Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Elena Suvorova (hereinafter referred to as the "Operator").
1.1. The Operator’s paramount goal and condition for carrying out its activities is to respect 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 Operator’s policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://elena-suvorova.com/.

2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data – processing of personal data using computer technology.
2.2. Blocking of Personal Data – temporary cessation of processing personal data (except 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://elena-suvorova.com/.
2.4. Personal Data Information System – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of Personal Data – actions resulting in the impossibility of determining, without additional information, the ownership of personal data to a specific User or other personal data subject.
2.6. Processing of Personal Data – any action (operation) or 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, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual organizing and/or performing personal data processing independently or jointly with others, and determining the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal Data – any information relating directly or indirectly to a specific or identifiable User of the website https://elena-suvorova.com/.
2.9. Personal Data Permitted for Dissemination – personal data to which access has been granted to an unlimited number of persons by the personal data subject by consenting to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any visitor to the website https://elena-suvorova.com/.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or 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 known to an unlimited circle of persons, including publication in mass media, posting in information and telecommunication networks, or providing access in any other way.
2.13. Cross-Border Transfer of Personal Data – transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual, or 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 in the personal data information system and/or the destruction of physical media of personal data.

3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive reliable information and/or documents containing personal data from the personal data subject;
— If the personal data subject withdraws consent to personal data processing or submits a request to cease processing, the Operator has the right to continue processing without the subject’s consent if grounds specified in the Personal Data Law exist;
— Independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations under the Personal Data Law and related regulatory acts, unless otherwise specified by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the personal data subject with information regarding the processing of their personal data upon request;
— Organize personal data processing in accordance with current Russian legislation;
— Respond to inquiries and requests from personal data subjects and their legal representatives as required by the Personal Data Law;
— Provide the authorized body for personal data subjects’ rights protection with necessary information within 10 days of receiving such request;
— Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, or other unlawful actions;
— Cease transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in cases and manner stipulated by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.

4. Key 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 as provided by federal laws. Information is provided by the Operator in an accessible form and must not contain personal data of other subjects unless legally justified. The list of information and procedure for obtaining it are established by the Personal Data Law;
— Demand the Operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, and take legal measures to protect their rights;
— Stipulate prior consent when processing personal data for market promotion of goods, works, and services;
— Withdraw consent to personal data processing and submit a request to cease processing;
— Appeal unlawful actions or inaction of the Operator to the authorized body for personal data subjects’ rights protection or in court;
— Exercise other rights granted by Russian legislation.
4.2. Personal data subjects are obliged to:
— Provide the Operator with accurate information about themselves;
— Inform the Operator of updates or changes to their personal data.
4.3. Individuals who provide the Operator with false information about themselves or information about another personal data subject without the latter’s consent bear responsibility under Russian law.

5. Principles of Personal Data Processing
5.1. Processing is lawful and fair.
5.2. Processing is limited to achieving specific, predetermined, and legitimate purposes. Processing incompatible with collection purposes is prohibited.
5.3. Merging databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data relevant to processing purposes may be processed.
5.5. The content and scope of processed personal data correspond to stated purposes. Excessiveness relative to stated purposes is prohibited.
5.6. Accuracy, sufficiency, and (where necessary) relevance of personal data to processing purposes are ensured. The Operator takes measures to delete or clarify incomplete or inaccurate data.
5.7. Storage allows identification of the subject no longer than required by processing purposes, unless storage periods are established by federal law or contract. Processed data is destroyed or depersonalized upon achieving processing purposes or if no longer necessary, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Personal Data Processing
7.1. Processing occurs with the consent of the personal data subject.
7.2. Processing is necessary to achieve goals under an international treaty or Russian law, or to fulfill the Operator’s legal functions, powers, or duties.
7.3. Processing is necessary for administering justice, executing judicial acts, acts of other authorities, or officials under Russian enforcement legislation.
7.4. Processing is necessary to execute a contract where the subject is a party, beneficiary, or guarantor, or to conclude a contract initiated by the subject or where the subject will be a beneficiary/guarantor.
7.5. Processing is necessary to exercise the Operator’s or third parties’ legitimate interests or achieve socially significant goals, provided the subject’s rights and freedoms are not violated.
7.6. Processing involves personal data made publicly available by the subject or at their request (hereinafter "publicly available personal data").
7.7. Processing involves personal data subject to publication or mandatory disclosure under federal law.

8. Procedure for Collection, Storage, Transfer, and Other Processing Activities
The security of processed personal data is ensured by implementing legal, organizational, and technical measures necessary to fully comply with current personal data protection legislation.
8.1. The Operator ensures data integrity and takes all measures to prevent unauthorized access.
8.2. The User’s personal data will never be transferred to third parties except as required by law or with the subject’s consent to fulfill civil law obligations.
8.3. If inaccuracies are identified, the User may update their data by emailing the Operator at mentalhealth@elena-suvorova.com with the subject "Updating Personal Data".
8.4. Processing duration is determined by achievement of processing purposes, unless otherwise specified by contract or law.
The User may withdraw consent at any time by emailing mentalhealth@elena-suvorova.com with the subject "Withdrawal of Consent to Personal Data Processing".
8.5. Information collected by third-party services (payment systems, communication tools, etc.) is stored and processed by those parties (Operators) under their User Agreements and Privacy Policies. The Operator is not liable for actions of such third parties.
8.6. Restrictions imposed by the subject on transfer or processing of "personal data permitted for dissemination" do not apply when processing is in state, public, or other public interests as defined by Russian law.
8.7. The Operator ensures confidentiality during processing.
8.8. Storage allows identification no longer than required by processing purposes, unless storage periods are established by federal law or contract.
8.9. Processing ceases upon achieving purposes, expiration of consent, withdrawal of consent, request to cease processing, or detection of unlawful processing.

9. List of Actions Performed by the Operator with Personal Data
9.1. The Operator performs: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. Automated processing is performed with/without transmission via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data
10.1. Before cross-border transfer, the Operator must notify the authorized body for personal data subjects’ rights protection of its intent (separate from the processing intent notice).
10.2. Before submitting this notice, the Operator must obtain relevant information from foreign authorities/individuals/entities receiving the data.
11. Confidentiality of Personal Data
The Operator and others accessing personal data must not disclose or disseminate it without the subject’s consent, except as provided by federal law.
12. Final Provisions
12.1. The User may seek clarifications via email at mentalhealth@elena-suvorova.com.
12.2. This document will reflect any Policy changes. The Policy is effective indefinitely until replaced by a new version.
12.3. The current Policy is publicly available online at: https://elena-suvorova.com/privacy/.