Policy regarding the processing of personal data
1. General Provisions
This personal data processing policy is drafted 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 defines the procedure for processing personal data and the measures for ensuring the security of personal data undertaken by AVAMARINA Real Estate LLC (hereinafter referred to as the Operator).
1.1. The operator's primary goal and condition for carrying out its activities is to ensure the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy, personal, and family secrets.
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 receive about visitors to the website https://avamarina.com/en.
2. Key concepts used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing equipment.
2.2. Blocking of personal data — temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data is the process by which it is impossible to determine the affiliation of personal data to a specific User or another subject of personal data without using additional information.
2.6. Processing of personal data is any action (operation) or set of actions (operations) performed with the use of automation tools or without such tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. The operator is a state body, municipal body, legal entity, or individual, 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, and the actions (operations) performed with personal data.
2.8. Personal data is any information relating directly or indirectly to a specific or identifiable User of the website https://avamarina.com/en.
2.9. Personal data permitted by the data subject for dissemination are personal data to which an unlimited number of persons have access, granted by the data subject through consent to the processing of personal data permitted by the data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. The user is any visitor to the website https://avamarina.com/en.
2.11. Provision of personal data is the action aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data is any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the 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, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of physical carriers of personal data.

3.1. The operator has the right:
— receive accurate information and/or documents containing personal data from the data subject;
— in the event of the data subject withdrawing consent for the processing of personal data, as well as submitting a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject 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 stipulated by the Personal Data Law and the regulatory legal acts 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 data subject, 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 appeals 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 personal data subjects' rights with the necessary information upon request within 10 days from the date of receiving such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;

— cease the transfer (distribution, provision, access) of personal data, cease the processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other duties provided for by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Data subjects have the right:

— demand that the operator clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and also take legally prescribed measures to protect their rights;

— on the withdrawal of consent to the processing of personal data, as well as on the submission of a request to cease the processing of personal data;
— appeal to the authorized body for the protection of personal data subjects' rights or to the court against the unlawful actions or inactions of the Operator in processing his personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obliged to:
— provide the Operator with accurate information about yourself;
— inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing personal data are ensured. The operator takes necessary measures and/or ensures their adoption for the removal or clarification of incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows the identification of the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of loss of necessity 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
surname, first name, patronymic, phone numbers
Legal grounds
Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 No. 149-FZ
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
7. Conditions for the processing of personal data
7.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, for the performance of 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 execution of a judicial act, the act of another body or official, subject to execution 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 for the benefit of which the data subject is a beneficiary or guarantor, 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 or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. The processing of personal data is carried out, access to which has been provided by the data subject or at their request to an unlimited number of persons (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for the collection, storage, transfer, and other types of processing of personal data
The security of personal data processed by the Operator is ensured by implementing 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 prevent unauthorized access to personal data.
8.2. The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the enforcement of applicable law or if the data subject has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User can update it independently by sending a notification to the Operator's email address m@avamarina.com with the subject "Personal Data Update."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the contract or applicable law.
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 the Operator's email address m@avamarina.com with the subject "Withdrawal of consent to the processing of personal data."
8.5. 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 data subject and/or with the specified 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 subject of personal data on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The operator ensures the confidentiality of personal data when processing personal data.
8.8. The operator stores personal data in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may be conditioned by the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject, or a request to cease personal data processing, as well as the detection of unlawful personal data processing.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information through information and telecommunication networks or without such networks.

10. Cross-border transfer of personal data
10.1. Before commencing activities related to the cross-border transfer of personal data, the operator is required to notify the authorized body for the protection of the rights of personal data subjects of their intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before 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. Privacy of Personal Data
The operator and other individuals who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The user can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at m@avamarina.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. 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://avamarina.com/policyeng.