Privacy Policy

This Privacy Policy is established in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and outlines the procedures for processing personal data and the measures taken by Volna (hereinafter referred to as the “Operator”) to ensure the security of personal data.

1.1. The Operator considers the protection of human and civil rights and freedoms during the processing of personal data to be a fundamental goal and condition of its operations, including safeguarding the right to privacy, personal, and family secrets.

1.2. This Privacy Policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may collect about visitors to the website https://volna.me.

2.1. Automated Processing of Personal Data: Processing of personal data using computer technology.

2.2. Blocking of Personal Data: Temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website: A collection of graphic and informational materials, as well as computer programs and databases, made accessible on the internet at the network address https://volna.me.

2.4. Personal Data Information System: A set of personal data contained in databases, along with information technologies and technical means that enable their processing.

2.5. Anonymization of Personal Data: Actions that make it impossible to attribute personal data to a specific User or other personal data subject without additional information.

2.6. Processing of Personal Data: Any action (operation) or set of actions (operations) performed with personal data, whether automated or not, including collection, recording, systematization, accumulation, storage, updating (modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, or destruction of personal data.

2.7. Operator: A state body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal Data: Any information relating directly or indirectly to an identified or identifiable User of the website https://volna.me.

2.9. Personal Data Authorized for Dissemination: Personal data to which the data subject has granted access to an unlimited number of persons by consenting to the processing of such data in accordance with the procedures outlined in the Personal Data Law (hereinafter referred to as “personal data authorized for dissemination”).

2.10. User: Any visitor to the website https://volna.me.

2.11. Provision of Personal Data: Actions aimed at disclosing personal data to a specific person or group of persons.

2.12. Dissemination of Personal Data: Any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in the media, posting on information and telecommunication networks, or otherwise providing access to personal data.

2.13. Cross-Border Transfer of Personal Data: Transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of Personal Data: Any actions resulting in the irreversible destruction of personal data, with no possibility of restoring 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:

• Obtain accurate information and/or documents containing personal data from the data subject;
• Continue processing personal data without the data subject’s consent in cases where there are grounds specified in the Personal Data Law, even if the data subject withdraws consent or requests termination of processing;
• Independently determine the scope and list of measures necessary and sufficient to fulfill obligations under the Personal Data Law and related regulations, unless otherwise stipulated by the Personal Data Law or other federal laws.

3.2. The Operator is obligated to:

• Provide the data subject, upon request, with information regarding the processing of their personal data;
• Process personal data in accordance with the procedures established by current Russian legislation;
• 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 within 10 days of receiving such a request;
• Publish or otherwise provide unrestricted access to this Privacy Policy regarding the processing of personal data;
• Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, or other unlawful actions;
• Cease the transfer (dissemination, provision, or access), processing, and destruction of personal data in the manner and cases provided for by the Personal Data Law;
• Fulfill other obligations stipulated by the Personal Data Law.

4.1. Data subjects have the right to:

• Obtain information regarding the processing of their personal data, except in cases provided for by federal laws. Such information must be provided by the Operator in an accessible form and must not include personal data relating to other data subjects, except where there are lawful grounds for disclosure. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• Demand that the Operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take legally prescribed measures to protect their rights;
• Require prior consent for the processing of personal data for the purpose of promoting goods, works, or services in the market;
• Withdraw consent to the processing of personal data and request termination of processing;
• Appeal to the authorized body for the protection of data subjects’ rights or in court regarding unlawful actions or inaction by the Operator in processing their personal data;
• Exercise other rights provided for by Russian legislation.

4.2. Data subjects are obligated to:

• Provide the Operator with accurate information about themselves;
• Notify the Operator of any updates or changes to their personal data.

4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another data subject without their consent shall be held liable in accordance with Russian legislation.

5.1. Personal data processing is carried out on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collection is not permitted.

5.3. Databases containing personal data processed for incompatible purposes must not be merged.

5.4. Only personal data that meets the purposes of processing is subject to processing.

5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data beyond the stated purposes is not permitted.

5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data are ensured during processing. The Operator takes necessary measures, or ensures their implementation, to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or when the need to achieve these purposes ceases, unless otherwise provided by federal law.

• Purpose: Informing the User through the sending of emails.
• Personal Data: Last name, first name, patronymic; phone numbers; first name.
• Legal Basis: Federal Law No. 149-FZ of July 27, 2006, “On Information, Information Technologies, and Information Protection.”
• Types of Processing: Transfer of personal data.

7.1. Personal data processing is carried out with the consent of the data subject.

7.2. Processing is necessary to achieve purposes stipulated by an international treaty of the Russian Federation or law, or to fulfill functions, powers, and duties imposed on the Operator by Russian legislation.

7.3. Processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to enforcement under Russian legislation on enforcement proceedings.

7.4. Processing is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, or for entering into a contract at the initiative of the data subject or one in which the data subject will be a beneficiary or guarantor.

7.5. Processing is necessary to protect the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.

7.6. Processing involves personal data to which the data subject has granted access to an unlimited number of persons or at their request (hereinafter referred to as “publicly available personal data”).

7.7. Processing involves personal data subject to publication or mandatory disclosure in accordance with federal law.

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 on personal data protection.

8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent access 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 compliance with applicable law or when the data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address [email protected] with the subject line “Personal Data Update.”

8.4. The duration of personal data processing is determined by the achievement of the purposes for which the data was collected, unless a different period is stipulated by a contract 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 at [email protected] with the subject line “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 those entities (Operators) in accordance with their User Agreements and Privacy Policies. The data subject is responsible for familiarizing themselves with these documents. The Operator is not liable for the actions of third parties, including the service providers mentioned in this clause.

8.6. Restrictions set by the data subject on the transfer (except for granting access) or processing (except for obtaining access) of personal data authorized for dissemination do not apply in cases of processing in the state, public, or other public interests as defined by Russian legislation.

8.7. The Operator ensures the confidentiality of personal data during processing.

8.8. The Operator stores personal data in a form that allows identification of the data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor.

8.9. Processing of personal data may be terminated upon achieving the processing purposes, expiration of the data subject’s consent, withdrawal of consent, a request to cease processing, or detection of unlawful processing.

9.1. The Operator collects, records, systematizes, accumulates, stores, updates (modifies), retrieves, uses, transfers (disseminates, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data, with the receipt and/or transmission of information via information and telecommunication networks or otherwise.

10.1. Before initiating cross-border transfer of personal data, the Operator must notify the authorized body for the protection of data subjects’ rights of its intent to carry out such a transfer (this notification is separate from the notification of intent to process personal data).

10.2. Prior to submitting the aforementioned notification, the Operator must obtain relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

The Operator and other persons who have gained access to personal data are obligated not to disclose or disseminate personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.

12.1. The User may obtain clarification on any questions regarding the processing of their personal data by contacting the Operator via email at [email protected].

12.2. Any changes to the Operator’s Privacy Policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the internet at https://volna.me/privacy/.