Privacy Policy regarding the Processing of Personal Data

1. General Provisions
This policy on the processing of personal data is prepared 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 undertaken by Dmitry Sergeyevich Alyoshin (hereinafter referred to as the "Operator").
1.1. The Operator’s primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal, and family secrets.
1.2. This Policy of the Operator 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://implantnavigator.ru/.

2. Key Terms 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 personal data processing (except where processing is necessary to clarify personal data).
2.3. Website – a collection of graphical and informational materials, as well as computer programs and databases, made accessible on the internet at the network address https://implantnavigator.ru/.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means enabling their processing.
2.5. Depersonalization of personal data – actions that make it impossible to determine, without additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or processes personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the website https://implantnavigator.ru/.
2.9. Personal data permitted by the subject of personal data for dissemination – personal data to which access by an unlimited number of persons has been provided by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any visitor to the website https://implantnavigator.ru/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publishing personal data 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 authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and/or resulting in the destruction of physical media containing personal data.

3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive accurate information and/or documents containing personal data from the subject of personal data;
— Continue processing personal data without the subject’s consent if grounds specified in the Personal Data Law exist, in case of withdrawal of consent or a request to cease processing;
— Independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations under the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with current Russian legislation;
— Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized body for the protection of personal data subjects’ rights with necessary information within 10 days of receiving a request;
— Publish or otherwise ensure unlimited access to this Policy on the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, or dissemination, as well as from other unlawful actions;
— Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedures and cases provided by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.

4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— Obtain information regarding the processing of their personal data, except in cases provided by federal laws. The Operator provides this information in an accessible form, and it must not contain personal data related to other subjects, unless there are legal grounds for such disclosure;
— Demand that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated processing purpose, and take legal measures to protect their rights;
— Impose a condition of prior consent when processing personal data for market purposes;
— Withdraw consent to the processing of personal data and submit a demand to cease processing;
— Appeal to the authorized body for the protection of personal data subjects’ rights or in court against unlawful actions or inaction of the Operator in processing their personal data;
— Exercise other rights provided by Russian legislation.
4.2. Personal data subjects are obliged to:
— Provide the Operator with accurate information about themselves;
— Inform the Operator of any updates or changes to their personal data.
4.3. Individuals who provide the Operator with false information about themselves or information about another personal data subject without the latter’s consent bear responsibility under Russian law.

5. Principles of Personal Data Processing
5.1. Personal data processing is conducted on a lawful and fair basis.
5.2. Processing is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of data collection is not permitted.
5.3. Merging databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data relevant to the processing purposes may be processed.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. Redundancy in processed data relative to the stated purposes is not permitted.
5.6. Processing ensures the accuracy, sufficiency, and, where necessary, relevance of personal data relative to the processing purposes. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is conducted in a form that allows identification of the subject for no longer than required by the processing purposes, unless a storage period is established by federal law or an agreement. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or when such purposes are no longer relevant, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing: Informing the User via email.
Personal data: Phone numbers, name.
Legal basis: Federal Law No. 149-FZ of July 27, 2006, "On Information, Information Technologies, and Information Protection."
Types of processing: Transfer of personal data.

7. Conditions for Personal Data Processing
7.1. Processing is conducted with the consent of the personal data subject.
7.2. Processing is necessary for achieving purposes stipulated by international treaties or Russian law, or for performing functions, powers, or duties assigned to the Operator by Russian legislation.
7.3. Processing is necessary for administering justice, executing judicial or other orders under Russian enforcement proceedings law.
7.4. Processing is necessary for executing an agreement where the subject is a party, beneficiary, or guarantor, or for concluding an agreement initiated by the subject.
7.5. Processing is necessary for exercising the rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the subject are not violated.
7.6. Processing involves personal data made publicly available by the subject or at their request (hereinafter referred to as "publicly available personal data").
7.7. Processing involves personal data subject to publication or mandatory disclosure under federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with current personal data protection legislation.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where required by law or with the subject’s consent for transfer to a third party to fulfill civil law obligations.
8.3. If inaccuracies in personal data are identified, the User may update them independently by notifying the Operator via email at implantnavigator@yandex.ru with the subject line "Updating Personal Data."
8.4. The processing period for personal data is determined by the purposes for which the data was collected, unless otherwise specified by contract or law.
The User may withdraw consent to processing at any time by notifying the Operator via email at implantnavigator@yandex.ru with the subject line "Withdrawal of Consent to Process 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 Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties, including the service providers mentioned herein.
8.6. Restrictions imposed by the subject on the transfer (except for providing access) or processing of personal data permitted for dissemination do not apply in cases of processing for state, public, or other public interests as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the subject for no longer than required by the processing purposes, unless a storage period is established by federal law or contract.
8.9. Processing may be terminated upon achieving the purposes, expiration of the consent period, withdrawal of consent, a demand to cease processing, or identification of unlawful processing.

9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without the transfer of obtained information via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data
10.1. Before engaging in cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to conduct such transfers.
10.2. Prior to submitting such notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer is planned.

11. Confidentiality of Personal Data
The Operator and other persons with access to personal data are obliged not to disclose or distribute personal data to third parties without the subject’s consent, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain clarification on questions regarding the processing of their personal data by contacting the Operator via email at implantnavigator@yandex.ru.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://implantnavigator.ru/.