Personal Data Processing Policy


1. General Provisions
This personal data processing policy is compiled in accordance with the requirements of the Federal Law dated July 27, 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 M S S G MARKETING MANAGEMENT L.L.C. (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of privacy rights, personal and family secrets, as its primary goal and condition for carrying out its activities.
1.2. This Operator's personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://mssg.studio.

2. Basic Concepts 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 processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as programs for computers and databases, ensuring their availability on the Internet at the network address https://mssg.studio.
2.4. Information system of personal data - a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data - actions resulting in the impossibility to determine without additional information the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal or physical person, independently or jointly 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 relating directly or indirectly to a specific or identifiable User of the website https://mssg.studio.
2.9. Personal data permitted by the subject of personal data for dissemination - personal data to which the subject of personal data has granted access to an unlimited number of persons by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User - any visitor to the website https://mssg.studio.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including publishing personal data in the media, placing them in information and telecommunications 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 the authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.


3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
  • Obtain accurate information and/or documents containing personal data from the subject of personal data;
  • Continue processing personal data without the consent of the subject of personal data if the subject withdraws consent to the processing of personal data, or submits a request to stop processing personal data, provided 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 stipulated by the Personal Data Law and regulations adopted in accordance with it, 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, upon 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 requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
  • Report necessary information to the authorized body for the protection of the rights of subjects of personal data upon request within 10 days from the date of receipt of such a request;
  • Publish or otherwise provide unlimited 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 concerning personal data;
  • Cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
  • Fulfill other obligations stipulated by the Personal Data Law.

4. Main 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 relating to other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
  • Demand the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
  • Set a condition of prior consent when processing personal data for marketing purposes of goods, works, and services;
  • Withdraw consent to the processing of personal data, as well as submit a request to stop processing personal data;
  • Appeal against unlawful actions or inaction of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
  • Exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
  • Provide the Operator with accurate information about themselves;
  • Inform the Operator about clarifying (updating, changing) their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without their consent bear responsibility in accordance with 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 goals. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes of their processing is not allowed.
5.6. 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 their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the personal data subject no longer than the purpose of personal data processing requires unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or if there is no longer a need to achieve these purposes unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
  • Purpose of processing: informing the User by sending emails
  • Personal data: email address
  • Legal grounds: charter (founding) documents of the Operator
  • Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
  • Sending informational emails 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 the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement initiated by the personal data subject or an agreement under which the personal data 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. Processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collection, Storage, Transfer, 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 to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security 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 fulfillment of applicable law or if the personal data subject has given the Operator consent to transfer the data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address Art.p@mssg.agency with the subject "Personal Data Update".
8.4. The processing time for personal data is determined by the achievement of the purposes for which the personal data was collected unless another period is stipulated by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to Art.p@mssg.agency with the subject "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. The prohibitions established by the personal data subject on the transfer (except providing access), as well as on processing or conditions of processing (except obtaining access) of personal data allowed for dissemination, do not apply in cases of processing personal data in state, public, and other public interests as defined by Russian Federation legislation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than is required for the purposes of personal data processing unless the period of personal data storage is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achieving the processing purposes or in case there is no longer a need to achieve these purposes unless otherwise provided by federal law.
8.9. The condition for stopping the processing of personal data can be the achievement of the personal data processing purposes, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject, or a request to stop the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, updates (modifies), retrieves, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with receiving and/or transmitting the received information via information and telecommunication networks or without it.

10. Cross-Border Transfer of Personal Data
10.1. Before starting activities on the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out the 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 aforementioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities 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 obliged not to disclose personal data to third parties and not to disseminate 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 explanations on questions of interest regarding the processing of their personal data by contacting the Operator via email at Art.p@mssg.agency.
12.2. Any changes to 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.
12.3. The current version of the Policy is freely available on the Internet at https://mssg.studio.