Privacy policy

Privacy policy

1. General Provisions

1.1. This Policy of OOO «Media Company «Severny Gorod», OGRN 1052457053252, INN 2457059448, location: 663302, Krasnoyarsk Krai, Norilsk, ul. Komsomolskaya, 33A (hereinafter — the Operator) regarding the processing of personal data (hereinafter — the Policy) has been developed pursuant to the requirements of clause 2, part 1, art. 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) for the purpose of ensuring the protection of the rights and freedoms of the individual and citizen in the processing of their personal data, including the protection of the rights to privacy and to personal and family confidentiality.

1.2. The Policy applies to the personal data that the Operator processes on the website thisistaimyr.org.

1.3. The Policy applies to relations in the field of personal data processing that arose for the Operator both before and after the approval of this Policy.

1.4. Pursuant to the requirements of part 2, art. 18.1 of the Personal Data Law, this Policy is published with free access on the information and telecommunications network “Internet” on the Operator’s website.

2. Basic Concepts

2.1 Personal data — any information relating to a directly or indirectly identified or identifiable natural person (the personal data subject);

2.2 Personal data authorized by the personal data subject for dissemination — personal data, access to which by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data authorized by the personal data subject for dissemination in the manner provided for by this Federal Law;

2.3 Operator — a legal entity or a natural person that, independently or jointly with other persons, organizes and (or) carries out the processing of personal data, as well as determines the purposes of the processing of personal data, the composition of the personal data to be processed, and the actions (operations) performed with the personal data;

2.4 Processing of personal data — any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, destruction of personal data;

2.5 Automated processing of personal data — processing of personal data by means of computer technology;

2.6 Dissemination of personal data — actions aimed at disclosing personal data to an indefinite number of persons;

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

2.8 Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to refine the personal data);

2.9 Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed;

2.10 Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine the belonging of personal data to a specific personal data subject;

2.11 Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing;

2.12 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 natural person, or a foreign legal entity.

2.13 Cookies — small fragments of data that are automatically stored on the user’s device when visiting the website and make it possible to identify the user’s browser, save settings, and analyze activity.

3. Purposes of Personal Data Processing

3.1. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. The processing of personal data incompatible with the purposes of the collection of personal data is not permitted.

3.2. Only personal data that meet the purposes of their processing are subject to processing.

3.3. The Operator processes personal data for the following purposes:

— carrying out the statutory activities of a mass media outlet, the production and dissemination of news, analytical, and other content — the posting of news on the website thisistaimyr.org.

— analysis of the traffic of the website thisistaimyr.org.

4. Volume and Categories of Processed Personal Data, Categories of Personal Data Subjects

4.1. The content and volume of the processed personal data must correspond to the stated purposes of processing provided for in Section 3.

4.2. The Operator may process the personal data of the categories of personal data subjects listed below.

4.2.1. Legal grounds for the processing of personal data:

— consent of the personal data subject to the processing of their personal data (clause 1, part 1, art. 6 of Federal Law No. 152-FZ);

— the processing of personal data is necessary for carrying out the professional activity of a journalist and (or) the lawful activity of a mass media outlet (clause 8, part 1, art. 6 of Federal Law No. 152-FZ).

4.2.2. For the purpose of posting news on the website thisistaimyr.org:

4.2.2.1 Categories of personal data: surname, first name, patronymic; citizenship; gender; date and place of birth (to the extent of public significance); position held, place of work (study); information about professional activity, awards, titles; email address; telephone number; other information voluntarily provided by the subject for dissemination in the mass media or contained in official (state) sources, as well as information obtained during photo and video recording in public places or at events.

4.2.2.2 Categories of subjects whose personal data are processed:

— experts, officials, public figures, subjects of articles, speakers, commentators, as well as persons information about whom has been obtained from official or publicly available sources.

4.2.2.3 Methods of processing: mixed; with transfer over the legal entity’s internal network; with transfer over the Internet;

4.2.2.4 Periods of processing and storage: The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or applicable law.

In the event that the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing the personal data without the consent of the personal data subject if the grounds specified in clauses 2–11 of part 1 of article 6, part 2 of article 10, and part 2 of article 11 of the Federal Law “On Personal Data” No. 152-FZ of 27.07.2006 are present.

4.2.3 Analysis of the traffic of the website thisistaimyr.org:

4.2.3.1. A metric program, “Yandex.Metrica,” is installed on the website. Data processing using “Yandex.Metrica” is carried out only on the condition that the user’s consent to the processing of cookies, IP address, and other identifiers is obtained. Consent is requested by means of a pop-up notification (cookie banner) on the first visit to the website.

4.2.3.2 Categories of personal data collected by means of the “Yandex.Metrica” metric program: location information; type and version of the OS; type and version of the browser; type of device and its screen resolution; the source from which the user came to the website; from which website or via which advertisement; language of the OS and browser; which pages the user opens and which buttons the user clicks; IP address.

4.2.3.3 Categories of subjects whose personal data are processed: website visitors;

4.2.3.4 Methods of processing: mixed; with transfer over the legal entity’s internal network; with transfer over the Internet;

4.2.3.5 Periods of processing and storage: The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by a contract or applicable law.
In the event that the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing the personal data without the consent of the personal data subject if the grounds specified in clauses 2–11 of part 1 of article 6, part 2 of article 10, and part 2 of article 11 of the Federal Law “On Personal Data” No. 152-FZ of 27.07.2006 are present.

5. Procedure and Conditions for the Processing of Personal Data

5.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.

5.2. The processing of personal data is carried out with the consent of the personal data subjects to the processing of their personal data, as well as without such consent in the cases provided for by the legislation of the Russian Federation.

5.3. The Operator carries out both automated and non-automated processing of personal data.

5.4. Only employees of the Operator who are appointed by an order of the Operator and whose job duties include the processing of personal data are permitted to process personal data.

5.5. Disclosure to third parties and dissemination of personal data without the consent of the personal data subject is not permitted, unless otherwise provided for by federal law. Consent to the processing of personal data authorized by the personal data subject for dissemination is drawn up separately from other consents of the personal data subject to the processing of their personal data.

5.6. Cross-border transfer of personal data without the consent of the personal data subject is not permitted. Consent to the cross-border transfer of personal data authorized by the personal data subject is drawn up separately from other consents of the personal data subject to the processing of their personal data.

5.7. The transfer of personal data to inquiry and investigation bodies, the Federal Security Service, the Ministry of Defense, the Federal Tax Service, the Social Fund of Russia, credit organizations, and other authorized executive bodies and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.

5.8. The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, dissemination, and other unauthorized actions, including:

determines the threats to the security of personal data during their processing;

adopts local regulatory acts and other documents governing relations in the field of the processing and protection of personal data;

appoints persons responsible for organizing the processing of personal data, ensuring the processing of personal data, and ensuring the security of personal data in the structural subdivisions and information systems of the Operator;

creates the necessary conditions for working with personal data;

organizes the accounting of information systems and documents containing personal data;

organizes work with information systems in which personal data are processed;

stores personal data under conditions that ensure their safety and exclude unlawful access to them;

organizes training for the Operator’s employees who process personal data;

carries out internal control of the compliance of the processing of personal data with the requirements of personal data legislation and the Operator’s local acts.

5.9. The Operator processes and stores personal data in a form that makes it possible to identify the personal data subject for no longer than the purposes of processing the personal data require, unless the storage period for personal data is established by federal law or a contract.

5.10. When collecting personal data, including via the information and telecommunications network “Internet,” the Operator ensures the recording, systematization, accumulation, storage, refinement (updating, modification), and extraction of the personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

6. Basic Rights and Obligations of the Operator

6.1. The Operator has the right to:

6.2. The Operator is obliged to:

7. Basic Rights of the Personal Data Subject

The personal data subject has the right to:

  1. sg@mksg.ru or by mail to: 663302, Krasnoyarsk Krai, Norilsk, ul. Komsomolskaya, 33A. The Operator ceases processing and destroys the personal data within 10 working days from the date of receipt of the withdrawal, unless otherwise provided for by law or a contract.

8. Updating, Correction, Deletion, and Destruction of Personal Data; Responses to Subjects’ Requests for Access to Personal Data

8.1. Confirmation of the fact of the processing of personal data by the Operator, the legal grounds and purposes of the processing of personal data, as well as other information specified in part 7, art. 14 of the Personal Data Law, are provided by the Operator to the personal data subject or their representative upon appeal or upon receipt of a request from the personal data subject or their representative.

The request must contain:

the number of the principal identity document of the personal data subject or their representative, information about the date of issue of the said document, and the authority that issued it;

information confirming the participation of the personal data subject in relations with the Operator (contract number, date of conclusion of the contract, conditional verbal designation, and (or) other information), or information otherwise confirming the fact of the processing of personal data by the Operator;

the signature of the personal data subject or their representative.

The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.

A response to the request is sent within 10 working days from the date of receipt of the request.

If the appeal (request) of the personal data subject does not reflect all the necessary information in accordance with the requirements of the Personal Data Law, or if the subject does not have rights of access to the requested information, then a reasoned refusal is sent to them.

The right of the personal data subject to access their personal data may be limited in accordance with part 8, art. 14 of the Personal Data Law, including if access by the personal data subject to their personal data violates the rights and legitimate interests of third parties.

8.2. In the event that inaccurate personal data are detected upon the appeal of the personal data subject or their representative, or at their request or at the request of Roskomnadzor, the Operator blocks the personal data relating to that personal data subject from the moment of such appeal or receipt of the said request for the period of verification, provided that the blocking of personal data does not violate the rights and legitimate interests of the personal data subject or third parties.

In the event of confirmation of the fact of inaccuracy of the personal data, the Operator, on the basis of information provided by the personal data subject or their representative or by Roskomnadzor, or other necessary documents, refines the personal data within seven working days from the day of submission of such information and lifts the blocking of the personal data.

8.3. In the event that unlawful processing of personal data is detected upon the appeal (request) of the personal data subject or their representative or of Roskomnadzor, the Operator blocks the unlawfully processed personal data relating to that personal data subject from the moment of such appeal or receipt of the request.

8.4. Upon the achievement of the purposes of processing personal data, as well as in the event that the personal data subject withdraws consent to their processing, the personal data are subject to destruction if:

it is not otherwise provided for by a contract to which the personal data subject (beneficiary) is a party;

the operator is not entitled to carry out processing without the consent of the personal data subject on the grounds provided for by the Personal Data Law or other federal laws;

it is not otherwise provided for by another agreement between the Operator and the personal data subject.

8.5. Personal data are destroyed in accordance with the approved procedure for the destruction of personal data in compliance with applicable law, the requirements of Roskomnadzor Order No. 179 of 28.10.2022 “On Approval of the Requirements for Confirming the Destruction of Personal Data,” as well as other internal local acts of the Operator.

Contact information of the Operator on matters of personal data processing:

Address for written appeals: 663302, Krasnoyarsk Krai, Norilsk, ul. Komsomolskaya, 33A.

Email address: sg@mksg.ru

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