1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law"). It defines the procedures for processing personal data and measures to ensure the security of personal data carried out by Mikhailov Ivan Sergeevich (hereinafter referred to as the "Operator").

1. The Operator considers the protection of human rights and freedoms in the processing of their personal data, including the right to privacy, personal and family secrets, as its main goal and a condition for carrying out its activities.
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 receive about visitors to the website https://gate-realty.com.

2. Basic Concepts Used in the Policy

3. Automated Processing of Personal Data — processing of personal data using computer equipment.
4. Blocking of Personal Data — temporary cessation of personal data processing (except cases where processing is necessary for clarification).
5. Website — a set of graphic and informational materials, as well as software and databases that ensure their availability on the internet via the network address https://gate-realty.com.
6. Personal Data Information System — a collection of personal data stored in databases and the information technologies and technical tools used to process them.
7. Anonymization of Personal Data — actions which make it impossible to determine, without additional information, the ownership of personal data to a specific User or other data subject.
8. Processing of Personal Data — any action (operation) or set of actions (operations) performed using automation tools or manually with personal data, including collection, recording, systematization, accumulation, storage, refinement (update, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
9. Operator — a government body, municipal authority, legal or natural person who organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of personal data, and the actions (operations) performed with personal data.
10. Personal Data — any information relating directly or indirectly to an identified or identifiable user of the website https://gate-realty.com.
11. Personal Data Permitted for Distribution — personal data whose access is made publicly available by the data subject through consent for processing such data in accordance with the Personal Data Law (hereinafter — personal data permitted for distribution).
12. User — any visitor of the website https://gate-realty.com.
13. Disclosure of Personal Data — actions aimed at revealing personal data to a certain person or group of persons.
14. Distribution of Personal Data — any actions aimed at revealing personal data to an undefined circle of people (transfer of personal data) or acquainting an unlimited number of people with personal data, including publication in mass media, placement in information and telecommunications networks, or providing access to personal data in any other way.
15. Transborder Transfer of Personal Data — transfer of personal data to the territory of a foreign state, to a foreign state body, foreign physical or foreign legal entity.
16. Destroying Personal Data — any actions resulting in permanent destruction of personal data with no possibility of further recovery of the content of personal data in the personal data information system and/or destruction of material carriers of personal data.

3. Main Rights and Obligations of the Operator

14. The Operator has the right:
    • to obtain from the personal data subject accurate information and/or documents containing personal data;
    • in case the personal data subject revokes consent for processing personal data, or submits a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject if grounds are provided under the Personal Data Law;
    • to independently determine the composition and list of measures necessary and sufficient to fulfill 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.
15. The Operator is obliged:
    • to provide the subject of personal data with information concerning the processing of his personal data upon request;
    • to organize the processing of personal data in accordance with the current legislation of the Russian Federation;
    • to respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
    • to report to the authorized body for the protection of the rights of personal data subjects upon request of this body the necessary information within 10 days from the date of receipt of such request;
    • to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
    • to take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, providing, distributing personal data, as well as from other unlawful actions in relation to personal data;
    • to cease transmission (distribution, provision, access) of personal data, to stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
    • to perform other duties provided for by the Personal Data Law.

3. Main Rights and Obligations of the Operator

14. The Operator has the right:
    • to obtain accurate information and/or documents containing personal data from the data subject;
    • in case the data subject revokes consent for processing personal data, or submits a request to stop the processing of personal data, the Operator may continue processing such data without the subject’s consent if grounds are provided under the Personal Data Law;
    • to independently determine the necessary and sufficient measures required to fulfill obligations stipulated by the Personal Data Law and regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
15. The Operator is obliged:
    • to provide the data subject with information concerning the processing of their personal data upon request;
    • to organize personal data processing in compliance with current Russian legislation;
    • to respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
    • to report to the authorized body for the protection of personal data rights, upon request, the necessary information within 10 days of receiving such a request;
    • to publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
    • to take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, disclosure, dissemination, as well as any other unauthorized actions;
    • to cease transmission (distribution, provision, access) of personal data, to stop processing, and destroy personal data in the manner and cases specified by the Personal Data Law;
    • to perform other duties provided by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

16. 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 in an accessible format and must not contain personal data relating to other data subjects, unless legally justified. The list of such information and the procedure for its receipt are established by the Personal Data Law;
    • to request clarification, blocking, or deletion of their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, and to take other protective measures provided by law;
    • to require prior consent when processing personal data for the promotion of goods, works, and services on the market;
    • to revoke consent for personal data processing and to submit a request to terminate such processing;
    • to file complaints with the authorized body for the protection of personal data rights or to appeal in court against unlawful actions or inaction by the Operator during data processing;
    • to exercise other rights provided by Russian legislation.
17. Data subjects are obliged:
    • to provide the Operator with accurate personal information;
    • to notify the Operator about changes to their personal data (updates or modifications).
18. Individuals who provide false information about themselves or disclose another person's personal data without consent are liable in accordance with Russian legislation.

5. Principles of Personal Data Processing

5. Personal data processing is carried out on a lawful and fair basis.
6. Processing of personal data is limited to achieving specific, previously defined, and legitimate purposes. Processing that is incompatible with the purposes of data collection is prohibited.
7. Combining databases containing personal data processed for incompatible purposes is not allowed.
8. Only personal data that corresponds to the purposes of processing shall be processed.
9. The content and scope of processed personal data correspond to the declared purposes of processing. Excessive personal data in relation to the stated purposes of processing is not allowed.
10. Accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing are ensured during processing. The Operator takes necessary measures, or ensures they are taken, to delete or correct incomplete or inaccurate data.
11. Personal data is stored in a form allowing identification of the data subject no longer than necessary for the purposes of processing, unless the storage period is set by federal law, contract, or where the subject is a party, beneficiary, or guarantor of the contract. Processed personal data is destroyed or anonymized upon achievement of processing objectives or loss of necessity, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: informing the User via email

Personal data collected:

• Last name, first name, patronymic
• Email address
• Phone numbers
• Year, month, date, and place of birth

Legal basis: contracts concluded between the Operator and the data subject

Types of personal data processing:

• Collection
• Recording
• Systematization
• Accumulation
• Storage
• Destroying and anonymizing personal data

7. Conditions for Personal Data Processing

7. Processing of personal data is carried out with the consent of the data subject for the processing of their personal data.
8. Processing of personal data is necessary to achieve goals provided by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and duties assigned to the Operator by Russian legislation.
9. Processing of personal data is necessary for the administration of justice, execution of a court decision, or decisions of other authorities or officials, which must be enforced in accordance with Russian legislation on enforcement proceedings.
10. Processing of personal data is necessary for the performance of a contract where the data subject is a party, beneficiary, or guarantor, as well as for concluding a contract initiated by the data subject or one where the data subject will be a beneficiary or guarantor.
11. Processing of personal data is necessary to realize 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.
12. Processing of personal data whose access is made publicly available by the data subject or at their request (hereinafter — publicly accessible personal data).
13. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transmission, 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 on personal data protection.

8. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to them.
9. User personal data will never be transferred to third parties under any circumstances, except in cases related to the execution of current legislation or if the data subject has given consent to the Operator for transferring data to a third party for the fulfillment of obligations under a civil law contract.
10. In case of inaccuracies found in personal data, the User can update them independently by sending a notification to the Operator at the email address: gate.realtyme@gmail.com with the subject line “Updating Personal Data”.
11. The duration of personal data processing is determined by the achievement of the purposes for which the data was collected, unless otherwise provided by a contract or current legislation. The User may withdraw their consent to data processing at any time by sending a notice via email to gate.realtyme@gmail.com with the subject line “Revoking Consent for Personal Data Processing”.
12. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their user agreement and privacy policy. The Operator is not responsible for the actions of third parties, including those mentioned in this section.
13. Restrictions set by the data subject on transferring (except granting access), processing, or conditions for processing (except granting access) of publicly available personal data do not apply in cases involving public interest processing as defined by Russian legislation.
14. The Operator ensures confidentiality of personal data during processing.
15. The Operator stores personal data in a form that allows identifying the data subject no longer than necessary for the purposes of processing, unless the storage period is set by federal law, contract, or where the subject is a party, beneficiary, or guarantor of the contract.
16. Termination of personal data processing may occur upon achieving the processing objectives, expiration of the data subject's consent, withdrawal of consent, or a request to terminate processing, as well as upon discovery of unlawful processing.

9. List of Actions Performed by the Operator with Collected Personal Data

9. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, refinement (updating, modifying), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction.
10. The Operator performs automated processing of personal data with or without obtaining or transmitting information via telecommunications networks.

10. Transborder Transfer of Personal Data

10. Before starting transborder transfer of personal data, the Operator must notify the authorized body for the protection of data subjects' rights about the intention to carry out such transfer. This notification is submitted separately from the notification of intent to process personal data.
11. Before submitting the above notification, the Operator must obtain relevant information from foreign government bodies, foreign individuals, and foreign legal entities to whom the transborder transfer of personal data is planned.

11. Confidentiality of Personal Data

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

12. Final Provisions

12. The User may contact the Operator via email at gate.realtyme@gmail.com for clarifications regarding personal data processing.
13. This document will reflect any changes to the Operator's personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.
14. The current version of the Policy is freely available online at https://gate-realty.com.

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