Personal Data Processing Policy

1. Personal Data Processing Policy

The Personal Data Processing Policy (the "Policy") is adopted in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" and defines the personal data processing procedure and measures implemented by Kristian Torres Cestaro (the "Operator") to secure personal data.

  1. The Operator's paramount purpose and precondition for carrying out his activities is to procure the protection of a person's rights and liberties while processing his/her personal data, including the right to privacy, personal and family secrecy.
  2. 1. The Policy applies to all information that the Operator can obtain about the visitors of the website

2. Terms and Definitions

  1. Automated personal data processing means personal data processing by means of computer technology;
  2. Blocking of personal data means temporary cessation of personal data processing (except for the cases when the processing is needed for personal data specification);
  3. Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability at;
  4. Personal data information system means a set of personal data contained in personal data databases, and information technologies and technical means used to process personal data;
  5. Anonymization of personal data means actions performed on personal data that do not permit to identity the individual concerned solely on the basis of such anonymized data;
  6. Personal data processing means any action (operation) or a combination of actions (operations) performed both automatically and manually with personal data, including collection, recording, arrangement, accumulation, storage, specification (updating, changing), extraction, use, distribution (including transfer), anonymizing, blocking and destruction of personal data;
  7. Operator means a state agency, municipal authority, legal entity or individual who independently or in cooperation with other entities organizes and/or processes personal data as well as determines the purposes and scope of personal data processing;
  8. Personal data means any information relating directly or indirectly to a particular or definable user of the website;
  9. User means any visitor of the website;
  10. Provision of personal data means actions related to making the data available to a definite person or a definite range of persons;
  11. Distribution of personal data means actions related to making the data available to an indefinite range of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publishing personal data in the media, information and telecommunications networks or providing access to personal data in any other way;
  12. Cross-border transfer of personal data means cross-border transfer of personal data to a foreign state agency, a foreign legal entity or an individual located in a foreign state;
  13. Destruction of personal data means actions performed on personal data contained in the respective database that prevent such data from being restored and (or) actions aimed at the physical destruction of a tangible medium with personal data.

3. The Operator may process the following user personal data:

  1. Full name;
  2. E-mail;
  3. Phone;
  4. The website also collects and processes anonymized visitors' data (including cookies) using Internet statistics services (Yandex.Metrica, Google Analytics etc.);
  5. The above-mentioned data is hereinafter referred to as personal data.

4. Purposes of personal data processing

  1. The purpose of personal data processing is to send emails to the User.
  2. In addition, the Operator reserves the right to send new products, services, events notifications and special offers to the User. The User can unsubscribe at any time from information communications by sending an email to the Operator at entitled "Please cancel my subscription to new products, services, and special offers notifications".
  3. Internet statistics services gather anonymized user data, including actions of the Users on the website, to improve the website's quality and its content.

5. Personal Data Processing Legal Grounds

  1. The Operator processes the User's personal data only if the User wishes to fill his/her data in the forms at By filling out the relevant forms and/or sending his/her personal data to the Operator, the User expresses his consent to this Policy.
  2. The Operator processes user anonymized data if it is allowed by the settings of the User's browser (cookies and JavaScript are enabled)

6. Procedure for personal data collecting, storing, transferring and other means processing

Security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully implement the personal data protection laws.
  1. The Operator must secure personal data and take all possible measures to prevent unauthorized persons from accessing personal data.
  2. User's personal data will never, under any circumstances, be transferred to third parties, except when the Operator must disclose personal data in accordance with the law.
  3. In the event that the User identifies personal data errors, the User may update his/her personal data by sending an email at entitled "Personal data update".
  4. The period of personal data processing is unlimited. The User may withdraw his/her consent to the processing of personal data at any time by sending the Operator an email at entitled "Withdrawal of consent to the processing of personal data".

7. Cross-border transfer of personal data

  1. Before any cross-border transfer of personal data, the Operator must make sure that the foreign state to which the personal data transfer is supposed to be made, ensures reliable protection of the rights of the data subject.
  2. Cross-border transfers of personal data to foreign states that do not meet the aforementioned requirements may take place only if the personal data subject consents in writing to the cross-border transfer of his/her personal data and /or the transfer is performed in accordance with an agreement, to which the personal data subject is a party.

8. Final provisions

  1. The User may obtain any clarifications on the processing of his/her personal data by sending the Operator an email at
  2. This document will reflect any changes to the Operator's Personal Data Processing Policy. The Policy is valid indefinitely until replaced by a new version.
  3. The current version of the Policy is freely available at