Personal Data Processing Policy

1. General provisions

1.1. This Personal Data Processing Policy (the “Policy”) has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”). It sets out the processing procedures and security measures applied by Individual Entrepreneur Ekaterina Mikhailovna Medzhidova (Taxpayer ID (INN) 091705972928, State Registration No. (OGRNIP) 325774600418811, address: Apt. 202, 19 building 2, Rozhdestvenskaya Street, Moscow), hereinafter the “Operator”.

1.2. Respect for human and civil rights and freedoms when processing personal data, including the rights to privacy and personal and family confidentiality, is a primary objective and condition of the Operator’s activities.

1.3. This Policy applies to all information the Operator may obtain about visitors to the ISENTIE website at www.isentie.ru (the “Website”).

2. Definitions

2.1. Personal data means any information relating to an identified or identifiable individual, directly or indirectly (the data subject).

2.2. Personal data processing means any action or set of actions performed on personal data, with or without automated tools, including collection, recording, organisation, accumulation, storage, clarification (updating and modification), retrieval, use, transfer (dissemination, provision or access), depersonalisation, blocking, deletion and destruction.

2.3. Operator means Individual Entrepreneur Ekaterina Mikhailovna Medzhidova, who independently or jointly with others organises and/or performs personal data processing and determines its purposes, the data to be processed and the operations to be performed.

2.4. Data subject means a Website User completing a concert booking request form.

3. Categories of personal data processed

3.1. The Operator processes the following data of Users completing a concert booking request form: surname and first name, telephone number, email address, and preferences for the event location and date.

3.2. The Operator does not process special categories of personal data (race, ethnicity, political views, religious beliefs, health or intimate life) or biometric personal data.

3.3. The Operator does not collect personal data from Website visitors who do not complete the request form. When visitors follow links to third-party ticket services, their data is processed by those service operators under their own policies.

4. Purposes of processing

4.1. Personal data is processed solely to consider a concert booking request; contact the User to clarify its details (location, date and event arrangements); and enter into and perform a concert agreement, if an agreement is reached.

4.2. Processing for purposes other than those specified in clause 4.1 is not permitted.

5. Legal grounds for processing

5.1. The legal grounds are Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and the data subject’s consent to processing.

6. Processing procedures and conditions

6.1. Personal data is processed with the data subject’s consent, expressed by ticking a checkbox when submitting the Website request form.

6.2. Consent is set out in a separate Personal Data Processing Consent document. Its text is provided to the data subject before consent is obtained.

6.3. Both automated and non-automated methods are used (mixed processing).

6.4. Personal data is stored on servers located in the Russian Federation.

6.5. Personal data is retained until the processing purposes have been achieved, but for no longer than three (3) years after it is provided, unless Russian law provides otherwise.

6.6. The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions.

7. Disclosure to third parties

7.1. The Operator does not disclose personal data to third parties except where expressly provided for by the laws of the Russian Federation.

7.2. The Operator does not carry out cross-border transfers of personal data.

7.3. The Operator does not use personal data for advertising mailings without the data subject’s separate consent.

8. Data subject rights

8.1. Data subjects have the right to:

• obtain information about the processing of their personal data;
• request correction, blocking or destruction of data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose;
• withdraw consent to processing;
• challenge the Operator’s acts or omissions before the authorised authority for the protection of data subjects’ rights (Roskomnadzor) or in court.

8.2. To exercise these rights, the data subject must send a written request to the Operator at: Apt. 202, 19 building 2, Rozhdestvenskaya Street, Moscow, or email isentie.music@gmail.com.

9. Withdrawal of consent

9.1. Data subjects may withdraw consent to the processing of their personal data at any time.

9.2. Consent may be withdrawn by written notice to the Operator at: Apt. 202, 19 building 2, Rozhdestvenskaya Street, Moscow, or by email to isentie.music@gmail.com.

9.3. Upon receipt of withdrawal, the Operator stops processing and destroys the personal data within thirty (30) days, except where processing may continue under Russian law.

10. Final provisions

10.1. The Operator may amend this Policy. A new version takes effect when published on the Website.

10.2. Compliance with this Policy is monitored by the person responsible for organising personal data processing.

10.3. Matters not covered by this Policy are governed by the laws of the Russian Federation.