for the actions of third parties, including service providers mentioned in this section.
8.6. Prohibitions established by the data subject on the transfer (except for providing access) or processing (except for obtaining access) of personal data allowed for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identifying the data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, the party to which, the beneficiary or guarantor of which is the data subject.
8.9. The termination of personal data processing may be conditioned by the achievement of the purposes of processing personal data, expiration of the consent period of the data subject, withdrawal of consent by the data subject, or a request to cease processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator conducts automated processing of personal data with the receipt and/or transmission of obtained information through information and telecommunication networks or without them.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of their intention to carry out such transfer (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other parties who have access to personal data are obligated 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 may obtain any clarifications on matters related to the processing of their personal data by contacting the Operator via email at grinkodesign@gmail.com.
12.2. Any changes to the policy of processing personal data by the Operator 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 freely available on the Internet at https://grinchristin.com/privacy/en.