1. General Provisions
This personal data processing policy is drafted 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 Sole Proprietor Memoleto (hereinafter referred to as 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 right to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.
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://memoleto.com.
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 — 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://memoleto.com.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, 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 set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), 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 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://memoleto.com.
2.9. Personal data permitted by the subject of personal data for distribution — personal data, access to which is provided 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 the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").
2.10. User — any visitor to the website https://memoleto.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, placement in 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 state authority, foreign natural or foreign legal person.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or resulting in the destruction of material carriers of personal data.
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 case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request with a requirement to stop processing 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 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 subject of personal data, upon his request, with information concerning the processing of his personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— inform the authorized body for the protection of the rights of subjects of personal data, upon request of this body, of the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise provide unrestricted access to this Policy regarding 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, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— 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. The 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, unless 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;
— require the Operator to clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as send a request to stop processing personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when processing his personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data 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 false information about themselves or information about another subject of personal data 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. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful goals. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, unless the period of storage of personal data is established by federal law, a contract, the party to which, the beneficiary or guarantor under which is the subject of personal data. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails.
Personal data:
— email address
— name
Legal grounds:
— charter (founding) documents of the Operator
Types of personal data processing:
— collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
7. Conditions for Personal Data Processin
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract, the party to which, the beneficiary or guarantor under which is the subject of personal data, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. The processing of personal data is carried out, access to which is provided by the subject of personal data or at his request (hereinafter referred to as "publicly available personal data").
7.7. The processing of personal data is carried out, subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
8.1. 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 current legislation in the field of personal data protection.
8.2. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.3. The User’s personal data will never, under any circumstances, be transferred to third parties, 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.
8.4. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the email address info@memoleto.com marked “Personal Data Update.”
8.5. The processing period of personal data is determined by the achievement of the purposes for which the personal data was collected unless a different period is provided by the contract or applicable legislation.
The User may at any time withdraw consent to the processing of personal data by sending the Operator a notification via email to info@memoleto.com marked “Withdrawal of Consent to the Processing of Personal Data.”
8.6. All information that is 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 subject of personal data and/or the User is obliged to independently familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.7. The prohibitions established by the subject of personal data on the transfer (other than granting access), as well as on the processing or conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public, and other public interests as defined by Russian legislation.
8.8. The Operator ensures the confidentiality of personal data when processing it.
8.9. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than required for the purposes of personal data processing, unless the storage period is established by federal law, a contract, or other legal obligation.
8.10. The condition for termination of personal data processing may be the achievement of the processing goals, the expiration of the consent period of the subject of personal data, the withdrawal of consent by the subject of personal data, or a requirement to cease processing personal data, as well as identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data Received
9.1. The Operator performs the following actions with personal data: 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 receiving and/or transmitting the obtained information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
10.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if the subject of personal data consents in writing to the cross-border transfer of their personal data and/or in cases provided for by federal law.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any explanations regarding the processing of their personal data by contacting the Operator via email at info@memoleto.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://memoleto.com.
This personal data processing policy is drafted 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 Sole Proprietor Memoleto (hereinafter referred to as 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 right to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.
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://memoleto.com.
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 — 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://memoleto.com.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, 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 set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), 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 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://memoleto.com.
2.9. Personal data permitted by the subject of personal data for distribution — personal data, access to which is provided 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 the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").
2.10. User — any visitor to the website https://memoleto.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, placement in 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 state authority, foreign natural or foreign legal person.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or resulting in the destruction of material carriers of personal data.
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 case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request with a requirement to stop processing 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 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 subject of personal data, upon his request, with information concerning the processing of his personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— inform the authorized body for the protection of the rights of subjects of personal data, upon request of this body, of the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise provide unrestricted access to this Policy regarding 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, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— 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. The 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, unless 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;
— require the Operator to clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as send a request to stop processing personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when processing his personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data 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 false information about themselves or information about another subject of personal data 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. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful goals. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, unless the period of storage of personal data is established by federal law, a contract, the party to which, the beneficiary or guarantor under which is the subject of personal data. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails.
Personal data:
— email address
— name
Legal grounds:
— charter (founding) documents of the Operator
Types of personal data processing:
— collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
7. Conditions for Personal Data Processin
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract, the party to which, the beneficiary or guarantor under which is the subject of personal data, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. The processing of personal data is carried out, access to which is provided by the subject of personal data or at his request (hereinafter referred to as "publicly available personal data").
7.7. The processing of personal data is carried out, subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
8.1. 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 current legislation in the field of personal data protection.
8.2. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.3. The User’s personal data will never, under any circumstances, be transferred to third parties, 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.
8.4. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the email address info@memoleto.com marked “Personal Data Update.”
8.5. The processing period of personal data is determined by the achievement of the purposes for which the personal data was collected unless a different period is provided by the contract or applicable legislation.
The User may at any time withdraw consent to the processing of personal data by sending the Operator a notification via email to info@memoleto.com marked “Withdrawal of Consent to the Processing of Personal Data.”
8.6. All information that is 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 subject of personal data and/or the User is obliged to independently familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.7. The prohibitions established by the subject of personal data on the transfer (other than granting access), as well as on the processing or conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public, and other public interests as defined by Russian legislation.
8.8. The Operator ensures the confidentiality of personal data when processing it.
8.9. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than required for the purposes of personal data processing, unless the storage period is established by federal law, a contract, or other legal obligation.
8.10. The condition for termination of personal data processing may be the achievement of the processing goals, the expiration of the consent period of the subject of personal data, the withdrawal of consent by the subject of personal data, or a requirement to cease processing personal data, as well as identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Personal Data Received
9.1. The Operator performs the following actions with personal data: 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 receiving and/or transmitting the obtained information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
10.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if the subject of personal data consents in writing to the cross-border transfer of their personal data and/or in cases provided for by federal law.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any explanations regarding the processing of their personal data by contacting the Operator via email at info@memoleto.com.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://memoleto.com.
Privacy Policy
