1. General Provisions
This personal data processing policy is drawn up 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 Elena Samuel Design Bureau (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of their rights to privacy, personal, and family information.
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://elena-samuel.ru/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data is the processing of personal data using computer technology.
2.2. Blocking of personal data is the temporary suspension of the processing of personal data (except in cases where the processing is necessary to clarify personal data).
2.3. A website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://elena-samuel.ru/.
2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Personal data anonymization is an action that makes it impossible to determine the ownership of personal data to a specific User or other subject of personal data without using additional information.
2.6. Personal data processing is any action (operation) or a set of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, a municipal body, a legal entity or an individual, 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 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://elena-samuel.ru/.
2.9. Personal data permitted by the subject of personal data for distribution is personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in accordance with the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.10. User - any visitor to the website https://elena-samuel.ru/.
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 is any action aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including the publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to a foreign government agency, a foreign individual, or a foreign legal entity in a foreign country.
2.14. Destruction of personal data — any actions that result in the destruction of personal data.
2.14. Destruction of personal data — any actions that result in the permanent destruction of personal data, making it impossible to restore the content of personal data in the personal data information system, and/or the destruction of physical media containing personal data.
3. The Operator's Basic Rights and Obligations
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the subject of personal data;
— in the event that the subject of personal data revokes their consent to the processing of personal data, or submits a request to terminate the processing of personal data, the Operator may continue to process personal data without the subject of personal data's consent if there are grounds specified in the Law on Personal Data;
— to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject with information regarding the processing of his/her personal data upon request;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to the requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— provide the necessary information to the authorized body for the protection of the rights of personal data subjects upon request of this body within 10 days from the date of receipt of such a request;
— to publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, and distribution of personal data, as well as from other illegal actions in relation to personal data
— to stop the transfer (distribution, provision, access) of personal data, stop the processing, and destroy personal data in accordance with the procedures and cases provided for by the Personal Data Law;
— to fulfill other obligations provided for by the Personal Data Law.
4. Basic rights and obligations of subjects of personal data
4.1. Subjects of personal data have the right to:
— receive information concerning the processing of his personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for the disclosure of such personal data. The list of information and the procedure for its receipt are established by the Law on Personal Data;
— to request the operator to clarify its personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and to take legal measures to protect its rights;
— to set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator's unlawful actions or inaction when processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, are liable under the laws of the Russian Federation.
5. Principles of processing personal data
5.1. Processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate goals. The processing of personal data that is incompatible with the purposes of collecting personal data is prohibited.
5.3. The merging of databases containing personal data that is processed for incompatible purposes is prohibited.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the declared purposes of processing. Excessive processing of personal data in relation to the declared purposes of processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the subject of personal data for no longer than necessary for the purposes of processing personal data, unless a longer period of storage is required by federal law or a contract in which the subject of personal data is a party, beneficiary, or guarantor. Personal data processed is destroyed or anonymized upon achievement of the processing goals or upon loss of necessity to achieve these goals, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing
informing the User by sending e-mails
Personal data
surname, name, patronymic
e-mail address
telephone numbers
Legal Basis
Contracts concluded between the operator and the personal data subject.
Types of Personal Data Processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data;
Sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject.
7.2. Processing is necessary to achieve goals stipulated by international treaties of the Russian Federation or law, and to perform functions, powers, and duties imposed on the operator by Russian legislation.
7.3. Processing is required for the administration of justice, enforcement of court decisions, or acts of other authorities under Russian law on enforcement proceedings.
7.4. Processing is necessary for the performance of a contract where the personal data subject is a party, beneficiary, or guarantor, or for concluding a contract initiated by the subject.
7.5. Processing is necessary to protect the legitimate interests of the operator or third parties, or to achieve socially significant goals, provided the rights and freedoms of the personal data subject are not violated.
7.6. Processing involves personal data made publicly available by the subject or at their request.
7.7. Processing involves personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Processing of Personal Data
The Operator ensures the security of processed personal data by implementing legal, organizational, and technical measures to fully comply with current personal data protection laws.
8.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will not be transferred to third parties, except as required by law or with the subject’s consent for fulfilling obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by notifying the Operator via email at info@elena-samuel.ru with the subject "Updating Personal Data."
8.4. The processing period is determined by the purposes for which the data was collected, unless otherwise specified by contract or law. The User may withdraw consent at any time by emailing info@elena-samuel.ru with the subject "Withdrawal of Consent to Personal Data Processing."
8.5. Information collected by third-party services (e.g., payment systems, communication tools) is stored and processed by those operators in accordance with their agreements and privacy policies. The Operator is not liable for the actions of such third parties.
8.6. Restrictions on transfer or processing of personal data do not apply when processing is in state, public, or other public interests under Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. Personal data is stored only as long as necessary to achieve processing purposes, unless otherwise specified by law or contract.
8.9. Processing may cease upon achieving its purposes, expiration of consent, withdrawal of consent, or identification of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, updates, extracts, uses, transfers, anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data, with or without transmission via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before conducting cross-border transfers, the Operator must notify the authorized body for personal data subject rights protection.
10.2. Prior to such notification, the Operator must obtain relevant information from foreign authorities or entities involved in the transfer.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data must not disclose or distribute it without the subject’s consent, except as provided by federal law.
12. Final Provisions
12.1. The User may seek clarifications on personal data processing by contacting the Operator via email at info@elena-samuel.ru.
12.2. This document may be updated to reflect changes in the Operator’s personal data processing policy. The policy remains effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at: https://elena-samuel.ru/privacy/.
This personal data processing policy is drawn up 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 Elena Samuel Design Bureau (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of their rights to privacy, personal, and family information.
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://elena-samuel.ru/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data is the processing of personal data using computer technology.
2.2. Blocking of personal data is the temporary suspension of the processing of personal data (except in cases where the processing is necessary to clarify personal data).
2.3. A website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://elena-samuel.ru/.
2.4. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Personal data anonymization is an action that makes it impossible to determine the ownership of personal data to a specific User or other subject of personal data without using additional information.
2.6. Personal data processing is any action (operation) or a set of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, a municipal body, a legal entity or an individual, 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 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://elena-samuel.ru/.
2.9. Personal data permitted by the subject of personal data for distribution is personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in accordance with the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.10. User - any visitor to the website https://elena-samuel.ru/.
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 is any action aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including the publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to a foreign government agency, a foreign individual, or a foreign legal entity in a foreign country.
2.14. Destruction of personal data — any actions that result in the destruction of personal data.
2.14. Destruction of personal data — any actions that result in the permanent destruction of personal data, making it impossible to restore the content of personal data in the personal data information system, and/or the destruction of physical media containing personal data.
3. The Operator's Basic Rights and Obligations
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the subject of personal data;
— in the event that the subject of personal data revokes their consent to the processing of personal data, or submits a request to terminate the processing of personal data, the Operator may continue to process personal data without the subject of personal data's consent if there are grounds specified in the Law on Personal Data;
— to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject with information regarding the processing of his/her personal data upon request;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to the requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— provide the necessary information to the authorized body for the protection of the rights of personal data subjects upon request of this body within 10 days from the date of receipt of such a request;
— to publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, and distribution of personal data, as well as from other illegal actions in relation to personal data
— to stop the transfer (distribution, provision, access) of personal data, stop the processing, and destroy personal data in accordance with the procedures and cases provided for by the Personal Data Law;
— to fulfill other obligations provided for by the Personal Data Law.
4. Basic rights and obligations of subjects of personal data
4.1. Subjects of personal data have the right to:
— receive information concerning the processing of his personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for the disclosure of such personal data. The list of information and the procedure for its receipt are established by the Law on Personal Data;
— to request the operator to clarify its personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and to take legal measures to protect its rights;
— to set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator's unlawful actions or inaction when processing their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, are liable under the laws of the Russian Federation.
5. Principles of processing personal data
5.1. Processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate goals. The processing of personal data that is incompatible with the purposes of collecting personal data is prohibited.
5.3. The merging of databases containing personal data that is processed for incompatible purposes is prohibited.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the declared purposes of processing. Excessive processing of personal data in relation to the declared purposes of processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the identification of the subject of personal data for no longer than necessary for the purposes of processing personal data, unless a longer period of storage is required by federal law or a contract in which the subject of personal data is a party, beneficiary, or guarantor. Personal data processed is destroyed or anonymized upon achievement of the processing goals or upon loss of necessity to achieve these goals, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing
informing the User by sending e-mails
Personal data
surname, name, patronymic
e-mail address
telephone numbers
Legal Basis
Contracts concluded between the operator and the personal data subject.
Types of Personal Data Processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data;
Sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject.
7.2. Processing is necessary to achieve goals stipulated by international treaties of the Russian Federation or law, and to perform functions, powers, and duties imposed on the operator by Russian legislation.
7.3. Processing is required for the administration of justice, enforcement of court decisions, or acts of other authorities under Russian law on enforcement proceedings.
7.4. Processing is necessary for the performance of a contract where the personal data subject is a party, beneficiary, or guarantor, or for concluding a contract initiated by the subject.
7.5. Processing is necessary to protect the legitimate interests of the operator or third parties, or to achieve socially significant goals, provided the rights and freedoms of the personal data subject are not violated.
7.6. Processing involves personal data made publicly available by the subject or at their request.
7.7. Processing involves personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collecting, Storing, Transferring, and Other Processing of Personal Data
The Operator ensures the security of processed personal data by implementing legal, organizational, and technical measures to fully comply with current personal data protection laws.
8.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will not be transferred to third parties, except as required by law or with the subject’s consent for fulfilling obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by notifying the Operator via email at info@elena-samuel.ru with the subject "Updating Personal Data."
8.4. The processing period is determined by the purposes for which the data was collected, unless otherwise specified by contract or law. The User may withdraw consent at any time by emailing info@elena-samuel.ru with the subject "Withdrawal of Consent to Personal Data Processing."
8.5. Information collected by third-party services (e.g., payment systems, communication tools) is stored and processed by those operators in accordance with their agreements and privacy policies. The Operator is not liable for the actions of such third parties.
8.6. Restrictions on transfer or processing of personal data do not apply when processing is in state, public, or other public interests under Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. Personal data is stored only as long as necessary to achieve processing purposes, unless otherwise specified by law or contract.
8.9. Processing may cease upon achieving its purposes, expiration of consent, withdrawal of consent, or identification of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, updates, extracts, uses, transfers, anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data, with or without transmission via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before conducting cross-border transfers, the Operator must notify the authorized body for personal data subject rights protection.
10.2. Prior to such notification, the Operator must obtain relevant information from foreign authorities or entities involved in the transfer.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data must not disclose or distribute it without the subject’s consent, except as provided by federal law.
12. Final Provisions
12.1. The User may seek clarifications on personal data processing by contacting the Operator via email at info@elena-samuel.ru.
12.2. This document may be updated to reflect changes in the Operator’s personal data processing policy. The policy remains effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at: https://elena-samuel.ru/privacy/.