PRIVACY POLICY REGARDING THE PROCESSING OF PERSONAL
DATA ON THE WEBSITE HTTPS://BLENDS.INSPIROPROJECTS.RU OF LLC «INSPIRITS»
1. GENERAL PROVISIONS
1.1. This document (hereinafter referred to as the «Policy») defines the policy of LLC «INSPIRITS» (hereinafter referred to as the «Operator») regarding the processing of personal data of users on the Internet website at: https://blends.inspiroprojects.ru (hereinafter referred to as the «Website»).
1.2. This Policy is developed in accordance with paragraph 2, part 1, article 18.1 of the Federal Law No. 152-FZ dated July 27, 2006 «On Personal Data», and the Recommendations on drafting a document defining the operator’s policy on the processing of personal data, established by this Federal Law.
1.3. To comply with part 2 of article 18.1 of Federal Law No. 152-FZ «On Personal Data», this Policy is published for public access on the Operator’s Website at: https://blends.inspiroprojects.ru.
1.4. This Privacy Policy applies only to this Website. The Operator does not control and is not responsible for third-party websites to which the User may follow links available on the Website.
1.5. The terms used in article 3 of Federal Law No. 152-FZ «On Personal Data» are used in this Policy with the same meaning.
1.6. The following terms are also used in this Policy:
1.7.1. The Operator is obliged to:
1.8.1. The User is obliged to:
2. PURPOSES OF PERSONAL DATA PROCESSING
2.1. The processing of personal data shall be limited to the achievement of specific, pre-defined, and lawful purposes. Processing of data incompatible with the stated purposes is not permitted. The personal data being processed must correspond to the purposes of their processing and must not be excessive.
2.2. The Operator processes the User’s personal data for the following purposes:
2.2.1. Identifying the User who is registered on the Website.
2.2.2. Informing Users about the operation of the Website (Services), monitoring and improving service quality.
2.2.3. Providing the User with access to personalized resources of the Website.
2.2.4. Establishing feedback with the User, including sending notifications and inquiries regarding the use of the Website, services, fulfillment of tasks, as well as processing requests and applications.
2.2.5. Determining the User’s location to ensure security and prevent fraud involving the use of personal data on the Website.
2.2.6. Creating a User account.
2.2.7. Providing efficient customer and technical support for issues related to the Website.
2.2.8. Sending advertising materials to the User with their prior consent.
3. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
3.1. The legal grounds for processing personal data by the Operator include:
4. SCOPE AND CATEGORIES OF PROCESSED PERSONAL DATA,CATEGORIES OF PERSONAL DATA SUBJECTS
4.1. The Operator may process the personal data of the following categories of Users: visitors of the Operator’s Website.
4.2. The personal data processed by the Operator may include:
4.4. The Operator does not process biometric personal data or special categories of personal data relating to race, nationality, political opinions, religious or philosophical beliefs, or sexual life.
5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING5.1. The Operator processes personal data in accordance with the legislation of the Russian Federation using the following methods:
collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.
5.3. The Operator processes personal data upon receiving the User’s consent (hereinafter – the "Consent"), obtained in accordance with Federal Law No. 152-FZ, except where processing is permitted without such consent under Russian law.
5.4. The User provides personal data and gives Consent freely, by their own will and in their own interest.
5.5. The duration of personal data processing is determined by the time required to achieve the purposes for which the data was collected, unless otherwise specified by contract or applicable law.
Processing may cease upon achieving these purposes, no longer needing the data, expiration or withdrawal of consent, or if unlawful processing is discovered.
5.6. Consent may be withdrawn by submitting a written notice to the Operator’s address.
5.7. The Operator may disseminate personal data that the User has explicitly allowed to be shared with the public, subject to the prohibitions, conditions, and requirements stated in Article 10.1 of Federal Law No. 152-FZ.
Disclosure or distribution of personal data to third parties without the User’s consent is not permitted unless otherwise established by federal law.
Consent for publicly disclosed data is issued separately from other types of consent and must comply with the requirements defined by Roskomnadzor Order No. 18 dated 24.02.2021.
5.8. The Operator implements and ensures necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and any other unlawful actions.
5.9. Personal data is stored in a form that allows identification of the User for no longer than required by the purposes of processing, unless a longer retention period is stipulated by law or agreement.
5.10. The Operator complies with Article 18 of Federal Law No. 152-FZ during personal data processing.
5.11. The Operator commits to maintaining the confidentiality of personal data.
5.12. Cross-border transfer of personal data is not performed by the Operator.
5.13. In the event of unlawful or accidental disclosure, provision, or access to personal data, the Operator notifies the User within ten (10) business days.
5.14. The Operator and the User take all necessary measures to prevent losses or other negative consequences resulting from unauthorized disclosure or access to the User’s personal data.
6. BLOCKING, UPDATING, AND DELETION OF PERSONAL DATA.RESPONSES TO USER REQUESTS FOR ACCESS TO PERSONAL DATA
6.1. If unlawful processing of personal data is identified based on a User request (or that of their representative) or a request from an authorized data protection authority, the Operator blocks the unlawfully processed data related to the relevant User, or ensures such data is blocked from the moment of the request, for the duration of the inspection.
If inaccurate personal data is discovered, the Operator blocks the data upon request from the User (or their representative), or the authorized authority, for the duration of the verification, provided the blocking does not violate the rights and lawful interests of the User or third parties.
6.2. If the inaccuracy of personal data is confirmed, the Operator, based on information provided by the User (or their representative) or the authorized authority, or on the basis of other necessary documents, corrects or ensures the correction of such data within seven (7) business days from the date such information is received.
6.3. If unlawful processing of personal data is confirmed, the Operator, within no more than three (3) business days from the date of confirmation, ceases or ensures the cessation of such processing.
If lawful processing cannot be ensured, the Operator deletes or ensures the deletion of such data within ten (10) business days from the date of confirmation.
6.4. Once the purposes of personal data processing have been achieved, the Operator deletes or ensures the deletion of the personal data within thirty (30) days, unless otherwise stipulated by a contract to which the User is a party, beneficiary, or guarantor, or by an agreement between the Operator and the User, or unless the Operator is entitled to process the data without consent under Federal Law No. 152-FZ or other federal laws.
6.5. If the User withdraws their consent to the processing of personal data and if the data is no longer required for the purposes of processing, the Operator deletes or ensures the deletion of the data within thirty (30) days from the receipt of the withdrawal notice, unless otherwise stipulated by contract or applicable law.
6.6. Within seven (7) business days from the receipt of evidence from the User (or their representative) confirming that the personal data was unlawfully obtained or is unnecessary for the stated purpose, the Operator deletes such personal data.
6.7. Processed personal data must be deleted if there is no longer a need to achieve the processing purposes, unless otherwise required by federal law.
6.8. The Operator responds to User requests and inquiries regarding the processing of their personal data.
7. LIABILITY OF THE PARTIES7.1. The Operator is liable for violations of Federal Law No. 152-FZ “On Personal Data” in accordance with the legislation of the Russian Federation.
7.2. The User has the right to claim compensation for damages and/or moral harm in court.
Moral harm caused to the User as a result of violations of their rights, rules of personal data processing, or legal requirements for personal data protection — including those established by Federal Law No. 152-FZ and this Policy — shall be compensated in accordance with the legislation of the Russian Federation.
Compensation for moral harm shall be provided regardless of any property damage or financial loss incurred by the User.
8. DISPUTE RESOLUTION
8.1. In the event of disputes and/or disagreements arising from the relationship between the User and the Operator, such disputes shall be resolved in accordance with the legislation of the Russian Federation.
8.2. This Policy and all legal relations between the User and the Operator shall be governed by the current legislation of the Russian Federation.
9. FINAL PROVISIONS
9.1. The Operator reserves the right to make changes to this Policy without the User’s consent.
9.2. The new version of the Policy enters into force from the moment it is published on the Website, unless otherwise stated in the new version of the Policy.
The new version shall apply to all relations arising after its entry into force.
9.3. Any suggestions or questions regarding this Policy should be sent to: blends@spiro.vc.
DATA ON THE WEBSITE HTTPS://BLENDS.INSPIROPROJECTS.RU OF LLC «INSPIRITS»
1. GENERAL PROVISIONS
1.1. This document (hereinafter referred to as the «Policy») defines the policy of LLC «INSPIRITS» (hereinafter referred to as the «Operator») regarding the processing of personal data of users on the Internet website at: https://blends.inspiroprojects.ru (hereinafter referred to as the «Website»).
1.2. This Policy is developed in accordance with paragraph 2, part 1, article 18.1 of the Federal Law No. 152-FZ dated July 27, 2006 «On Personal Data», and the Recommendations on drafting a document defining the operator’s policy on the processing of personal data, established by this Federal Law.
1.3. To comply with part 2 of article 18.1 of Federal Law No. 152-FZ «On Personal Data», this Policy is published for public access on the Operator’s Website at: https://blends.inspiroprojects.ru.
1.4. This Privacy Policy applies only to this Website. The Operator does not control and is not responsible for third-party websites to which the User may follow links available on the Website.
1.5. The terms used in article 3 of Federal Law No. 152-FZ «On Personal Data» are used in this Policy with the same meaning.
1.6. The following terms are also used in this Policy:
- User — any person visiting the Website and using its information, materials, and services. The User is considered a subject of personal data within the meaning of Federal Law No. 152-FZ «On Personal Data».
- Website Services — interactive (dialogue-based) software components on the Website pages used for integration with information systems and providing Users with specific functionalities for accessing information on the Website, namely: https://blends.inspiroprojects.ru (hereinafter referred to as the «Services» or «Website Services»).
1.7.1. The Operator is obliged to:
- process personal data solely for the purposes specified in this Policy, in accordance with the legislation of the Russian Federation, and take the necessary and sufficient measures to fulfill the responsibilities provided by Federal Law No. 152-FZ and related regulations;
- not disclose personal data without the User’s consent, unless otherwise provided by law;
- ensure that processing complies with the principles and rules established by the Federal Law;
- implement personal data protection in accordance with applicable legal requirements;
- respond to User inquiries (or those of their legal representatives) regarding personal data processing and provide reasoned responses;
- grant Users (or their representatives) free access to their personal data;
- update, block, or delete personal data in cases specified by law.
- determine the necessary and sufficient measures to fulfill its responsibilities unless otherwise specified by law;
- entrust the processing of personal data to another party with the User’s consent, based on a contract (including public or municipal contracts);
- continue processing personal data after the User revokes consent, if legal grounds exist;
- request accurate information and/or documents from the User for processing purposes outlined in section 2.2 of the Policy;
- require the User to update previously provided personal data in a timely manner.
1.8.1. The User is obliged to:
- provide accurate personal data necessary for the purposes outlined in section 2.2;
- provide updated information upon request to clarify the data provided.
- access full information regarding their personal data processing, unless restricted by law;
- request correction, blocking, or deletion of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary;
- revoke their consent to personal data processing;
- take lawful action to protect their rights;
- file complaints with authorized bodies or in court regarding unlawful actions or omissions by the Operator during data processing.
2. PURPOSES OF PERSONAL DATA PROCESSING
2.1. The processing of personal data shall be limited to the achievement of specific, pre-defined, and lawful purposes. Processing of data incompatible with the stated purposes is not permitted. The personal data being processed must correspond to the purposes of their processing and must not be excessive.
2.2. The Operator processes the User’s personal data for the following purposes:
2.2.1. Identifying the User who is registered on the Website.
2.2.2. Informing Users about the operation of the Website (Services), monitoring and improving service quality.
2.2.3. Providing the User with access to personalized resources of the Website.
2.2.4. Establishing feedback with the User, including sending notifications and inquiries regarding the use of the Website, services, fulfillment of tasks, as well as processing requests and applications.
2.2.5. Determining the User’s location to ensure security and prevent fraud involving the use of personal data on the Website.
2.2.6. Creating a User account.
2.2.7. Providing efficient customer and technical support for issues related to the Website.
2.2.8. Sending advertising materials to the User with their prior consent.
3. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING
3.1. The legal grounds for processing personal data by the Operator include:
- The Constitution of the Russian Federation;
- The Civil Code of the Russian Federation;
- Federal Law No. 149-FZ dated 27.07.2006 “On Information, Information Technologies, and Information Protection”;
- Federal Law No. 294-FZ dated 26.12.2008 “On the Protection of the Rights of Legal Entities and Individual Entrepreneurs during State and Municipal Control”;
- Decree of the President of the Russian Federation No. 188 dated 06.03.1997 “On Approval of the List of Confidential Information”;
- Decree of the Government of the Russian Federation No. 1119 dated 01.11.2012 “On the Requirements for Personal Data Protection in Information Systems”;
- Order of the FSTEC of Russia No. 21 dated 18.02.2013 “On the Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data in Information Systems”;
- The User’s consent to personal data processing on the Website.
4. SCOPE AND CATEGORIES OF PROCESSED PERSONAL DATA,CATEGORIES OF PERSONAL DATA SUBJECTS
4.1. The Operator may process the personal data of the following categories of Users: visitors of the Operator’s Website.
4.2. The personal data processed by the Operator may include:
- User’s last name, first name, and patronymic (if applicable);
- Place of residence (region/city);
- Mobile phone number;
- Email address;
- Data automatically transmitted to the Website Services during their use via the User’s software, including IP address, cookie files, information about the User’s browser or other software used for accessing the Services, technical specifications of hardware and software used by the User, date and time of access to Services, requested page addresses, and browsing history on https://blends.inspiroprojects.ru and its Services.
4.4. The Operator does not process biometric personal data or special categories of personal data relating to race, nationality, political opinions, religious or philosophical beliefs, or sexual life.
5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING5.1. The Operator processes personal data in accordance with the legislation of the Russian Federation using the following methods:
- Non-automated processing of personal data;
- Automated processing of personal data, with or without the transmission of received data via information and telecommunication networks;
- Mixed processing of personal data.
collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.
5.3. The Operator processes personal data upon receiving the User’s consent (hereinafter – the "Consent"), obtained in accordance with Federal Law No. 152-FZ, except where processing is permitted without such consent under Russian law.
5.4. The User provides personal data and gives Consent freely, by their own will and in their own interest.
5.5. The duration of personal data processing is determined by the time required to achieve the purposes for which the data was collected, unless otherwise specified by contract or applicable law.
Processing may cease upon achieving these purposes, no longer needing the data, expiration or withdrawal of consent, or if unlawful processing is discovered.
5.6. Consent may be withdrawn by submitting a written notice to the Operator’s address.
5.7. The Operator may disseminate personal data that the User has explicitly allowed to be shared with the public, subject to the prohibitions, conditions, and requirements stated in Article 10.1 of Federal Law No. 152-FZ.
Disclosure or distribution of personal data to third parties without the User’s consent is not permitted unless otherwise established by federal law.
Consent for publicly disclosed data is issued separately from other types of consent and must comply with the requirements defined by Roskomnadzor Order No. 18 dated 24.02.2021.
5.8. The Operator implements and ensures necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and any other unlawful actions.
5.9. Personal data is stored in a form that allows identification of the User for no longer than required by the purposes of processing, unless a longer retention period is stipulated by law or agreement.
5.10. The Operator complies with Article 18 of Federal Law No. 152-FZ during personal data processing.
5.11. The Operator commits to maintaining the confidentiality of personal data.
5.12. Cross-border transfer of personal data is not performed by the Operator.
5.13. In the event of unlawful or accidental disclosure, provision, or access to personal data, the Operator notifies the User within ten (10) business days.
5.14. The Operator and the User take all necessary measures to prevent losses or other negative consequences resulting from unauthorized disclosure or access to the User’s personal data.
6. BLOCKING, UPDATING, AND DELETION OF PERSONAL DATA.RESPONSES TO USER REQUESTS FOR ACCESS TO PERSONAL DATA
6.1. If unlawful processing of personal data is identified based on a User request (or that of their representative) or a request from an authorized data protection authority, the Operator blocks the unlawfully processed data related to the relevant User, or ensures such data is blocked from the moment of the request, for the duration of the inspection.
If inaccurate personal data is discovered, the Operator blocks the data upon request from the User (or their representative), or the authorized authority, for the duration of the verification, provided the blocking does not violate the rights and lawful interests of the User or third parties.
6.2. If the inaccuracy of personal data is confirmed, the Operator, based on information provided by the User (or their representative) or the authorized authority, or on the basis of other necessary documents, corrects or ensures the correction of such data within seven (7) business days from the date such information is received.
6.3. If unlawful processing of personal data is confirmed, the Operator, within no more than three (3) business days from the date of confirmation, ceases or ensures the cessation of such processing.
If lawful processing cannot be ensured, the Operator deletes or ensures the deletion of such data within ten (10) business days from the date of confirmation.
6.4. Once the purposes of personal data processing have been achieved, the Operator deletes or ensures the deletion of the personal data within thirty (30) days, unless otherwise stipulated by a contract to which the User is a party, beneficiary, or guarantor, or by an agreement between the Operator and the User, or unless the Operator is entitled to process the data without consent under Federal Law No. 152-FZ or other federal laws.
6.5. If the User withdraws their consent to the processing of personal data and if the data is no longer required for the purposes of processing, the Operator deletes or ensures the deletion of the data within thirty (30) days from the receipt of the withdrawal notice, unless otherwise stipulated by contract or applicable law.
6.6. Within seven (7) business days from the receipt of evidence from the User (or their representative) confirming that the personal data was unlawfully obtained or is unnecessary for the stated purpose, the Operator deletes such personal data.
6.7. Processed personal data must be deleted if there is no longer a need to achieve the processing purposes, unless otherwise required by federal law.
6.8. The Operator responds to User requests and inquiries regarding the processing of their personal data.
7. LIABILITY OF THE PARTIES7.1. The Operator is liable for violations of Federal Law No. 152-FZ “On Personal Data” in accordance with the legislation of the Russian Federation.
7.2. The User has the right to claim compensation for damages and/or moral harm in court.
Moral harm caused to the User as a result of violations of their rights, rules of personal data processing, or legal requirements for personal data protection — including those established by Federal Law No. 152-FZ and this Policy — shall be compensated in accordance with the legislation of the Russian Federation.
Compensation for moral harm shall be provided regardless of any property damage or financial loss incurred by the User.
8. DISPUTE RESOLUTION
8.1. In the event of disputes and/or disagreements arising from the relationship between the User and the Operator, such disputes shall be resolved in accordance with the legislation of the Russian Federation.
8.2. This Policy and all legal relations between the User and the Operator shall be governed by the current legislation of the Russian Federation.
9. FINAL PROVISIONS
9.1. The Operator reserves the right to make changes to this Policy without the User’s consent.
9.2. The new version of the Policy enters into force from the moment it is published on the Website, unless otherwise stated in the new version of the Policy.
The new version shall apply to all relations arising after its entry into force.
9.3. Any suggestions or questions regarding this Policy should be sent to: blends@spiro.vc.
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