Privacy Policy

1. General Provisions
This Policy on personal data processing has been developed 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 the measures aimed at ensuring the security of personal data undertaken by LLC "EdSpector" (hereinafter referred to as the Operator).

1.1. The Operator regards 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 one of its most important goals and essential conditions 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 of the website https://onctv.ru

2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data by means of computer technology.

2.2. Blocking of personal data — temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphical and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the network address https://onctv.ru.

2.4. Personal data information system — a set of personal data contained in databases, as well as information technologies and technical tools ensuring their processing.

2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without the use of additional information, the affiliation of personal data to a specific User or another 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 on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.

2.7. Operator — a state authority, municipal authority, legal or natural person, independently or jointly with others organizing and/or performing the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://onctv.ru.

2.9. Personal data made publicly available by the personal data subject — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data made publicly available by the personal data subject in accordance with the procedure established by the Personal Data Law (hereinafter — personal data made publicly available).

2.10. User — any visitor of the website https://onctv.ru.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number 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 the media, posting in information and telecommunication networks, or granting access to personal data in any other way.

2.13. Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual, or a 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 within the personal data information system 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 reliable information and/or documents containing personal data;
— in the event that the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing the personal data without the consent of the personal data subject if there are legal grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for 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, upon his or her request, with information concerning the processing of his or her personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries 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 the rights of personal data subjects, upon its request, with the necessary information within ten (10) days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, or distribution, as well as from other unlawful actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations established by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of such information and the procedure for obtaining it are established by the Personal Data Law;
— request that the Operator clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— set a condition of prior consent when personal data are processed for the purpose of promoting goods, works, and services on the market;
— withdraw their consent to the processing of personal data, as well as submit a request to terminate the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of the clarification (updating, modification) 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 that subject shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Personal data processing shall be carried out on a lawful and fair basis.

5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.

5.3. It is not permitted to combine databases containing personal data that are processed for purposes that are incompatible with one another.

5.4. Only personal data that meet the purposes of their processing shall be subject to processing.

5.5. The content and scope of the personal data being processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of their processing is not permitted.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the 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. Processed personal data shall be destroyed or depersonalized upon the achievement of the purposes of processing or if the necessity for achieving these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
— Purpose of processing:
Providing the User with access to the services, information, and/or materials contained on the website.
— Personal data:
Email address.
— Legal grounds:
Contracts concluded between the Operator and the personal data subject.
— Types of personal data processing:
Sending informational messages to the email address.

7. Conditions for Personal Data Processing
7.1. The processing of personal data shall be carried out with the consent of the personal data subject to the processing of his or her personal data

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, as well as for the performance of the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or the execution of an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the attainment of socially significant goals, provided that the rights and freedoms of the personal data subject are not thereby violated.

7.6. The processing of personal data made publicly available by the personal data subject or at the personal data subject’s request (hereinafter — publicly available personal data) is carried out.

7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.


8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
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 prevent unauthorized access to personal data by third parties.

8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or if the personal data subject has given the Operator consent to transfer the data to a third party for the purpose of fulfilling obligations under a civil law contract.

8.3. If inaccuracies in personal data are identified, the User may independently update them by sending a notification to the Operator via email at support@adspector.ru with the subject line “Personal Data Update.”

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is established by contract or by applicable law.
The User may at any time withdraw his or her consent to the processing of personal data by sending a notification to the Operator via email at support@adspector.ru with the subject line “Withdrawal of Consent to the Processing of 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 such entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject must independently review these documents. The Operator shall not be responsible for the actions of third parties, including those service providers mentioned in this paragraph.

8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for access) of personal data permitted for dissemination, shall not apply in cases where personal data are processed in state, public, or other public interests as defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.