Privacy Policy for the NUR Media Art Festival Website

This Personal Data Processing Policy has been developed in accordance with the requirements of Federal Law No. 152-FL of July 27, 2006, No. 152-FL “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Media Proof Limited Liability Company (hereinafter referred to as the “Operator”).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and personal and family secrets, to be its primary goal and a prerequisite for conducting its activities.
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://nurfestival.com, including anonymized data and data on user activity.
1.3. The Operator reserves the right to make necessary changes to the Policy in the event of changes to the current legislation of the Russian Federation and the conditions of its operations.
1.4. The Policy (including any amendments thereto or a new version of the Policy) shall enter into force upon its publication on the website, unless otherwise provided for in the Policy.

2.1. Automated processing of personal data — the processing of personal data using computer technology.
2.2. Blocking of personal data — the temporary suspension of the processing of personal data (except in cases where processing is necessary to verify the accuracy of the personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the web address nurfestival.com
2.4. Personal Data Information System — a collection of personal data contained in databases, along with the information technologies and technical means that enable their processing.
2.5. Anonymization of personal data — actions that make it impossible to determine, without the use of additional information, whether personal data belongs 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 on personal data, including collection, recording, organization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Controller — a government agency, municipal authority, legal entity, or individual that, either independently or jointly with others, organizes and/or carries out the processing of personal data, as well as determines the purposes of such processing, the scope of personal data to be processed, and the actions (operations) performed on the personal data.
2.8. Personal Data — any information relating directly or indirectly to a specific or identifiable User of the nurfestival.com website
2.9. Personal data authorized by the data subject for disclosure — personal data to which an unlimited circle of persons has been granted access by the data subject through the provision of consent to the processing of personal data authorized by the data subject for disclosure in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data authorized for disclosure).
2.10. User — any visitor to the nurfestival.com website
2.11. Disclosure of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Disclosure of personal data—any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or to make personal data available to an unlimited group of persons, including the publication of personal data in the media, posting on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a government authority of a foreign state, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently restore the content of the personal data in the personal data information system and/or the destruction of physical media containing personal data.

3.1. The Operator has the right to:
— receive from the data subject accurate information and/or documents containing personal data;
— in the event that the data subject revokes consent to the processing of personal data, or submits a request to cease processing personal data, the Operator has the right to continue processing personal data without the data subject’s consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
— receive and process data that is automatically transmitted to the Operator during the use of services via software installed on the User’s device, including the IP address, cookie data, information about the User’s browser (or other program used to access the Operator’s website), technical specifications of the hardware and software used by the User, the date and time of access to the website, the addresses of requested pages, and other similar information.

3.2. The Data Controller is obligated to:
— provide the data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedures established by the current legislation of the Russian Federation;
— respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of data subjects’ rights with the necessary information upon request within 10 (ten) days from the date of receipt of such a 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 unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, or dissemination of personal data, as well as from other unlawful actions regarding personal data;
— cease the transfer (distribution, disclosure, access) of personal data, cease processing, and destroy personal data in the manner and under the circumstances provided for by
the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.

4.1. Data subjects have the right to:
— receive information regarding the processing of their personal data, except as provided for by federal laws. The information is provided to the data subject by the Controller in an accessible form and must not contain personal data relating to other data subjects, except in cases 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 Law;
— to require the Operator to correct, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, obtained unlawfully, or unnecessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— to require prior consent for the processing of personal data for the purpose of marketing goods, works, and services;
— to withdraw consent for the processing of personal data, as well as to submit a request to cease the processing of personal data;
— to appeal to the authorized body for the protection of the rights of data subjects or through the courts against unlawful actions or inaction by the Operator in the processing of their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are required to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any corrections (updates, changes) to their personal data.
4.3. The user consents to the collection, processing, and transfer of cookies to third parties. The user may disable cookies in the settings of the browser they use to access the website. Disabling cookies may result in the inability to access parts of the website that require authorization.
4.4. Persons who have provided the Operator with false information about themselves, or information about another data subject without the latter’s consent, shall be liable in accordance with the laws of the Russian Federation.

5.1. Personal data shall be processed on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predefined, and legitimate purposes. The processing of personal data that is incompatible with the purposes for which the personal data was collected is prohibited.
5.3. It is not permitted to combine databases containing personal data that are processed for purposes incompatible with one another.
5.4. Only personal data that is relevant to the purposes of processing shall be processed.
5.5. The content and scope of the personal data being processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of processing is not permitted.
5.6. When processing personal data, the accuracy, adequacy, and, where necessary, relevance of the personal data to the purposes of processing are ensured. The controller takes the necessary measures and/or ensures that such measures are taken to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows for the identification of the data subject for no longer than is necessary to achieve the purposes of processing, unless the retention period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in the event that the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.

The purpose of processing is to conclude, perform, and terminate civil law contracts; to provide the User with access to the services, information, and/or materials contained on the website; to contact the User using the contact information provided; to inform the User by sending emails and phone calls, using the User’s data to maintain communication with the User by any means, including phone calls to the specified phone number, sending SMS messages and messages via messengers to the specified phone number, sending emails to the specified email address to inform the User about ongoing promotions, events, discounts, and their results; to conduct remote surveys to gather feedback on services and events; to send newsletters, etc.; and to process SMS messages, emails, requests, and applications from the User.

Personal Data
– last name, first name, middle name;
– email address;
– contact phone number;
– IP address and cookie data;
– information about the browser or other software used to access the Operator’s website;
– technical specifications of the hardware and software used by the User;
– date and time of access to the website;
– information about purchases made through the Operator’s website and order history;
– URLs of requested pages and other similar information.

Legal Basis
– Federal Law “On Information, Information Technologies, and Information Protection” dated July 27, 2006, No. 149-FL;
– Federal Law “On Personal Data” dated July 27, 2006, No. 152-FL;
– The Operator’s charter (incorporation) documents.

Types of personal data processing
– Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data;
– Sending informational emails to an email address;
– Sending SMS messages and messages via instant messaging apps;
– Making telephone calls.

7.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data. Consent to the Personal Data Processing Policy and to receiving informational and promotional messages and materials is deemed to have been obtained properly and without exception upon clicking any action button on the website, filling out any form on the website, sending any information to the Operator’s contact details, or logging in to the website, in which case no further confirmation is required from the User to the Operator.
7.2. The processing of personal data is necessary to achieve the objectives provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a judicial order, or an order of another authority or official, enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party or a beneficiary, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the controller or third parties, or to achieve socially significant objectives, provided that this does not infringe upon the rights and freedoms of the data subject.
7.6. The processing of personal data to which an unlimited circle of persons has been granted access by the data subject or at their request (hereinafter referred to as “Publicly Available Personal Data”) is carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
7.8. The Operator does not verify the accuracy of the personal information provided by the User and is unable to assess the User’s legal capacity; however, the Operator assumes that the User, in accordance with the Federal Law “On Personal Data,” freely, of their own volition, and in their own interest consents to the collection, analysis, processing, storage, and use of their personal data, provides accurate and sufficient personal information, and keeps this information up to date.

8.1. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable data protection laws.
8.2. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
8.4. If inaccuracies are found in the personal data, the User may update them independently by sending a notification to the Operator’s email address pr@nurfestival.com with the subject line “Update of Personal Data.”
8.5. The term for processing personal data is indefinite, unless a different term is provided for by the agreement or applicable law. 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 the Operator’s email address pr@nurfestival.com with the subject line “Withdrawal of consent to the processing of personal data.”
8.6. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by such entities (Operators) in accordance with their Terms of Service and Privacy Policy. The data subject and/or with the specified documents. The Operator is not liable for the actions of third parties, including the service providers specified in this clause.
8.7. Restrictions on the transfer (other than granting access) and on the processing or conditions of processing (other than obtaining access) of personal data authorized for disclosure, as established by the data subject, do not apply in cases where personal data is processed in the state, public, or other public interests as defined by the legislation of the Russian Federation.
8.8. When processing personal data, the operator ensures the confidentiality of personal data.
8.9. The Operator stores personal data in a form that allows for the identification of the data subject for no longer than is necessary to achieve the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the data subject is a party, or a contract under which the data subject is a beneficiary or guarantor.
8.10. The termination of personal data processing may be conditioned upon the achievement of the purposes of personal data processing, the expiration of the data subject’s consent, the withdrawal of consent by the data subject, a request to terminate personal data processing, or the detection of unlawful personal data processing.

9.1. The Operator collects, records, organizes, accumulates, stores, updates (modifies), retrieves, uses, transfers (distributes, discloses, provides access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data, with or without the receipt and/or transmission of the information received via information and telecommunications networks.

10.1. Before commencing activities involving the cross-border transfer of personal data, the controller must notify the competent authority responsible for protecting the rights of data subjects of its intention to carry out such a transfer (such notification shall be sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the aforementioned notification, the Operator is required to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11.1. The Operator and other persons who have access to personal data are prohibited from disclosing such data to third parties or disseminating it without the consent of the data subject, unless otherwise provided by federal law.

12.1. To ensure the security of personal data during its processing, the Operator takes measures to protect against unauthorized or accidental unlawful access, destruction, alteration, blocking, copying, and other actions that may compromise the security characteristics established for personal data, including:
- confidentiality (the requirement not to disclose information to third parties without the consent of its owner, which must be observed by any person who has access to the information);
- integrity (the state of information in which there are no changes, or changes are made only intentionally by authorized parties);
- availability (the state of information in which authorized subjects can exercise their access rights without hindrance).
12.2. The Controller shall take the necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, disclosure, and other unauthorized actions, including:
- identifying security risks to personal data during its processing;
- creates the necessary conditions for working with personal data;
- organizes the record-keeping of documents containing personal data;
- organizes the operation of systems in which personal data is processed;
- sets individual passwords for employees’ access to information systems containing personal data, in accordance with their job responsibilities.

13.1. Users may obtain clarification on any questions regarding the processing of their personal data by contacting the Operator via email at pr@nurfestival.com.
13.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. This Policy remains in effect indefinitely until replaced by a new version.
13.3. The current version of the Policy is freely available on the Internet at nurfestival.com.

Media Proof Limited Liability Company
TIN 1655395665 / KPP 165501001
Registered address: 420111, Republic of Tatarstan, Kazan, 19B Musa Jalil St., Office 1
pr@nurfestival.com