Privacy Policy of MEDIANA AGENCY Llc.

This edition was approved on June 10, 2023.

1. GENERAL PROVISIONS
This personal data processing policy is drawn up in accordance with the requirements of Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter, the “Personal Data Law”) and defines the procedure for processing personal data and the measures to ensure the security of personal data implemented by MEDIANA AGENCY Llc. (legal address: 117452, Moscow, intracity municipal district Zyuzino, Chernomorskiy Boulevard, 17, bldg. 1, fl./prem. 5/I, office 229; OGRN (Primary State Registration Number): 1207700301687; hereinafter, the “Operator”).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to the inviolability of private life, personal and family secrecy, to be its highest priority and a fundamental condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter, the “Policy”) applies to all information that the Operator may obtain about visitors of the website https://medianaagency.ru/.

2. BASIC TERMS USED IN THE POLICY
2.1. User - any visitor of the website https://medianaagency.ru/.
2.2. Operator - a state body, municipal body, legal or natural person which, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and which also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.3. Counterparty - a legal or natural person with whom the Operator enters into contractual relations, except for employment relations.
2.4. Personal data - any information relating directly or indirectly to an identified or identifiable User of the website https://medianaagency.ru/.
2.5. Personal data allowed by the personal data subject for dissemination - personal data to which an unlimited number of persons is granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner provided by the Personal Data Law (hereinafter, “personal data allowed for dissemination”).
2.6. Biometric personal data - information that characterizes the physiological and biological characteristics of a person on the basis of which it is possible to establish that person's identity, and which is used to identify the personal data subject.
2.7. Automated processing of personal data - the processing of personal data using computer equipment.
2.8. Non-automated processing of personal data - any actions with personal data, provided that the use, updating, dissemination, and destruction of personal data are carried out with the direct participation of a person.
2.9. Website - a collection of graphical and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the address https://medianaagency.ru/.
2.10. Information system of personal data - a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.11. Confidentiality of personal data - a requirement mandatory for the Operator or other persons who have gained access to personal data to not disclose to third parties or disseminate personal data without the consent of the personal data subject, unless otherwise authorized by federal law.
2.12. Processing of personal data - any action (operation) or combination of actions performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.13. Blocking of personal data - the temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.14. Anonymization of personal data - actions that result in it being impossible to determine, without additional information, which specific User or other personal data subject the personal data pertain to.
2.15. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.16. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.17. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state, to a foreign state authority, to a foreign individual, or to a foreign legal entity.
2.18. Destruction of personal data - any actions resulting in personal data being irreversibly destroyed with the impossibility of further restoration of the content of personal data in the information system of personal data and/or resulting in the destruction of the tangible media containing personal data.

3. MAIN RIGHTS AND OBLIGATIONS OF THE OPERATOR
3.1. The Operator has the right:
- to receive from the personal data subject accurate information and/or documents containing personal data;
- in the event of the personal data subject’s withdrawal of consent to the processing of personal data, or the submission of a request demanding the cessation of processing of personal data, the Operator is entitled to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided by the Personal Data Law and the 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 obliged:
- to provide the personal data subject, at their request, information concerning the processing of their personal data;
- to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- to respond to inquiries and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- to provide the authorized body for the protection of the rights of personal data subjects, upon request of that body, the necessary information within 10 days from the date of receipt of such request;
- to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
- to take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions with respect to personal data;
- to cease the transfer (dissemination, provision, access) of personal data, to cease processing, and to destroy personal data in the manner and cases provided for by the Personal Data Law;
- to perform other duties provided for by the Personal Data Law.

4. MAIN RIGHTS AND OBLIGATIONS OF THE PERSONAL DATA SUBJECT
4.1. The personal data subject has the right:
- to obtain information concerning the processing of their personal data, except in cases provided for by federal laws. Such information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except when 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;
- to demand that the Operator clarify (update, amend) their personal data, block or destroy it 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 measures provided by law to protect their rights;
- to stipulate as a condition the requirement of prior consent for the processing of their personal data;
- to withdraw consent to the processing of personal data, as well as to send a demand to cease the processing of personal data;
- to appeal unlawful actions or omissions of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
- to exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
- to provide the Operator with accurate data about themselves;
- to inform the Operator of any clarification (updating, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the consent of the latter bear liability in accordance with the legislation of the Russian Federation.

5. PRINCIPLES OF PERSONAL DATA PROCESSING
5.1. The User can obtain materials and information on the Site without registration and without providing personal data, in which case the Operator does not receive or process personal data.
5.2. Processing of personal data is carried out on a lawful and fair basis.
5.3. Processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. It is not allowed to process personal data in ways incompatible with the purposes of personal data collection.
5.4. It is not allowed to combine databases containing personal data if the processing of those databases is carried out for purposes that are incompatible with each other.
5.5. Only personal data that meet the purposes of their processing shall be processed.
5.6. The content and volume of processed personal data must correspond to the stated purposes of processing. The processed personal data must not be excessive in relation to the stated purposes of their processing.
5.7. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of personal data processing must be ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
5.8. Personal data is stored in a form that allows determining the personal data subject, and no longer than required by the purposes of personal data processing, unless a longer storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or if there is no longer a need to achieve those purposes, unless otherwise provided by federal law.

6. PURPOSES OF PERSONAL DATA PROCESSING
6.1. The personal data provided to LLC "MEDIANA AGENCY" are processed to achieve the following purposes:
- the conclusion and execution of contracts with beneficiaries/grantees/scholarship recipients/counterparties;
- the implementation of the legitimate interests of MEDIANA AGENCY Llc.;
- the fulfillment of the obligations imposed on MEDIANA AGENCY Llc. by law, for example, in the case of providing information to authorized state bodies.

7. CONDITIONS FOR PROCESSING PERSONAL DATA
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their 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 by law, and for the discharge of the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, or the execution of a judicial act or an act of another body or official, which is to 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 to which the personal data subject is a party or a beneficiary or guarantor, as well as for entering into a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a 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 purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing of personal data is carried out if personal data have been made publicly accessible by the personal data subject or at their request (hereinafter – publicly available personal data).
7.7. Processing of personal data is carried out in cases where personal data are subject to publication or mandatory disclosure in accordance with federal law.

8. PROCEDURE FOR THE COLLECTION, STORAGE, TRANSFER AND OTHER TYPES OF PROCESSING OF PERSONAL DATA
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 safekeeping of personal data and takes all possible measures to preclude access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has given consent to the Operator for the transfer of data to a third party.
8.3. In the event of detection of inaccuracies in personal data, the User can update the data independently.
8.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or by current legislation. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to the Operator’s email address info@medianaagency.ru with the subject line "Withdrawal of consent to the processing of personal data".
8.5. Any prohibitions established by the personal data subject on the transfer (excluding provision of access) as well as on the processing or conditions of processing (excluding obtaining access) of personal data allowed for dissemination do not apply in cases of processing personal data in state, public and other public interests as defined by the legislation of the Russian Federation.
8.6. In processing personal data, the Operator ensures the confidentiality of personal data.
8.7. Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish that person’s identity (biometric personal data), may be processed by the Operator only with the written consent of the personal data subject.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless a longer period for storing personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. The processing of personal data may be terminated upon the achievement of the purposes of personal data processing, the expiration of the period of validity of the personal data subject’s consent, the withdrawal of consent by the personal data subject or a demand to cease the processing of personal data, as well as upon the detection of unlawful processing of personal data.

9. LIST OF ACTIONS PERFORMED BY THE OPERATOR WITH THE COLLECTED PERSONAL DATA
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without the use of such means.

10. SPECIAL CATEGORIES OF PERSONAL DATA
10.1. The processing by the Operator of special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, health, or intimate life is permitted in the following cases if:
- the personal data subject has given written consent to the processing of their personal data;
- the personal data have been made publicly available by the personal data subject;
- the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, and the legislation of the Russian Federation on pensions for state pension provision and on labor pensions;
- the processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject or the life, health or other vital interests of other persons, and obtaining the consent of the personal data subject is impossible;
- the processing of personal data is carried out for medical and preventive purposes, for establishing a medical diagnosis, or for the provision of medical and medico-social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities who is obliged, in accordance with the legislation of the Russian Federation, to maintain medical confidentiality;
- the processing of personal data is necessary for establishing or exercising the rights of the personal data subject or third parties, as well as in connection with the administration of justice;
- the processing of personal data is carried out in accordance with the legislation on compulsory types of insurance and insurance legislation.
10.2. The processing of special categories of personal data carried out in the cases provided for by paragraph 4 of Article 10 of Federal Law No. 152-FZ must be immediately terminated if the reasons for which it was carried out have been eliminated, unless otherwise provided by federal law. Processing of personal data concerning criminal record may be carried out by the Operator exclusively in cases and in the manner determined in accordance with federal laws.

11. CROSS-BORDER TRANSFER OF PERSONAL DATA
11.1. Before commencing any activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out a cross-border transfer of personal data (such notification is sent separately from the notification of the intention to carry out the processing of personal data).
11.2. Prior to submitting the above notification, the Operator is obliged to obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.

12. CONFIDENTIALITY OF PERSONAL DATA
12.1. The Operator and other persons who have gained access to personal data are obligated not to disclose to third parties or disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.

13. FINAL PROVISIONS
13.1. This document reflects any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
13.2. The current version of the Policy is freely available on the Internet at https://medianaagency.ru/.