Your privacy is critically important to us. At the Seven Winds Charitable Art Foundation, we have some fundamental principles:
- We don’t ask for personal information unless we really need it.
- We do not share your personal information with anyone, except to comply with the law or protect our rights.
- We store and process personal data in strict accordance with the requirements of the laws of the Russian Federation.
All of the following is an expression of these principles in more precise formulations.
2. General provisions
This Policy (the “Policy”), developed in accordance with the Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (the “PD Law”), is an internal fundamental regulatory document of the Seven Winds Foundation which determines its main areas of activity in terms of the processing and protection of personal data.
For the purposes of this Policy the Seven Winds Foudation or Operator shall mean “The Seven Winds Charitable Art Foundation for Support of Contemporary Artists and Talented Youth” – non-profit charitable organization registered on May 11, 2011 in accordance with the laws of the Russian Federation (Tax Num. 3443104029 / Reg. Num. 1113400001770 / Reg. Code 344401001).
This Policy aims to implement the personal data processing and protection legislation requirements and also to protect the rights and freedoms of individuals and citizens when the Seven Winds Foudation processes their personal data.
The following terms are defined in the Policy:
- Security of personal data – the state of protection of personal data from illegal acts, characterized by the ability of users, technical means and information systems to ensure the confidentiality, integrity and availability of personal data during their processing, regardless of their form.
- Confidentiality of personal data – a mandatory requirement for the Operator or other person who has gained access to personal data not to disclose to third parties and not to allow their dissemination in the absence of the consent of the personal data subject or other legal grounds.
- Personal data processing – 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.
- Operator of personal data – 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.
- Personal data (PD) – any information referring directly or indirectly to a particular or identified individual (hereinafter referred to as “PD Subject”).
- Website – a set of linked web pages (plus their associated resources – texts, images and other media) that share a unique domain name http://7vetrov.net or https://seven-winds.art
- User – any visitor to the specified websites and their subdomains.
- Depersonalization (of PD) – actions that lead to the impossibility of determining the ownership of personal data by a specific person.
See also: Legal Disclaimer
2. The rights of the personal data subjects
The PD subjects have the following rights:
- the right to receive information with respect to the processing of their PD in the Seven Winds Foudation as well as with respect to the PD processed under the Seven Winds Foudation’s instruction;
- the right to designate their representatives to defend their rights;
- the right to request an Seven Winds Foudation to rectify, block or destroy their PD in the event that the PD are incomplete, out-of-date, inaccurate or unlawfully obtained or are not needed for the stated purpose of the processing, and shall have the right to take measures provided for by law to protect their rights;
- the right to claim notification by the Seven Winds Foudation of all third parties to whom the incorrect or incomplete PD have been transferred on all amendments of PD;
- the right to get a free of charge access to their PD, including the right to get a copy of any PD entry, except as otherwise provided by federal laws;
- the right to withdraw the consent for PD processing;
- the right to object against decisions taken solely on the basis of the automated processing of their PD as well as to receive clarifications from the Operator regarding the means by which the PD subjects may protect their rights and legitimate interests;
- the right to appeal against the actions or inaction of the Operator to the authorized body for the protection of the personal data subjects’ rights or through the courts;
- other rights provided by laws of the Russian Federation
3. Personal data processing: purposes and principles
The Seven Winds Foudation shall process PD fairly and lawfully, and only to the extent necessary to achieve certain previously determined legitimate purposes.
Personal data is processed for the following purposes:
- presentation and promotion of artists and their works;
- presentation and promotion of participants of creative contests and projects of the Seven Winds Foundation;
- presentation of information about printed and digital editions, their authors and editors;
- presentation of information about the authors of publications posted on the website;
- sending news messages to website Users.
Only those PD should be processed that meet their processing purposes. The content and scope of PD to be processed by the Seven Winds Foudation shall correspond to declared processing purposes; it is prohibited to process any redundant PD.
When the Seven Winds Foudation processes PD, it shall ensure their accuracy, adequacy and relevance in relation to processing purposes. The Seven Winds Foudation shall take all necessary measures to destroy (delete) or clarify incomplete or inaccurate PD.
The Seven Winds Foudation shall store PD in such a form as to allow the identification of the subject of the Personal Data, and for a period no longer than is required by their processing purposes if such a period of storage is not stipulated by the PD Law or contract (agreement) under which the PD subject acts as a party, beneficiary, or guarantor. Processed PD should be destroyed or sanitised as soon as their processing purposes are achieved or if they no longer need to be achieved, unless otherwise stipulated by the federal laws.
In the course of its activity and with the consent of the PD subject, the Seven Winds Foudation may delegate and (or) assign operations on PD processing to another person, unless otherwise provided by the PD Law. In such case the parties’ obligation to ensure the confidentiality and security of PD during their processing is a mandatory condition for delegating and (or) assigning operations on PD processing to another person.
The Seven Winds Foudation shall not place the subjects’ PD a in the public domain without their preliminary consent.
4. The personal data subjects
In the course of its main line of activity, the Seven Winds Foudation processes the PD of the following subjects (including, but not limited, to):
- Authors of works of art (artists);
- Authors and editors of printed and digital publications of the Seven Winds Foundation, as well as texts posted on the website;
- Participants in creative competitions and projects organized or conducted by the Seven Winds Foundation;
- Employees and volunteers of the Seven Winds Foundation (including former employees / volunteers and individuals whose contracts were terminated);
- Counterparties and partners of the Seven Winds Foundation;
- Visitors to the events of the Seven Winds Foundation – if access to these events requires the personal identification of visitors;
- Visitors of the websites operating in favor of the Seven Winds Foudation expressed their will to receive newsletters from the Seven Winds Foundation;
5. Key security measures for personal data
In order to protect Personal Data during their processing, the Seven Winds Foudation shall independently determine the content and list of measures that is necessary and sufficient for the performance of obligations stipulated by the Personal Data Law. Such measures shall include, specifically, the following:
- the appointment of a personal data processing manager.
- the adoption of documents determining the Seven Winds Foudation’s policy on Personal Data processing, issuing internal regulations on Personal Data processing and other internal regulatory documents establishing the procedures for preventing and detecting Russian law violations and eliminating the consequences of such violations.
- the application of legal, organisational and technical measures to protect Personal Data.
- the performance of internal controls to assess compliance with the PD Law, as well as with the regulations and requirements on Personal Data protection adopted thereunder, and with the Operator’s policy on Personal Data processing and its internal regulations.
- an assessment of the harm that might be caused to Personal Data subjects in the event of a breach of legal requirements, the extent of such identified harm, and security measures taken by the Seven Winds Foudation.
- familiarisation of the Seven Winds Foudation’s staff directly involved in Personal Data processing with PD Law requirements.
- arranging and (or) supervising activities related to the receipt and processing of applications and requests of Personal Data subjects or their representatives (in accordance with local legal provisions adopted in the Seven Winds Foudation);
- other security measures for personal data applied by the Seven Winds Foudation.
6. The response to the requests of the personal data subjects
In accordance with PD Law the PD subjects or their representatives are entitled to submit the following requests to the Seven Winds Foudation:
a) Request to the receipt of the information concerning the processing of PD, including:
- confirmation of the processing of PD by the Seven Winds Foudation;
- the legal grounds for and purposes of the processing of the PD;
- the purposes and methods used by the Seven Winds Foudation for the processing of the PD;
- the name and location of the Seven Winds Foudation and information on persons (other than staff of the Seven Winds Foudation) who have access to the PD or to whom the PD may be disclosed on the basis of a contract with the Seven Winds Foudation or on the basis of a federal law;
- the processed PD relating to the PD Subject in question and the source from which they were obtained, unless a different procedure for the presentation of such data is prescribed by a federal law;
- the period of the processing of the PD, including the data retention period;
- the procedure for the exercise by the PD Subject of the rights provided for in the PD Law;
- name or surname, first name and patronymic and the address of the person carrying out the processing of PD on the instruction of the Seven Winds Foudation, if the processing has been or is intended to be assigned to such a person;
- other information provided for in the PD Law or other federal laws.
b) Demand from an Operator that his personal data be adjusted, blocked or destroyed if the personal data are incomplete, outdated, incorrect, illegally received or are not necessary for the declared purpose of processing / if the purpose of processing is fulfilled;
c) Objection against the decision made exclusively on the basis of the automated PD processing;
d) Revoking of the consent to PD processing;
Requests by PD subjects (their representatives) can be submitted to the Seven Winds Foudation in a written form via Russian Post as well as in electronic form in accordance with the current legislation of the Russian Federation, personally by PD subject when visiting the Seven Winds Foudation and on the phone.
All the received requests by PD subjects (their representatives) in a paper or electronic form as well as the actions on dealing with such requests are registered by the Seven Winds Foudation on the day of reception of a request (if a request was received on a working day) or on the first day following the day of the reception of a request (if it was received on a non-working day) or on the day of performing the actions on dealing with a request respectively.
In case of submitting requests by PD subjects (their representatives) to the Seven Winds Foudation on the phone, they are to be informed that such requests have to be submitted personally or sent in a written form to the Seven Winds Foudation via Russian Post or in an electronic form in accordance with legislation of the Russian Federation. In this case the PD subject must be provided with the address where a written request is to be sent.
For requests of the personal data subjects see: Contact details
The request content requirement
A PD subject’s request shall contain the following information:
- the number of the principal identification document of the PD subject or of his legal representative;
- the date of issue of the identification document and the body which issued it;
- the information evidencing the PD subject’s relationship with the Seven Winds Foudation or information which otherwise confirms the processing of the PD by the Seven Winds Foudation;
- the signature of the PD subject or of his representative (if the request is sent in the electronic form it shall be made in a form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation).
When deemed necessary the Seven Winds Foudation may request the PD subject (the representative of the PD subject) to provide additional information. When the request of the PD subject does not contain the necessary information in accordance with PD Law or the PD subject does not possess the access rights to the requested data the Seven Winds Foudation shall provide a PD subject with a reasoned refusal. The right of access of a PD subject to his PD may be restricted in accordance with federal laws.
The Seven Winds Foudation’s staff recognizes the importance of and the need for PD protection and encourages the constant improvement of the system designed to protect Personal Data processed by the Seven Winds Foudation in the course of its main line of activity.