Personal Data Privacy Policy of the Charitable Foundation “Kolыbel Otechestva”

1. GENERAL PROVISIONS

1.1. This document — the Personal Data Processing Policy (hereinafter, the “Policy”) — defines the policy on the processing of personal data of users of the “Bitva Gorodov” website of the Charitable Foundation “Kolыbel Otechestva” (Primary State Registration Number (OGRN) 1237700595153, address: 101000, Moscow, Myasnitskaya St., 46, Bld. 7, Room III, Office 4) (hereinafter, the “Operator”) on the website on the Internet at: https://judobattle.com/

(hereinafter, the “Website”).

1.2. This Policy has been developed pursuant to and on the basis of para. 2 part 1 art. 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, as well as the Recommendations on the preparation of the document determining the operator’s policy on the processing of personal data, in the manner established by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.

1.3. In compliance with the requirements of part 2 art. 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, the Policy is published for free access on the Operator’s Website at: https://judobattle.com/

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1.4. The Policy applies exclusively to the Website. The Operator does not control and is not responsible for third-party websites to which the User may follow links available on the Website.

1.5. Terms contained in art. 3 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” are used in this Policy with the same meaning.

1.6. The following terms are also used in this Policy:

“Personal data” — any information relating to a directly or indirectly identified or identifiable natural person (personal data subject);

“Personal data made publicly available by the personal data subject” — personal data to which access is provided to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data made publicly available by the personal data subject in the manner provided for by this Federal Law;

“User” — any person visiting the Website and using the information, materials and services of the Website. A Website User is a personal data subject within the meaning of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”;

“Participant” — a User who is an athlete and has registered on the Website to participate in the judo tournament;

“Legal representative” — a parent, adopter or guardian of a minor Participant;

“Website Services” — interactive (dialogue) software components on the Website pages, used for integration with information systems and providing Website users with certain features for accessing information on the Website, namely: tournament registration form, feedback form, registration fee payment system, participant/representative personal account (hereinafter, the “Services”, the “Website Services”);

“Processing of personal data” — any action (operation) or set of actions (operations) performed with personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction of personal data;

“Operator” — a state body, municipal body, legal entity or natural person which, independently or together with others, organises and (or) carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data. For the purposes of this Policy, the Operator is the Charitable Foundation “Kolыbel Otechestva” (OGRN 1237700595153);

“Distribution of personal data” — actions aimed at disclosing personal data to an indefinite circle of persons;

“Provision of personal data” — actions aimed at disclosing personal data to a specific person or a specific circle of persons;

“Anonymisation of personal data” — actions as a result of which it becomes impossible, without the use of additional information, to determine the affiliation of personal data to a specific personal data subject;

“Personal data information system” — a set of personal data contained in databases and information technologies and technical means ensuring their processing;

“Cross-border transfer of personal data” — the transfer of personal data to the territory of a foreign state, to the authority of a foreign state, a foreign natural or foreign legal person;

“Biometric personal data” — information that characterises a person’s physiological and biological features, on the basis of which their identity can be established, and which is used by the operator to establish the identity of a personal data subject;

“Special categories of personal data” — personal data concerning race, nationality, political views, religious or philosophical beliefs, state of health, sex life;

“Publicly available sources of personal data” — directories, address books, electronic and other information systems into which, in cases established by law, information on a personal data subject is included with their written consent;

“Contest” — a draw, quiz, competition or other similar promotional event organised by the Operator on the Website, in which Users who are not Participants of the tournament may take part;

“Automated processing of personal data” — processing of personal data using computer technology;

“Operator’s legitimate interest” — the necessity to protect the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the personal data subject are not violated;

“Cookies” — small text files that a web server places on the User’s device to store information about their actions and preferences on the Website. Cookies are divided into the following types:

“Session cookies” — temporary files stored on the User’s device only during one session (one visit to the Website) and deleted after the browser is closed. They are necessary to ensure the proper operation of the Website during viewing (e.g., to remember the contents of a basket or login data during a single session);

“Persistent cookies” — files stored on the User’s device for a specified period indicated in the file, or until the User deletes them manually. They are used to remember the User’s preferences, their login and password (where consent exists), as well as to collect analytical information;

“Strictly necessary (technical) cookies” — files without which the functioning of the Website and its Services is technically impossible. They are activated in response to the User’s actions, such as logging in to an account or filling in forms. These files do not require the User’s consent;

“Functionality cookies” — files that allow the Website to remember choices made by the User (e.g., username, language, region) and provide enhanced, more personalised features;

“Analytics/performance cookies” — files that allow the Operator to count visits and traffic sources, and to measure and improve the performance of the Website. They help understand which pages are most popular and which are less in demand. All data collected are anonymised;

“Targeting/advertising cookies” — files used to track the User’s interests on the Website in order to display relevant advertising on this and other websites. They are also used to limit the number of ad displays and measure the effectiveness of advertising campaigns.

1.7. Rights and obligations of the Operator.

1.7.1. The Operator shall:

process personal data exclusively for the purposes specified in the Policy, in the manner established by the current legislation of the Russian Federation, and take measures necessary and sufficient to ensure the fulfilment of the obligations stipulated by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and regulatory legal acts adopted in accordance with it;

not distribute personal data without the User’s consent, unless otherwise provided by the current legislation of the Russian Federation;

process personal data in compliance with the principles and rules stipulated by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”;

organise the protection of personal data in accordance with the requirements of the legislation of the Russian Federation;

consider the User’s (their legal representative’s) requests regarding the processing of personal data and provide reasoned responses;

provide the User (their legal representative) with the possibility of free access to their personal data;

take measures to clarify, block, destroy the User’s personal data in cases established by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.

1.7.2. The Operator has the right to:

independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations stipulated by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and regulatory legal acts adopted in accordance with it, unless otherwise provided by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” or other federal laws;

entrust the processing of personal data to another person with the User’s consent, unless otherwise provided by federal law, on the basis of a contract concluded with such person, including a state or municipal contract, or by adopting an appropriate act by a state or municipal authority (for example, to an online payment operator, hosting provider);

in the event of the User’s withdrawal of consent to the processing of personal data, continue processing without the User’s consent if grounds specified in Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” exist (for example, to fulfil statutory obligations);

receive from the User accurate information and/or documents containing the User’s personal data for the purposes of processing specified in clause 2.2 of the Policy;

require the User to timely clarify the personal data provided.

1.8. Rights and obligations of the User.

1.8.1. The User shall:

ensure the accuracy of personal data provided to the Operator and necessary for the processing purposes specified in clause 2.2 of the Policy;

provide the Operator, where necessary, with information to clarify (update, modify) the personal data provided.

1.8.2. The User has the right to:

receive full information regarding the processing of their personal data by the Operator, except in cases provided for by the legislation of the Russian Federation;

request clarification of their personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing;

demand that the Operator clarify, block or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing;

withdraw consent to the processing of personal data;

take measures provided by law to protect their rights;

appeal to the authorised body for the protection of the rights of personal data subjects or in court against unlawful actions or omissions of the Operator in processing their personal data;

give prior consent to the processing of personal data for the purposes of receiving advertising and newsletters.

The Operator and Users also have other rights and bear other obligations as provided for by the legislation of the Russian Federation.

1.9. Principles of personal data processing

Processing of personal data by the Operator is carried out on the basis of the following principles:

lawfulness and fairness;

limitation of personal data processing to the achievement of specific, pre-determined and lawful purposes;

inadmissibility of processing personal data incompatible with the purposes of personal data collection;

inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

processing only those personal data that meet the purposes of their processing;

correspondence of the content and scope of the processed personal data to the stated purposes of processing;

inadmissibility of processing excessive personal data in relation to the stated purposes of their processing;

ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;

destruction or anonymisation of personal data upon achievement of the purposes of their processing or in the event of loss of the necessity to achieve these purposes, unless otherwise provided by federal law.

2. PURPOSES OF PERSONAL DATA PROCESSING

2.1. The processing of personal data is limited to the achievement of specific, pre-determined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted. The personal data processed shall not be excessive in relation to the stated purposes of their processing. Only personal data that meet the purposes of their processing are subject to processing.

2.2. The Operator processes the User’s personal data for the following purposes:

2.2.1. Registration of a Participant for the tournament, formation of participant lists, drawing of lots, formation of the competition bracket.

2.2.2. Identification of the User registered on the Website.

2.2.3. Informing about the operation of the Website (Services), monitoring and improving the quality of the Services.

2.2.4. Providing the User with access to personalised resources of the Website (Personal Account).

2.2.5. Establishing feedback with the User, including sending notifications and requests related to the use of the Website, the provision of services, the performance of works, processing the User’s enquiries and applications.

2.2.6. Determining the User’s location to ensure security and prevent fraud using the User’s personal data on the Website.

2.2.7. Creating an account, if the User has consented to the creation of an account.

2.2.8. Providing the User with effective customer and technical support for issues related to the use of the Website.

2.2.9. Processing and confirming payment of the registration fee.

2.2.10. Subscription to a newsletter about the tournament and other events of the Operator.

2.2.11. Sending advertising and informational materials to the User with their prior consent.

2.2.12. Publication of tournament results, including the Participant’s surname, name, weight category, sports organisation and place achieved, on the Website and official resources of sports federations.

2.2.13. Formation and transmission of reporting documentation to the relevant sports federations (the Russian Judo Federation, regional federations) in the manner provided for by legislation on physical culture and sport.

2.2.14. Ensuring security and public order during the tournament.

2.2.15. Considering appeals, complaints and applications.

2.2.16. Based on the User’s consent: subscription to a newsletter about the tournament and other events of the Operator; use of the Participant’s photographs for publication in event reports, on the Website and in the Operator’s social networks.

2.2.17. Based on the Operator’s legitimate interests: provision of customer and technical support; analysis of Users’ behaviour on the Website to improve its operation and the quality of the Services; protection of the Operator’s legitimate rights and interests, including in court.

2.2.18. For the fulfilment of statutory obligations: consideration of appeals, complaints and applications in the manner established by law; data retention in accordance with archival legislation.

2.2.19. Payment of prize money to the tournament winners and medallists, as well as calculation and withholding of taxes related to such payment, in accordance with the tax legislation of the Russian Federation.

2.2.20. Organisation and conduct of prize draws, contests, quizzes and other promotional events among Website users, including registration of participants, determination of winners, awarding of prizes and fulfilment of related tax obligations.

3. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

3.1. The legal grounds for the Operator’s processing of personal data are:

the Constitution of the Russian Federation;

the Tax Code of the Russian Federation;

the Civil Code of the Russian Federation;

Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”;

Federal Law No. 149-FZ of 27.07.2006 “On Information, Information Technologies and Information Protection”;

Federal Law No. 329-FZ of 04.12.2007 “On Physical Culture and Sports in the Russian Federation”;

Federal Law No. 294-FZ of 26.12.2008 “On the Protection of the Rights of Legal Entities and Individual Entrepreneurs in the Exercise of State Control (Supervision) and Municipal Control”;

Presidential Decree No. 188 of 06.03.1997 “On Approval of the List of Confidential Information”;

Resolution of the Government of the Russian Federation No. 1119 of 01.11.2012 “On Approval of the Requirements for the Protection of Personal Data during their Processing in Personal Data Information Systems”;

Order of the FSTEC of Russia No. 21 of 18.02.2013 “On Approval of the Composition and Content of Organisational and Technical Measures to Ensure the Security of Personal Data during their Processing in Personal Data Information Systems”;

Order of Roskomnadzor No. 18 of 24.02.2021 “On Approval of the Requirements for the Content of Consent to the Processing of Personal Data made publicly available by the personal data subject”;

Charter and regulations for the conduct of competitions of the all-Russian and relevant regional sports federations for judo;

Consent to the processing of personal data obtained from the User or their legal representative on the Website;

The tournament participation agreement concluded between the Operator and the Participant (their legal representative).

4. SCOPE AND CATEGORIES OF PERSONAL DATA PROCESSED, CATEGORIES OF PERSONAL DATA SUBJECTS

4.1. The Operator may process personal data of the following categories of Users: visitors to the Operator’s Website, tournament Participants, legal representatives of minor Participants, coaches, representatives of sports organisations.

4.2. The personal data processed by the Operator include:

For tournament Participants:

Surname, first name, patronymic;

Date and place of birth;

Sex;

Citizenship;

Identity document details (series, number, by whom and when issued);

E-mail address;

Mobile phone number;

Photograph (for pass, accreditation, publication on the Website);

Sports qualification (category, title, kyu/dan);

Weight category;

Name of sports school/club/regional federation;

Coach’s full name;

Tournament performance results;

Data from a medical certificate permitting participation (as required by the regulations);

Insurance individual account number (SNILS) (for the formation of official reports to federations).

For legal representatives of minor Participants:

Surname, first name, patronymic;

Mobile phone number;

E-mail address;

Degree of kinship.

For all Users:

Data automatically transmitted to the Website Services in the course of their use via the software installed on the User’s device, namely: IP address, cookie data, information about the User’s browser (or other programme used to access the Services), technical characteristics of the hardware and software used by the User, date and time of access to the Services, addresses of requested pages, and the history of queries and views on the Website and its Services.

For the purpose of paying tournament prize money:

Full bank details for the transfer of funds (bank account number, bank name, bank BIC, bank correspondent account, bank TIN);

Insurance individual account number (SNILS);

Taxpayer Identification Number (INN) (if assigned);

Information on the amount of winnings and the tax withheld.

For prize draw and contest participants:

Surname, first name, patronymic; contact phone number; e-mail address; social media accounts; postal address; identity document details;

Full bank details for the transfer of funds (bank account number, bank name, bank BIC, bank correspondent account, bank TIN);

Insurance individual account number (SNILS);

Taxpayer Identification Number (INN) (if assigned);

Information on the amount of winnings and the tax withheld.

Processing of these data is mandatory to receive prize money. Failure to provide them will make it impossible to receive a cash prize.

4.3. The Operator ensures that the content and scope of the personal data processed correspond to the stated purposes of processing provided for in section 2 of the Policy.

4.4. Processing of special and biometric personal data

4.4.1. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, state of health, or sex life, in connection with the payment of prize money, participation in the tournament or other purposes specified in section 2 of this Policy, is not carried out by the Operator.

4.4.2. Processing of biometric personal data (information that characterises a person’s physiological and biological features by which their identity can be established) for the purposes of paying prize money is not carried out. Photographic images of Participants are processed exclusively for the purposes of accreditation, publication of tournament results and media coverage of the event, and are not used to establish the identity of the personal data subject.

4.4.3. Processing of personal data related to the payment of prize money (including but not limited to: bank details, INN, SNILS, data on amounts paid and taxes withheld) does not fall within special or biometric categories of personal data within the meaning of arts. 10 and 11 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, and is carried out solely to the extent necessary for the Operator to fulfil the obligations of a tax agent in accordance with the Tax Code of the Russian Federation, as well as for the proper performance of contractual obligations to the Participant.

4.4.4. An exception to clauses 4.4.1 and 4.4.2 is the processing of health data provided in the form of a medical certificate permitting participation in competitions. Such processing is carried out exclusively for the purpose of complying with the tournament regulations and ensuring the safety of Participants, on the basis of an explicitly expressed written consent of the personal data subject, executed in accordance with the requirements of part 4 art. 9 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.

4.5. Provision of personal data specified in sub-paras. 1–13 of clause 4.2 of this Policy is mandatory for concluding the participation agreement for the tournament. Failure to provide these data makes participation in the tournament impossible.

4.6. The data specified in clause 4.2 (automatically transmitted) are collected and processed automatically when visiting the Website using cookies and similar technologies. The User may disable the use of cookies in their browser settings.

4.7. COOKIE POLICY

4.7.1. The Website uses cookies and similar technologies for the purposes specified in section 2 of this Policy. Processing of data obtained through cookies is carried out in anonymised form, unless otherwise provided by this Policy.

4.7.2. Depending on their purpose and the need to obtain consent for processing, the Website uses the following types of cookies defined in clause 1.6 of this Policy:

Strictly necessary (technical) cookies;

Functionality cookies;

Analytics/performance cookies;

Targeting/advertising cookies.

4.7.3. The legal basis for the use of strictly necessary (technical) cookies is the Operator’s legitimate interest (art. 6 part 1 sub-para. 9 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”) in ensuring the technically correct and secure functioning of the Website and provision of requested services to the User. The User’s consent to the use of strictly necessary cookies is not required.

4.7.4. The legal basis for the use of other types of cookies (functionality, analytics, advertising) is the User’s consent obtained at the first visit to the Website via a pop-up (banner) in the manner provided for by arts. 9 and 10.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.

4.7.5. Consequences of absence, refusal or withdrawal of consent to cookie processing:

In the absence, refusal or withdrawal of consent to the use of cookies that are not strictly necessary, their processing will be immediately terminated.

Refusal of analytics cookies will not affect the functioning of the Website but will deprive the Operator of the ability to analyse User behaviour and improve the quality of the Services.

Refusal of functionality cookies will limit the Website’s functionality: the Website will not be able to remember the User’s preferences and settings (e.g., language, region, login data), which will need to be re-entered at each new visit.

Refusal of targeting/advertising cookies will not affect the functioning of the Website; however, advertising displayed to the User may be less related to their interests.

Refusal of any cookies is not a ground for refusal to provide the Website’s core services, except where the provision of the service is technically impossible without them (e.g., session cookies required for payment).

4.7.6. The User may withdraw their consent or change cookie settings at any time as follows:

Via browser settings. The User can configure their browser to block all or some cookies, as well as delete previously saved files. To do this, refer to the instructions for the relevant browser (usually located in “Help”, “Edit” or “Settings”).

Using special online services, for example, http://www.youronlinechoices.com/ru/

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By changing consent settings in a special interface (widget) on the Website that allows selective cookie management (if this function is provided).

4.7.7. The Operator uses both first-party cookies (set by the Website’s domain) and third-party services (e.g., Yandex.Metrica, Google Analytics, online chat systems, social plugins), which may set cookies on their own behalf. The use of cookies by third-party companies is governed by their own privacy policies, which the User can read on the relevant websites.

4.7.8. The retention period of cookies on the User’s device is determined by their type: session cookies are stored for the duration of the session; persistent cookies are stored for the period specified in the file or until manually deleted by the User.

4.8. Special conditions for processing data of prize draw and contest participants

4.8.1. This section regulates the processing of personal data of Website users (who are not tournament Participants) taking part in draws, contests, quizzes and other similar events (hereinafter, “Contests”) organised by the Operator on the Website.

4.8.2. For the purposes of participation in Contests, the Operator may process the following personal data:

Surname, first name, patronymic;

Contact phone number;

E-mail address;

Social media accounts;

Postal address (for sending prizes);

Other data necessary for a specific Contest.

4.8.3. The legal basis for processing personal data for participation in Contests is the consent of the personal data subject, expressed by conclusive actions (completing the entry form, sending a message, fulfilling the Contest conditions).

4.8.4. The purposes of processing personal data of Contest participants are:

registration of a Contest entry;

determination of Contest winners;

notification of Contest victory;

awarding of prizes to winners;

fulfilment of tax obligations related to awarding prizes;

informing about future Contests and events of the Operator (only with separate consent).

4.8.5. The Operator requests the following data from a Contest winner:

INN (if any);

SNILS;

passport details;

Full bank details for the transfer of funds (bank account number, bank name, bank BIC, bank correspondent account, bank TIN);

Insurance individual account number (SNILS);

Taxpayer Identification Number (INN) (if assigned);

Information on the amount of winnings and tax withheld.

Processing of these data is mandatory to receive a prize. Failure to provide them will make it impossible to receive a cash prize.

4.8.6. Publication of personal data of Contest winners on the Website and in the Operator’s official social media accounts for the purpose of informing the public is carried out exclusively on the basis of a separate, informed, clearly expressed and specific consent to the dissemination of personal data, obtained by the Operator from the winner in writing or in another form allowing confirmation of the fact of its receipt, in accordance with art. 10.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.

4.8.6.1. Consent to the dissemination of personal data is requested from the winner after the Contest results are summed up and is not a prerequisite for receiving a prize. The winner is entitled to refuse such consent without giving reasons, which does not deprive them of the right to receive a prize.

4.8.6.2. If consent to the dissemination of personal data is given, only the following data may be published:

Surname and first name;

Photograph (avatar) of the winner;

Name of city/region of residence;

Nickname (username) on the Website or in social networks;

Name of the category or Contest in which the victory was achieved.

4.8.6.3. The winner has the right to withdraw consent to the dissemination of personal data at any time. In the event of withdrawal, the Operator shall immediately cease dissemination and delete the winner’s personal data from publicly available sources (Website, social networks), except where there is no technical possibility of deletion (e.g., publication in print media, archived copies of web resources).

4.8.7. The retention period for personal data of Contest participants is 1 year from the end of the Contest, except for winners’ data, which are retained for 5 years in accordance with the requirements of the tax legislation of the Russian Federation.

4.8.8. Contest participants have the right to withdraw consent to the processing of personal data at any time by sending a corresponding notice to the Operator at the contacts specified in section 9 of this Policy. In the event of withdrawal, the Operator ceases processing and destroys the data, except where processing must be continued in accordance with the requirements of the legislation of the Russian Federation.

5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING

5.1. The Operator processes personal data in accordance with the requirements of the legislation of the Russian Federation as follows:

non-automated processing of personal data;

automated processing of personal data with or without the transfer of received information via information and telecommunication networks;

mixed processing of personal data.

5.2. The list of actions performed by the Operator with the User’s personal data for the purposes stipulated in clause 2.2 of the Policy: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction.

5.3. Processing of personal data is carried out by the Operator on the basis of the User’s consent (hereinafter, the “Consent”), obtained in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, except in cases established by the legislation of the Russian Federation when personal data may be processed without such Consent (for example, for the performance of a contract to which the personal data subject is a party, or for the fulfilment of statutory obligations imposed on the operator).

5.4. In the case of processing personal data of a minor Participant under the age of 14, Consent to the processing of their personal data is given by their legal representative. For minors aged 14 to 18, Consent is given independently, with the informed consent of a legal representative.

5.5. The User takes the decision to provide their personal data and gives Consent freely, of their own will and in their own interest.

5.6. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract with the User or by current legislation. Grounds for ceasing the processing of personal data may include achievement of the purposes of personal data processing or the loss of necessity for achieving these purposes, expiry of the Consent or withdrawal of the Consent by the User, as well as the identification of unlawful processing of personal data.

5.7. Consent may be withdrawn as follows: by sending the Operator a written statement (demand) to the address specified in clause 9.3 of this Policy, or by e-mail. Withdrawal of consent to the processing of personal data entails deletion of the User’s account on the Website and destruction of records containing their personal data, except where the Operator is entitled to continue processing without the User’s consent on the grounds provided by law.

5.8. The Operator disseminates personal data permitted by the User for dissemination (surname, name, performance results, sports organisation), i.e., performs actions aimed at their disclosure to an indefinite circle of persons (publication on the Website, in social networks, transfer to sports federations for publication of official results), subject to the requirements, prohibitions and conditions established by part 9 art. 9 and art. 10.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”. The Operator undertakes to provide the personal data subject with information on which of their data and to whom were transferred for dissemination within 3 (three) working days from receipt of the relevant request. Disclosure to third parties and dissemination of other personal data without the User’s consent are not permitted unless otherwise provided by federal law. Consent to the processing of personal data permitted by the User for dissemination is executed separately from other consents of the User to the processing of their personal data, taking into account the Requirements for the content of consent to the processing of personal data made publicly available by the personal data subject, approved by Roskomnadzor Order No. 18 of 24.02.2021.

5.9. In processing personal data, the Operator takes or ensures the taking of necessary legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data.

5.10. Personal data are stored in a form that allows identification of the User for no longer than required by the purposes of personal data processing, except where the personal data retention period is established by federal law, by contract to which the User is a party, beneficiary or guarantor.

Other storage conditions: Personal data contained in documents related to the organisation and conduct of the tournament (applications, participant lists, competition protocols) are stored for the periods established by the legislation of the Russian Federation on archives and on physical culture and sport (not less than 5 years). Data processed on the basis of consent are stored until the moment such consent is withdrawn.

5.11. In processing personal data, the Operator undertakes to observe the confidentiality of personal data.

5.12. Cross-border transfer of personal data by the Operator is not carried out, except in cases expressly provided for by the legislation of the Russian Federation. Cross-border transfer of personal data related to the payment of prize money (including financial and tax data) is not carried out under any circumstances.

5.13. In the event of unlawful or accidental transfer (provision, dissemination, access) of personal data, the Operator shall inform the User thereof within 72 (seventy-two) hours from the moment the incident is detected.

5.14. The Operator, together with the User, shall take all necessary measures to prevent losses or other negative consequences caused by the unlawful or accidental transfer (provision, dissemination, access) of the User’s personal data.

5.15. Personal data related to the payment of prize money and tax calculation (including bank details, data on amounts paid and taxes withheld) are stored for the periods established by the tax and archival legislation of the Russian Federation (not less than 6 years).

5.16. The Operator does not make decisions based solely on automated processing of personal data that give rise to legal consequences for the personal data subject or otherwise affect their rights and legitimate interests.

6. BLOCKING, CLARIFICATION AND DESTRUCTION OF PERSONAL DATA. RESPONSES TO USERS’ REQUESTS FOR ACCESS TO PERSONAL DATA

6.1. If unlawful processing of personal data is detected upon the User’s (their representative’s) application or at the request of the User (their representative) or the authorised body for the protection of the rights of personal data subjects, the Operator shall block the unlawfully processed personal data relating to the relevant User, or ensure their blocking from the moment of such application or receipt of the request for the period of verification. If inaccurate personal data are identified upon the User’s or their representative’s application or request, or at the request of the authorised body for the protection of the rights of personal data subjects, the Operator shall block the personal data relating to that User, or ensure their blocking from the moment of such application or receipt of the request for the period of verification, if blocking the personal data does not violate the rights and legitimate interests of the User or third parties.

6.2. If the inaccuracy of personal data is confirmed, the Operator, on the basis of information provided by the User (their representative) or the authorised body for the protection of the rights of personal data subjects, or other necessary documents, shall clarify the personal data or ensure their clarification within seven working days from the date such information is provided.

6.3. If unlawful processing of personal data is revealed, the Operator, within no more than three working days from the date of such revelation, shall cease the unlawful processing of personal data or ensure its cessation, and if it is impossible to ensure the lawfulness of processing, within no more than ten working days from the date of revelation of unlawful processing shall destroy such personal data or ensure their destruction.

6.4. Upon achievement of the purpose of personal data processing, the Operator shall destroy the personal data or ensure their destruction within no more than thirty days from the date of achievement of the processing purpose, unless otherwise provided by a contract to which the User is a party, beneficiary or guarantor, or another agreement between the Operator and the User, or where the Operator is entitled to process personal data without the User’s consent on the grounds provided by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” or other federal laws.

6.5. In the event of the User’s withdrawal of consent to the processing of their personal data and where the retention of personal data is no longer required for the purposes of processing, the Operator shall destroy the personal data or ensure their destruction within no more than thirty days from the date of receipt of such withdrawal, unless otherwise provided by a contract to which the User is a party, beneficiary or guarantor, or another agreement between the Operator and the User, or where the Operator is entitled to process personal data without the User’s consent on the grounds provided by Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” or other federal laws.

6.6. Within no more than seven working days from the date the User (their representative) provides information confirming that such personal data were unlawfully obtained or are not necessary for the stated purpose of processing, the Operator shall destroy such personal data.

6.7. Processed personal data are subject to destruction upon loss of necessity to achieve the purposes of processing, unless otherwise provided by federal law.

6.8. The Operator responds to the User’s (their representative’s) requests and enquiries regarding the processing of their personal data as follows: the Operator considers any User request related to the processing of their personal data within no more than 10 (ten) days from the date of its receipt. The response is sent to the User in writing to the address indicated by them or in the form of an electronic document signed with a qualified electronic signature, unless otherwise specified in the request. The request must contain information confirming the User’s involvement in relations with the Operator (contract number, date of registration on the Website, e-mail address, etc.), or information otherwise confirming the fact of personal data processing by the Operator.

7. LIABILITY OF THE PARTIES

7.1. The Operator is liable for violation of the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” in accordance with the legislation of the Russian Federation.

7.2. The User has the right to demand compensation for losses and (or) compensation for non-pecuniary damage in court.

Non-pecuniary damage caused to the User as a result of violation of their rights, violation of the rules for processing personal data, as well as the requirements for the protection of personal data established in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, as well as the provisions of the Policy, is subject to compensation in accordance with the legislation of the Russian Federation. Compensation for non-pecuniary damage is provided regardless of compensation for pecuniary damage and losses incurred by the User.

8. DISPUTE RESOLUTION

8.1. In the event of disputes and/or disagreements arising from relations between the User and the Operator, such issues are resolved in accordance with the current legislation of the Russian Federation.

8.2. The Policy and relations between the User and the Operator are governed by the current legislation of the Russian Federation.

9. FINAL PROVISIONS

9.1. The Operator has the right to amend the Policy without the User’s consent.

9.2. The new version of the Policy comes into force from the moment of its placement on the Website, unless otherwise provided by the new version of the Policy. The new version of the Policy applies to relations arising after it enters into force.

9.3. All suggestions or questions regarding the Policy, all questions related to the processing of personal data, as well as for withdrawal of consent to processing, should be communicated by e-mail: info@fko.charity

, or by post: 101000, Moscow, Myasnitskaya St., 46, Bld. 7.