1. General Provisions

This personal data processing policy is drafted in accordance with the requirements of the
GDPR — General Data Protection Regulation EU 2016/679 (hereinafter, the Personal Data
Protection Law) and defines the procedure for processing personal data and the measures
to ensure the security of personal data undertaken by Tatjana Velenta-Griņina (hereinafter,
the Operator).

1.1. The Operator sets as the most important goal and condition of its activities the
observance of the rights and freedoms of individuals and citizens when processing their
personal data, including the protection of the rights 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 receive about visitors to the website
https://psy-baltics.com/.

2. Basic 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 the processing of personal data
(except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs
and databases, that ensure their availability on the Internet at the network address
https://psy-baltics.com/.
2.4. Personal data information system — a set of personal data contained in databases, and
information technologies and technical means that ensure their processing.
2.5. Depersonalization (anonymization) of personal data — actions as a result of which,
without the use of additional information, it is impossible to determine whether personal data
belong to a specific User or another data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations)
performed with or without the use of automation tools with personal data, including
collection, recording, systematization, accumulation, storage, clarification (updating,
modification), retrieval, use, transfer (distribution, provision, access), depersonalization,
blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person who independently or
jointly with other persons organizes and/or carries out the processing of personal data, as
well as determines the purposes of processing personal data, 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://psy-baltics.com/.
2.9. Personal data permitted by the personal data subject for dissemination — personal data
to which access to an unlimited circle of persons is provided by the personal data subject by
giving consent to the processing of personal data permitted by the personal data subject for
dissemination in the manner provided by the Personal Data Protection Law (hereinafter —
personal data permitted for dissemination).
2.10. User — any visitor to the website https://psy-baltics.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain
person or a certain circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an
unlimited circle of persons (transfer of personal data) or at familiarizing an unlimited circle of
persons with personal data, including making personal data public in the media, posting in
information and telecommunication networks, or providing access to personal data in any
other way.
2.13. Cross-border transfer of personal data — 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.
2.14. Destruction of personal data — any actions as a result of which personal data are
destroyed irretrievably with the impossibility of further restoring the content of personal data
in the personal data information system and/or material media 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 accurate information and/or documents containing
personal data;
— in the event that the personal data subject withdraws consent to the processing of
personal data, continue processing personal data without the consent of the personal data
subject if there are grounds specified in the Personal Data Protection 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 Protection Law
and regulatory legal acts adopted in accordance with it, unless otherwise provided by the
Personal Data Protection Law or other federal laws.
3.2. The Operator shall:
— upon request of the personal data subject, provide information relating to the processing
of his/her personal data;
— organize the processing of personal data in the manner established by the current
legislation of the Russian Federation;
— respond to appeals and requests of personal data subjects and their legal representatives
in accordance with the requirements of the Personal Data Protection Law;
— provide the authorized body for the protection of the rights of personal data subjects,
upon its request, with the necessary information within 30 days from the date of receipt of
such 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, modification, blocking, copying, provision, dissemination,
as well as from other unlawful actions in relation to personal data;
— cease transfer (dissemination, provision, access) of personal data, cease processing, and
destroy personal data in the manner and in the cases provided for by the Personal Data
Protection Law;
— fulfill other obligations provided for by the Personal Data Protection Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
— receive information relating to the processing of their personal data, except in cases
provided for by federal laws. Information is provided to the personal data subject by the
Operator in an accessible form and must not contain personal data relating to other personal
data subjects, except where there are legal grounds for disclosing such personal data. The
list of information and the procedure for obtaining it are established by the Personal Data
Protection Law;
— demand that the Operator clarify their personal data, block or destroy them if the personal
data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the
stated purpose of processing, as well as take legal measures to protect their rights;
— set the condition of prior consent when processing personal data for the purpose of
promoting goods, works and services on the market;
— withdraw consent to the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or
to the court against unlawful actions or inaction of the Operator in processing their personal
data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
— provide the Operator with accurate data about themselves;
— inform the Operator about clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves,
or information about another personal data subject without the latter’s consent, bear liability
in accordance with the legislation of the Russian Federation.

5. Personal Data of the User That May Be Processed by the Operator

5.1. Last name, first name, patronymic.
5.2. Email address.
5.3. Phone numbers.
5.4. The site also collects and processes anonymized data about visitors (including cookies)
using internet analytics services (Yandex Metrica and Google Analytics and others).
5.5. The above data are hereinafter collectively referred to in the Policy as Personal Data.
5.6. The Operator does not process special categories of personal data concerning race,
nationality, political views, religious or philosophical beliefs, intimate life.
5.7. Processing of personal data permitted for dissemination from among the special
categories of personal data specified in Part 1 of Article 10 of the Personal Data Protection
Law is allowed if the prohibitions and conditions provided for by Article 10.1 of the Personal
Data Protection Law are observed.
5.8. The User’s consent to the processing of personal data permitted for dissemination is
formalized separately from other consents to the processing of his/her personal data. In
doing so, the conditions provided for, in particular, by Article 10.1 of the Personal Data
Protection Law are observed. The requirements for the content of such consent are
established by the authorized body for the protection of the rights of personal data subjects.
5.8.1. The User provides the Operator directly with consent to the processing of personal
data permitted for dissemination.
5.8.2. The Operator is obliged, within no later than three working days from the moment of
receiving the said consent of the User, to publish information on the conditions of
processing, on the presence of prohibitions and conditions for processing personal data
permitted for dissemination by an unlimited circle of persons.
5.8.3. The transfer (dissemination, provision, access) of personal data permitted by the
personal data subject for dissemination must be terminated at any time at the request of the
personal data subject. Such a request must include the last name, first name, patronymic (if
any), contact information (phone number, email address or postal address) of the personal
data subject, as well as a list of personal data for which processing must be terminated. The
personal data specified in such a request may be processed only by the Operator to whom it
is addressed.
5.8.4. Consent to the processing of personal data permitted for dissemination ceases to be
valid from the moment the Operator receives the request specified in Clause 5.8.3 of this
Policy regarding the processing of personal data.

6. Principles of Personal Data Processing

6.1. Processing of personal data is carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to the achievement of specific, predetermined and
lawful purposes. Processing of personal data incompatible with the purposes of personal
data collection is not permitted.
6.3. It is not permitted to combine databases containing personal data, the processing of
which is carried out for purposes that are incompatible with each other.
6.4. Only personal data that meet the purposes of their processing are subject to processing.
6.5. The content and volume of the personal data processed correspond to the declared
processing purposes. Excessive processing of personal data in relation to the declared
processing purposes is not permitted.
6.6. In processing personal data, the accuracy, sufficiency and, where necessary, relevance
of personal data in relation to the purposes of personal data processing are ensured. The
Operator takes necessary measures and/or ensures that they are taken to remove or clarify
incomplete or inaccurate data.
6.7. Personal data are stored in a form that allows identifying the personal data subject for
no longer than required by the purposes of processing personal data, unless a storage
period for 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 are destroyed or
depersonalized upon achievement of the processing purposes or if the need to achieve
these purposes is lost, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing

7.1. The purposes of processing the User’s personal data:
— informing the User by sending emails;
— clarifying details of a request.
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 always refuse to receive
informational messages by sending the Operator an email to tatianavelenta@gmail.com
with the note “Refusal of notifications about new products and services and special offers”.
7.3. Anonymized data of Users collected using internet analytics services are used to gather
information about Users’ actions on the site, to improve the quality of the site and its content.

8. Legal Grounds for Processing Personal Data

8.1. The legal grounds for the Operator’s processing of personal data are:
— the Operator’s constituent documents;
— contracts concluded between the Operator and the personal data subject;
— federal laws and other regulatory legal acts in the field of personal data protection;
— Users’ consents to the processing of their personal data, including to the processing of
personal data permitted for dissemination.
8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by
the User independently via special forms posted on the website https://psy-baltics.com/ or
sent to the Operator by email. By filling in the relevant forms and/or sending his/her personal
data to the Operator, the User expresses consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is allowed in the User’s
browser settings (saving cookies and using JavaScript technology enabled).
8.4. The personal data subject independently makes the decision to provide his/her personal
data and gives consent freely, by his/her own will and in his/her own interest.

9. Conditions for Processing Personal Data

9.1. Processing of personal data is carried out with the consent of the personal data subject
to the processing of his/her personal data.
9.2. Processing of personal data is necessary to achieve the purposes provided for by an
international treaty of the Russian Federation or by law, to perform the functions, powers and
responsibilities imposed on the Operator by the legislation of the Russian Federation.
9.3. Processing of personal data is necessary for the administration of justice, execution of a
judicial act, an act of another body or official subject to execution in accordance with the
legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data is necessary for the performance of a contract to which the
personal data subject is a party or beneficiary or guarantor, as well as for the conclusion of 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. Processing of personal data is necessary for the exercise of the rights and legitimate
interests of the Operator or third parties or to achieve socially significant purposes, provided
that the rights and freedoms of the personal data subject are not violated.
9.6. Processing is carried out of personal data to which access is provided by the personal
data subject to an unlimited circle of persons or at his/her request (hereinafter — publicly
available personal data).
9.7. Processing is carried out of personal data subject to publication or mandatory disclosure
in accordance with federal law.

10. Procedure for Collection, Storage, Transfer and Other Types of Processing of
Personal Data

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
current legislation in the field of personal data protection.

10.1. The Operator ensures the preservation of personal data and takes all possible
measures to exclude unauthorized access to personal data.
10.2. The User’s personal data will never, under any circumstances, be transferred to third
parties, except in cases related to compliance with current legislation or where the personal
data subject has given the Operator consent to transfer the data to a third party for the
fulfillment of obligations under a civil law contract.
10.3. If inaccuracies are identified in personal data, the User may update them
independently by sending the Operator a notification to the Operator’s email address
tatianavelenta@gmail.com with the note “Updating personal data”.
10.4. 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 current legislation. The User may withdraw his/her consent to the processing
of personal data at any time by sending the Operator a notification by email to the Operator’s
email address tatianavelenta@gmail.com with the note “Withdrawal of consent to the
processing of personal data”.
10.5. All information collected by third-party services, including payment systems, means of
communication, and other service providers, is stored and processed by such persons
(Operators) in accordance with their User Agreement and Privacy Policy. The personal data
subject and/or the User must independently and timely familiarize themselves with these
documents. The Operator is not responsible for the actions of third parties, including the
service providers specified in this clause.
10.6. Prohibitions established by the personal data subject regarding transfer (other than
granting access), as well as regarding processing or conditions of processing (other than
obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation
of the Russian Federation.
10.7. In processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that makes it possible to identify the
personal data subject for no longer than required by the purposes of processing personal
data, unless the storage period for personal data is established by federal law or by a
contract to which the personal data subject is a party, beneficiary or guarantor.
10.9. A condition for terminating the processing of personal data may be the achievement of
the purposes of processing personal data, the expiration of the term of the personal data
subject’s consent, or the withdrawal of consent by the personal data subject, as well as the
identification of unlawful processing of personal data.

11. List of Actions Performed by the Operator with the Received Personal Data

11.1. 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 carries out automated processing of personal data with the receipt and/or
transfer of the received information via information and telecommunication networks or
without such networks.

12. Cross-Border Transfer of Personal Data

12.1. Before commencing the cross-border transfer of personal data, the Operator must
ensure that the foreign state to whose territory it is intended to transfer personal data
provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not
meet the above requirements may be carried out only in the presence of the written consent
of the personal data subject to the cross-border transfer of his/her personal data and/or for
the performance of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

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

14. Final Provisions

14.1. The User may obtain any clarifications on matters of interest regarding the processing
of his/her personal data by contacting the Operator by email at tatianavelenta@gmail.com.
14.2. Any changes in the Operator’s personal data processing policy will be reflected in this
document. The Policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://psy-
baltics.com/policy.