Policy on the Processing of Personal Data

1. General Provisions
This policy on the processing of personal data has been developed in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ "On Personal Data" (hereinafter - the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Metafora Film LLC (hereinafter - the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of a person and citizen in the processing of his personal data, including the protection of the rights to inviolability of private life, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can receive about visitors to the website [https://metafora.film](https://metafora.film/).
2. Basic 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 - a temporary cessation of the processing of personal data (except for cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as computer software and databases that ensure their availability on the Internet at the network address [https://metafora.film](https://metafora.film/).
2.4. Information system of personal data - a set of personal data contained in databases and providing their processing of information technologies and technical means.
2.5. Anonymization of personal data - actions as a result of which it is impossible to determine without the use of additional information the belonging of personal data to a specific User or other subject of personal data.
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 (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or physical person, independently or jointly with other persons organizing

3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
  • Receive from the subject of personal data reliable information and/or documents containing personal data;
  • In the event of the withdrawal of consent to the processing of personal data by the subject of personal data, as well as the sending of a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 for by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
  • Provide the subject of personal data with information about the processing of his personal data upon his request;
  • Organize the processing of personal data in the manner established by the current 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;
  • Report to the authorized body for the protection of the rights of personal data subjects the necessary information within 10 days from the date of receipt of such a request;
  • Publish or otherwise provide unrestricted access to this Policy on personal data processing;
  • Take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
  • Terminate the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Law on Personal Data;
  • Perform other duties provided for by the Law on Personal Data.

4.Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
  • Receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator to the personal data subject in an accessible form, and it should not contain personal data related to other personal data subjects, except when there are legal grounds for disclosing such personal data. The list of information and order of its receipt are established by the Personal Data Law;
  • Demand from the operator the clarification of their personal data, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the declared purpose of processing, as well as to take legally provided measures to protect their rights;
  • Set the condition of prior consent when processing personal data for the purposes of promoting goods, works, and services on the market;
  • Withdraw consent to the processing of personal data, and also to send a request to cease the processing of personal data;
  • Appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing 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 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 unreliable information about themselves, or information about another personal data subject without the latter's consent, are liable in accordance with the legislation of the Russian Federation.

5.Principles of personal data processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. Processing of personal data is limited to achieving specific, pre-determined, and legitimate goals. Processing of personal data incompatible with the purposes of collecting personal data is not allowed. 5.3. The combination of databases containing personal data processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the declared purposes of processing. Excessive processing of personal data is not allowed.

6.Purpose of personal data processing Purpose of processing: conclusion, execution and termination of civil contracts Personal data:
  • surname, name, patronymic
  • email address
  • phone numbers Legal basis:
  • Federal Law "On Information, Information Technologies and Protection of Information" of July 27, 2006 N 149-FZ Types of personal data processing:
  • Sending informational letters to the email address
7.Conditions for processing personal data
7.1. Personal data is processed with the consent of the personal data subject to the processing of his personal data.
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation of the 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, the execution of a judicial act, an act of another body or official, which must be executed 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, a party to which or a beneficiary or guarantor under which is a personal data subject, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the beneficiary or 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 personal data subject are not violated.
7.6. Processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at his request (hereinafter - publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8.Procedure for the collection, storage, transfer and other types of personal data processing
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.
8.1. The Operator ensures the safety of personal data and takes all possible measures excluding 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 execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address hello@metafora.film marked "Updating personal data".
8.4. The term of personal data processing is determined by achieving the goals for which personal data were collected unless another term is provided by the contract or current legislation. The user can withdraw his consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator's email address hello@metafora.film marked "Withdrawal of consent to the processing of personal data".
8.5. All information that is collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and / or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, are not valid in cases of processing of personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the personal data storage period is established by federal law, a contract, a party of which, beneficiary or guarantor under which is the subject of personal data.
8.9. The condition for terminating the processing of personal data can be achieving the goals of processing personal data, the expiration of the subject's consent to personal data, withdrawal of consent by the subject of personal data or a requirement to stop processing personal data, as well as detection of unlawful 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 (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such.

10.Cross-Border Transfer of Personal Data
10.1. The Operator, before commencing cross-border transfer of personal data, must notify the authorized body for the protection of personal data subjects about its intention to carry out such transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. The Operator, before submitting the aforementioned notification, is obliged to obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom 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 obliged 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.

12.Final Provisions
12.1. The User can obtain any clarifications on issues of interest related to the processing of his personal data by contacting the Operator via email at hello@metafora.film.
12.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is 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://metafora.film/privacy.