Gallery Triangle. Personal Data Processing Policy
Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Gallery Triangle (hereinafter — the Operator) to ensure the security of personal data.
1.1. The Operator’s primary goal and condition for its activities is to observe the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://ru.gallerytriangle.com/.
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 the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at https://ru.gallerytriangle.com/.
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 as a result of which it becomes impossible, without additional information, to determine whether personal data belong to a particular User or other personal data subject.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed, with or without 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 or municipal body, legal or natural person, independently or jointly with others organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, the composition of personal data to be processed, and the actions performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://ru.gallerytriangle.com/.
2.9. Personal data made publicly available by the data subject — personal data to which an unlimited number of persons have been granted access by the data subject through consent to the processing of such data in accordance with the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://ru.gallerytriangle.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a defined circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an indefinite circle of persons, including publication in the media, placement on information and telecommunication networks, or otherwise providing access to personal data.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a government body of that state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data, making it impossible to restore their content in the personal data information system, and/or the destruction of physical 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 accurate information and/or documents containing personal data;
– Continue processing personal data without the subject’s consent if permitted by the Personal Data Law;
– Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and other regulatory legal acts, 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 request, with information regarding the processing of their personal data;
– Organize the processing of personal data in accordance with the current legislation of the Russian Federation;
– Respond to inquiries and requests from personal data subjects and their legal representatives as required by the Personal Data Law;
– Report to the authorized body for the protection of the rights of personal data subjects any required information within 30 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, distribution, as well as other unlawful actions in relation to personal data;
– Cease the transfer (distribution, provision, access), stop 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 regarding the processing of their personal data, except in cases provided for by federal law. The Operator shall provide such information to the personal data subject in an accessible form, and it must not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosure. 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 delete their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take legal measures to protect their rights.
– Require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market.
– Withdraw their consent to the processing of personal data.
– File complaints with the authorized body for the protection of the rights of personal data subjects or bring legal action against unlawful actions or inaction of the Operator in the processing of their personal data.
– Exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
– Provide the Operator with accurate information about themselves.
– Notify the Operator of clarification (updating or 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 that person’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. The Operator May Process the Following Personal Data of the User
5.1. Surname, first name, patronymic (if applicable).
5.2. Email address.
5.3. Telephone numbers.
5.4. Photographs.
5.5. The website also collects and processes anonymized visitor data (including cookies) using web analytics services (Yandex.Metrica, Google Analytics, and others).
5.6. The above data are collectively referred to as “Personal Data” in this Policy.
5.7. The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or private life.
5.8. Processing of personal data made publicly available from among the special categories of personal data specified in Article 10(1) of the Personal Data Law is permitted only if the restrictions and conditions established by Article 10.1 of the Law are observed.
5.9. The User’s consent to the processing of personal data made publicly available shall be given separately from other consents to the processing of personal data. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.9.1. The User provides consent for the processing of personal data made publicly available directly to the Operator.
5.9.2. The Operator is obliged, within no more than three business days from receiving such consent, to publish information on the conditions of processing and on the existence of restrictions and conditions for the processing of personal data made publicly available.
5.9.3. The transfer (distribution, provision, access) of personal data made publicly available by the personal data subject shall be terminated at any time upon the subject’s request. Such request must include the subject’s surname, first name, patronymic (if applicable), contact information (phone number, email, or postal address), and the list of personal data to be discontinued. The specified personal data may thereafter be processed only by the Operator to whom the request was sent.
5.9.4. Consent to the processing of personal data made publicly available shall cease to be valid upon receipt by the Operator of the request specified in clause 5.9.3 of this Policy.
6. Principles of Personal Data Processing
6.1. Personal data shall be processed on a lawful and fair basis.
6.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of personal data collection is not permitted.
6.3. It is not permitted to combine databases containing personal data processed for purposes incompatible with one another.
6.4. Only personal data that meet the purposes of their processing shall be subject to processing.
6.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the declared purposes is not permitted.
6.6. When processing personal data, their accuracy, sufficiency, and, where necessary, relevance to the purposes of processing shall be ensured. The Operator shall take necessary measures to remove or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows the identification of the personal data subject no longer than required for the purposes of processing, unless a longer retention period 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 achievement of processing purposes or if the need to achieve such purposes no longer exists, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purposes of processing the User’s personal data are as follows:
– Informing the User by sending emails;
– Concluding, executing, and terminating civil law contracts;
– Providing the User with access to services, information, and/or materials contained on the website https://ru.gallerytriangle.com/.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events.
The User may at any time refuse to receive such informational messages by sending an email to the Operator at news@gallerytriangle.com with the subject line “Refusal to receive notifications about new products, services, and special offers.”
7.3. Anonymized User data collected via web analytics services are used to gather information about User activity on the website, to improve its quality and content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for processing personal data by the Operator are:
– The Operator’s constituent documents;
– Federal laws and other regulatory acts in the field of personal data protection;
– The User’s consent to the processing of their personal data, including consent to the processing of personal data made publicly available.
8.2. The Operator processes the User’s personal data only when such data are provided and/or submitted by the User independently through the special forms located on the website https://ru.gallerytriangle.com/ or sent to the Operator via email.
By filling out these forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is allowed in the User’s browser settings (for example, the storage of cookies and the use of JavaScript technology).
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions for Personal Data Processing
9.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
9.2. Personal data shall be processed when necessary to achieve the goals provided by an international treaty of the Russian Federation or by law, or to perform the Operator’s functions, powers, and duties imposed by Russian law.
9.3. Personal data shall be processed when necessary for the administration of justice or the execution of a judicial act, or an act of another body or official subject to execution in accordance with Russian law on enforcement proceedings.
9.4. Personal data shall be processed when necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5. Personal data shall be processed when necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that this does not infringe on the rights and freedoms of the personal data subject.
9.6. Processing of personal data to which an unlimited number of persons have been granted access by the personal data subject or at their request (hereinafter — publicly available personal data) may be carried out.
9.7. Processing of personal data subject to publication or mandatory disclosure under federal law may also be carried out.
10. Procedure for Collecting, Storing, Transferring, 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 current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data by third parties.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or when the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
10.3. If inaccuracies are found in the personal data, the User may update them independently by sending a notification to the Operator via email at news@gallerytriangle.com with the subject line “Updating of personal data.”
10.4. 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 a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notice via email to the Operator at news@gallerytriangle.com with the subject line “Withdrawal of consent to the processing of personal data.”
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreements and Privacy Policies.
The personal data subject and/or User is responsible for reviewing these documents in a timely manner.
The Operator is not responsible for the actions of third parties, including service providers mentioned in this clause.
10.6. Restrictions established by the personal data subject on the transfer (except for providing access), processing, or conditions of processing (except for access) of personal data made publicly available do not apply when personal data are processed for state, public, or other public interests as defined by Russian law.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than is required for the purposes of processing, unless a longer retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The processing of personal data shall be terminated upon achievement of the purposes of processing, expiration of consent, withdrawal of consent by the personal data subject, or detection of unlawful processing of personal data.
11. List of Actions Performed by the Operator with the Collected Personal Data11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data, with or without the transmission of the obtained information via information and telecommunication networks.
12. Cross-Border Transfer of Personal Data
12.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer is intended provides reliable protection of the rights of personal data subjects.
12.2. The 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 personal data subject has given written consent to the cross-border transfer of their personal data and/or if it is necessary for the performance of a contract to which the personal data subject is a party.
13. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User may obtain any clarification on questions of interest related to the processing of their personal data by contacting the Operator via email at news@gallerytriangle.com.
14.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://ru.gallerytriangle.com/.
15. Legal Information Gallery Triangle
LLC “Kosmos Gallery”
TIN (Taxpayer Identification Number): 7743920730
KPP (Tax Registration Reason Code): 770901001
4th Syromyatnichesky Lane, 9, Bld. 1/8, Moscow, 105120, Russia
AO Alfa-Bank, Moscow, Russia
Account No.: 40702810502320000364
BIC: 044525593
Correspondent Account: 30101810200000000593
Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Gallery Triangle (hereinafter — the Operator) to ensure the security of personal data.
1.1. The Operator’s primary goal and condition for its activities is to observe the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://ru.gallerytriangle.com/.
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 the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at https://ru.gallerytriangle.com/.
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 as a result of which it becomes impossible, without additional information, to determine whether personal data belong to a particular User or other personal data subject.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed, with or without 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 or municipal body, legal or natural person, independently or jointly with others organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, the composition of personal data to be processed, and the actions performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://ru.gallerytriangle.com/.
2.9. Personal data made publicly available by the data subject — personal data to which an unlimited number of persons have been granted access by the data subject through consent to the processing of such data in accordance with the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://ru.gallerytriangle.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a defined circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an indefinite circle of persons, including publication in the media, placement on information and telecommunication networks, or otherwise providing access to personal data.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a government body of that state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data, making it impossible to restore their content in the personal data information system, and/or the destruction of physical 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 accurate information and/or documents containing personal data;
– Continue processing personal data without the subject’s consent if permitted by the Personal Data Law;
– Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and other regulatory legal acts, 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 request, with information regarding the processing of their personal data;
– Organize the processing of personal data in accordance with the current legislation of the Russian Federation;
– Respond to inquiries and requests from personal data subjects and their legal representatives as required by the Personal Data Law;
– Report to the authorized body for the protection of the rights of personal data subjects any required information within 30 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, distribution, as well as other unlawful actions in relation to personal data;
– Cease the transfer (distribution, provision, access), stop 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 regarding the processing of their personal data, except in cases provided for by federal law. The Operator shall provide such information to the personal data subject in an accessible form, and it must not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosure. 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 delete their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take legal measures to protect their rights.
– Require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market.
– Withdraw their consent to the processing of personal data.
– File complaints with the authorized body for the protection of the rights of personal data subjects or bring legal action against unlawful actions or inaction of the Operator in the processing of their personal data.
– Exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
– Provide the Operator with accurate information about themselves.
– Notify the Operator of clarification (updating or 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 that person’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. The Operator May Process the Following Personal Data of the User
5.1. Surname, first name, patronymic (if applicable).
5.2. Email address.
5.3. Telephone numbers.
5.4. Photographs.
5.5. The website also collects and processes anonymized visitor data (including cookies) using web analytics services (Yandex.Metrica, Google Analytics, and others).
5.6. The above data are collectively referred to as “Personal Data” in this Policy.
5.7. The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or private life.
5.8. Processing of personal data made publicly available from among the special categories of personal data specified in Article 10(1) of the Personal Data Law is permitted only if the restrictions and conditions established by Article 10.1 of the Law are observed.
5.9. The User’s consent to the processing of personal data made publicly available shall be given separately from other consents to the processing of personal data. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.9.1. The User provides consent for the processing of personal data made publicly available directly to the Operator.
5.9.2. The Operator is obliged, within no more than three business days from receiving such consent, to publish information on the conditions of processing and on the existence of restrictions and conditions for the processing of personal data made publicly available.
5.9.3. The transfer (distribution, provision, access) of personal data made publicly available by the personal data subject shall be terminated at any time upon the subject’s request. Such request must include the subject’s surname, first name, patronymic (if applicable), contact information (phone number, email, or postal address), and the list of personal data to be discontinued. The specified personal data may thereafter be processed only by the Operator to whom the request was sent.
5.9.4. Consent to the processing of personal data made publicly available shall cease to be valid upon receipt by the Operator of the request specified in clause 5.9.3 of this Policy.
6. Principles of Personal Data Processing
6.1. Personal data shall be processed on a lawful and fair basis.
6.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of personal data collection is not permitted.
6.3. It is not permitted to combine databases containing personal data processed for purposes incompatible with one another.
6.4. Only personal data that meet the purposes of their processing shall be subject to processing.
6.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the declared purposes is not permitted.
6.6. When processing personal data, their accuracy, sufficiency, and, where necessary, relevance to the purposes of processing shall be ensured. The Operator shall take necessary measures to remove or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows the identification of the personal data subject no longer than required for the purposes of processing, unless a longer retention period 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 achievement of processing purposes or if the need to achieve such purposes no longer exists, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purposes of processing the User’s personal data are as follows:
– Informing the User by sending emails;
– Concluding, executing, and terminating civil law contracts;
– Providing the User with access to services, information, and/or materials contained on the website https://ru.gallerytriangle.com/.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events.
The User may at any time refuse to receive such informational messages by sending an email to the Operator at news@gallerytriangle.com with the subject line “Refusal to receive notifications about new products, services, and special offers.”
7.3. Anonymized User data collected via web analytics services are used to gather information about User activity on the website, to improve its quality and content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for processing personal data by the Operator are:
– The Operator’s constituent documents;
– Federal laws and other regulatory acts in the field of personal data protection;
– The User’s consent to the processing of their personal data, including consent to the processing of personal data made publicly available.
8.2. The Operator processes the User’s personal data only when such data are provided and/or submitted by the User independently through the special forms located on the website https://ru.gallerytriangle.com/ or sent to the Operator via email.
By filling out these forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is allowed in the User’s browser settings (for example, the storage of cookies and the use of JavaScript technology).
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.
9. Conditions for Personal Data Processing
9.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
9.2. Personal data shall be processed when necessary to achieve the goals provided by an international treaty of the Russian Federation or by law, or to perform the Operator’s functions, powers, and duties imposed by Russian law.
9.3. Personal data shall be processed when necessary for the administration of justice or the execution of a judicial act, or an act of another body or official subject to execution in accordance with Russian law on enforcement proceedings.
9.4. Personal data shall be processed when necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
9.5. Personal data shall be processed when necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that this does not infringe on the rights and freedoms of the personal data subject.
9.6. Processing of personal data to which an unlimited number of persons have been granted access by the personal data subject or at their request (hereinafter — publicly available personal data) may be carried out.
9.7. Processing of personal data subject to publication or mandatory disclosure under federal law may also be carried out.
10. Procedure for Collecting, Storing, Transferring, 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 current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data by third parties.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or when the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
10.3. If inaccuracies are found in the personal data, the User may update them independently by sending a notification to the Operator via email at news@gallerytriangle.com with the subject line “Updating of personal data.”
10.4. 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 a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notice via email to the Operator at news@gallerytriangle.com with the subject line “Withdrawal of consent to the processing of personal data.”
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreements and Privacy Policies.
The personal data subject and/or User is responsible for reviewing these documents in a timely manner.
The Operator is not responsible for the actions of third parties, including service providers mentioned in this clause.
10.6. Restrictions established by the personal data subject on the transfer (except for providing access), processing, or conditions of processing (except for access) of personal data made publicly available do not apply when personal data are processed for state, public, or other public interests as defined by Russian law.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows the identification of the personal data subject for no longer than is required for the purposes of processing, unless a longer retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The processing of personal data shall be terminated upon achievement of the purposes of processing, expiration of consent, withdrawal of consent by the personal data subject, or detection of unlawful processing of personal data.
11. List of Actions Performed by the Operator with the Collected Personal Data11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data, with or without the transmission of the obtained information via information and telecommunication networks.
12. Cross-Border Transfer of Personal Data
12.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer is intended provides reliable protection of the rights of personal data subjects.
12.2. The 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 personal data subject has given written consent to the cross-border transfer of their personal data and/or if it is necessary for the performance of a contract to which the personal data subject is a party.
13. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User may obtain any clarification on questions of interest related to the processing of their personal data by contacting the Operator via email at news@gallerytriangle.com.
14.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://ru.gallerytriangle.com/.
15. Legal Information Gallery Triangle
LLC “Kosmos Gallery”
TIN (Taxpayer Identification Number): 7743920730
KPP (Tax Registration Reason Code): 770901001
4th Syromyatnichesky Lane, 9, Bld. 1/8, Moscow, 105120, Russia
AO Alfa-Bank, Moscow, Russia
Account No.: 40702810502320000364
BIC: 044525593
Correspondent Account: 30101810200000000593