Policy on the Processing of Personal Data

1. General Provisions
This personal data processing policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (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 Stanislav Gennadievich Bondarenko (hereinafter referred to as the "Operator").
1.1. The Operator considers it one of its main goals and conditions of its activities to respect the rights and freedoms of individuals and citizens while 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 receive about visitors to the website http://f11club.ru/en.
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 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 http://f11club.ru/en.
2.4. Information system of personal data — a set of personal data stored in databases and ensuring their processing with the help of information technologies and technical means.
2.5. Anonymization of personal data — actions resulting in the impossibility of identifying specific Users or other personal data subjects without using additional information.
2.6. Processing of personal data — any action (operation) or a 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), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or physical person, independently or together with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to a specific or identifiable User of the website http://f11club.ru/en.
2.9. Personal data permitted by the personal data subject for distribution — personal data accessible to an indefinite number of persons provided by the subject of personal data with their consent to the processing of personal data permitted for distribution as envisaged by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").
2.10. User — any visitor to the website http://f11club.ru/en.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing with personal data to an unlimited number of persons, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign government body, a foreign physical or legal person.
2.14. Destruction of personal data — any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoration of personal data content in the personal data information system and (or) in the destruction of personal data material carriers.
3. Operator’s Basic Rights and Obligations
3.1. The Operator has the right to:

• Receive reliable information and/or documents containing personal data from the subject of personal data.
• Continue the processing of personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law, in case of withdrawal of the subject's consent to the processing of personal data or in case of a request for termination of personal data processing.
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of duties stipulated by the Personal Data Law and adopted legal regulations, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• Provide the subject of personal data, at their 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 in accordance with the requirements of the Personal Data Law.
• Notify the authorized body for the protection of personal data subjects' rights on requests for information within 10 days from the date of receiving such a request.
• Publish or otherwise provide unrestricted access to this Policy on personal data processing.
• Take legal, organizational, and technical measures to protect personal data from illegal or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions.
• Terminate the transfer (distribution, provision, access) and processing of personal data and destroy personal data in the manner and cases specified in the Personal Data Law.
• Perform other duties stipulated by the Personal Data Law.

4. Basic 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 by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and order of its receipt is defined by the Personal Data Law.
• Demand the Operator to clarify their personal data, block or destroy it if personal data is incomplete, outdated, inaccurate, illegally obtained or unnecessary for the declared processing purpose, and take legally prescribed measures to protect their rights.
• Require prior consent for the processing of personal data to advertise goods, works, and services.
• Withdraw consent to the processing of personal data, and require the termination of personal data processing.
• Appeal to the authorized body for the protection of personal data subject’s rights or judicially the Operator’s illegal actions or inactions regarding personal data processing.
• Exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• Provide true data about themselves to the Operator.
• Notify the Operator of clarifications (updates, changes) to their personal data.

4.3. Individuals who transferred false information about themselves to the Operator or information about another personal data subject without their consent are responsible under the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine personal data information systems, processing of which is carried out for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of personal data being processed should match the declared processing purposes. The excessive nature of personal data in relation to the declared processing purposes is not allowed.
5.6. During personal data processing, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the processing purposes must be ensured. The Operator shall take necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data storage is carried out in a form that allows for the identification of the personal data subject, not longer than required by the purposes of personal data processing, unless the personal data storage period is established by federal law, a contract to which the beneficiary or guarantor is the personal data subject. The processed personal data is destroyed or anonymized upon the achievement of the processing purposes or in case of loss of the necessity in achieving these purposes unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
The purpose of processing is to inform the User by sending electronic messages.
Personal data:

• Surname, first name, patronymic
• Email address
• Phone numbers

Legal grounds: contracts between the operator and the personal data subject
Types of personal data processing:

• Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
• Sending informational messages to the email address

7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject to process their personal data.
7.2. Personal data processing is necessary to achieve the goals stipulated by international treaties of the Russian Federation or law, to fulfill the functions, powers, and duties assigned by the legislation of the Russian Federation to the operator.
7.3. Personal data processing is necessary to execute justice, enforce a judicial act, an act of another authority, or an official enforceable under the laws of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, and for the conclusion of a contract initiated by the personal data subject or a contract under which the subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. The processing of public personal data, access to which is provided to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as "public personal data").
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
8. 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 for full compliance with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation, or if the personal data subject has given the Operator consent to transfer data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can independently update them by sending a notification to the Operator's email address hedgefundf11@gmail.com marked "Personal Data Update."
8.4. The processing period of personal data is determined by achieving the purposes for which the personal data was collected unless otherwise provided by the contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to hedgefundf11@gmail.com marked "Withdrawal of Consent to Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the specified documents should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including service providers specified in this clause.
8.6. The personal data subject's prohibitions on transfer (except for providing access) and processing or conditions of processing (except for obtaining access) of public personal data do not apply in cases of processing personal data for state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the personal data storage period is established by federal law, a contract to which the beneficiary or guarantor is the personal data subject.
8.9. The condition for the termination of personal data processing can be achieving the purposes of personal data processing, expiration of the data subject's consent, withdrawal of consent by the personal data subject, or a requirement to terminate the personal data processing, as well as identification of illegal processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distribution, provision, access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and (or) transfer of the received information via information and telecommunication networks or without such.
10. Cross-border Transfer of Personal Data
10.1. Before commencing the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights about its intention to perform a cross-border transfer of personal data (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from foreign governmental authorities, foreign individuals, and foreign legal persons to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obligated not to disclose the personal data to third parties and not to disseminate the personal data without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at hedgefundf11@gmail.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at http://f11club.ru/en.