Policy on personal data processing

1. General Provisions

1.1. The operator sets the observance of human and civil rights and freedoms in processing personal data as its most important goal and condition of its activity, including the protection of the rights to privacy and individual and family secrecy.

1.2. The operator’s policy on processing personal data (hereinafter, the policy) applies to all information the operator can obtain about visitors to the website https://masterpiece.ae.

2. Basic concepts used in the Policy

2.1. automated processing of personal data — processing of personal data using computer equipment.

2.2. Blocking personal data—temporary cessation of personal data processing (except when 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://masterpiece.ae.

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

2.5. Personal data depersonalization—actions resulting in the inability to determine, without using additional information, whether personal data belongs to a particular User or other subject of personal data.

2.6. Personal data processing—any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, 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 other persons organizing and/or carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. personal data — any information relating directly or indirectly to a particular or defined website user https://masterpiece.ae.

2.9. personal data authorized by the subject of personal data for dissemination — personal data, access to which is provided by the subject of personal data to an unlimited number of persons by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the law on personal data (hereinafter — personal data authorized for dissemination).

2.10. User — any visitor of the website https://masterpiece.ae.

2.11. Provision of personal data — actions aimed at disclosure of personal data to a specific person or a particular circle of persons.

2.12. Dissemination of personal data — any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Trans-border transfer of personal data—the transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions resulting from which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

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 case the personal data subject revokes his/her consent to personal data processing, as well as in case the personal data subject submits a request to stop personal data processing, the Operator has the right to continue personal data processing without the consent of the personal data subject, 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 stipulated by the Personal Data Law and regulatory legal acts adopted by 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 their request, with information regarding the processing of their data;

— organize the processing of personal data by the procedure established by the current legislation of the Russian Federation;

— respond to appeals and requests of personal data subjects and their legal representatives by the requirements of the Law on Personal Data;

— report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 10 days from the date of receipt of such a request;

— to publish or otherwise provide unrestricted access to this Policy on personal data processing;

— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions about personal data;

— cease transfer (dissemination, provision, access) of personal data; stop processing and destroy personal data in the manner and cases stipulated by the Personal Data Law;

— fulfill other obligations stipulated by the Personal Data Law.

4. Basic rights and obligations of personal data subjects

4.1. subjects of personal data have the right:

— To receive information regarding the processing of their data, except in cases stipulated by federal laws. Information shall be provided to the subject of personal data by the Operator in an accessible form. It shall not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosure of such personal data. The Law establishes the list of information and the procedure for obtaining it on Personal Data;

— demand from the operator to clarify his data, block or destroy it in case the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect his rights;

— to impose a condition of prior consent when processing personal data to market goods, works, and services;

— to withdraw consent to the processing of personal data, as well as to submit a request to stop the processing of personal data;

— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful acts or omissions of the Operator in the processing of his/her data;

— to 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;

— notify the Operator about their personal data clarification (update, change).

4.3 The legislation of the Russian Federation imposes liability on persons who have provided the Operator with false information about themselves or information about another subject of personal data without the latter’s consent.

5. Principles of personal data processing

5.1. Processing of personal data shall be carried out on a lawful and fair basis.

5.2 The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. It is not allowed to process personal data that is incompatible with the purposes of personal data collection.

5.3 Merging databases containing personal data processed for incompatible purposes is not allowed.

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

5.5 The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data regarding the stated purposes of their processing is not allowed.

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

5.7 Personal data is stored in a form that allows identifying the subject, not longer than required by the purposes of personal data processing unless the period of storage is established by federal law, contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes unless otherwise provided for by federal law.

6. Purposes of personal data processing

Purpose of processing

Possibility to contact the user

Personal data

surname, first name, patronymic

e-mail address

telephone numbers

Legal grounds

Federal Law «On Information, Information Technologies and Information Protection» dated 27.07.2006 N 149-FZ.

Types of personal data processing

Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

Sending informational letters to the e-mail address

7. Conditions of personal data processing

7.1. Processing of personal data shall be carried out with the consent of the personal data subject to processing his/her data.

7.2 The processing of personal data is necessary to achieve the purposes provided for by the Russian Federation’s international treaty or by law and to fulfill the functions, powers, and duties assigned to the operator by the Russian Federation’s legislation.

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

7.4 The processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5 The processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing personal data to which an unlimited number of persons have access by the individual data subject or at his/her request (hereinafter referred to as publicly available personal data).

7.7 Processing of personal data subject to publication or mandatory disclosure by federal law.

8. Procedure for collection, storage, transfer, and other types of personal data processing

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 the applicable legislation in personal data protection.

8.1 The Operator shall ensure the safety of personal data and take all possible measures to prevent unauthorized access to personal data.

8.2. The User’s data will never, under no circumstances, be transferred to third parties, except in cases related to the execution of the applicable law or if the subject of personal data has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.

8.3 If any inaccuracies are detected in the personal data, the User may update them independently by sending a notice to the Operator’s e-mail address info@mastepiece.ae with the remark «Personal Data Update.»

8.4 The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected unless the contract or applicable law stipulates another term.

The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator’s e-mail address info@mastepiece.ae marked «Withdrawal of consent to the processing of personal data.»

8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the specified persons (Operators) per their User Agreement and Privacy Policy. The subject of personal data and/or with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

8.6 The prohibitions established by the personal data subject on the transfer (except for granting access) and on the processing or conditions of processing (except for access) of personal data authorized for dissemination shall not apply in cases of personal data processing in the state, public, and other public interests defined by the legislation of the Russian Federation.

8.7 The Operator shall ensure confidentiality of personal data when processing personal data.

8.8. The Operator shall store personal data in a form that allows identifying the subject for no longer than required by the purposes of personal data processing unless the period of personal data storage is established by federal law or an agreement to which the subject of personal data is a party, beneficiary, or guarantor.

8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, or the requirement to terminate personal data processing, as well as the detection of unlawful processing of personal data.

9. List of actions performed by the Operator with the received personal data

9.1 The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete, and destroy personal data.

9.2 The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Transborder transfer of personal data

10.1 Before commencing the transborder transfer of personal data, the Operator shall notify the authorized body to protect the rights of personal data subjects of its intention to carry out the transfer (such notification shall be sent separately from the notification of intention to process personal data).

10.2 Before submitting the notification mentioned above, the Operator shall be obliged to obtain relevant information from foreign authorities, foreign individuals, and foreign legal entities to whom transborder transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have access to personal data are obliged not to disclose to third parties or disseminate personal data without the consent of the subject of personal data unless otherwise provided for by federal law.

12. Final provisions

12.1. the user can get any clarifications on the issues of interest regarding processing their data by contacting the operator via e-mail at info@mastepiece.ae.

12.2. This document will reflect any changes in the operator’s policy on personal data processing. The policy is valid indefinitely until a new version replaces it.

12.3. the current version of the policy is freely available on the Internet at https://masterpiece.ae.