1. What does this document regulate?
1.1. This Policy (the “Policy”) has been drawn up in accordance with Federal Law No. 152-FZ “On personal data” dated 27 July 2006. It determines the policy of the personal data operator, (“Operator”), with regard to the processing of personal data collected using the website www.spithf.ru (the “Website”). The Policy contains information concerning Operator’s requirements for the protection of such personal data.



2. Whose data is processed and what are the types of such data?
2.1. Operator processes personal data of the following categories of data subjects whose personal data can be collected by Operator using the Website:

• unregistered users;
• registered users;
• participants of events (who are not registered users);

2.2. The processed personal data of unregistered and registered users of the Website as well as of participants of events include all information the users provide to Operator using the Website including by filling out the relevant data fields on the Website.



3. For what purposes is personal data processed?
3.1. Operator will process the personal data of unregistered users to enable them to communicate with Operator.


3.2. Operator will process the personal data of registered users for the following purposes:
1) to enable them to use the Website, which involves:

• communicating with Operator,
• providing users with reference information,
• advising users on the work we perform and services we supply as well as providing support to users,
• making the Website more user-friendly;

2) to promote Operator’s work and services by contacting users directly;
3) to participate in events, which involves:

• providing users with information on upcoming events,
• registering for an event;
• providing users with materials for the events that will be held as well as following the events that have been held.

3.3. Operator will process the personal data of participants of the events to enable them to take part in such events, which involves:

• providing the participants of events with information on the upcoming events,
• registering for an event;
• providing participants of events with materials for the events that will be held as well as following the events that have been held.

4. How is personal data processed?
4.1. Operator may process personal data by using automated tools or without using such tools by collecting, recording, systematising, accumulating, storing, adjusting (updating or changing), extracting, using, transferring (making available), blocking, deleting and destroying the personal data.
4.2. Operator may transfer personal data to third parties or instruct third parties to process personal data if this is required for the purpose of the processing of such data in accordance with this Policy as well as in the cases for which current Russian legislation on personal data provides.
4.3. Operator will process personal data for no longer than is required for the purposes of such processing unless current Russian legislation on personal data provides for other timeframes.

5. How is personal data protected?
5.1. Operator takes responsibility for protecting the personal data collected and meets the requirements for protecting it by taking a set of measures that are necessary and sufficient for ensuring the performance of the obligations set out in current Russian legislation on personal data.
5.2. However, Operator is not responsible for third parties obtaining the personal data by obtaining access to registered users’ personal accounts. The registered users of the Website must independently ensure the security of the data for accessing their personal accounts.

6. Consent to the processing of personal data and applicable clauses
6.1. A user of the Website, of his/her own free will and volition and on his/her own behalf, provides Operator with his/her personal data and, on behalf of the participants of events, the personal data of such participants.
6.2. By accepting the terms of this Policy, the user of the Website hereby confirms that the personal data he/she has provided is accurate. Operator proceeds on the basis that a user of the Website provides and updates accurate personal data.

6.3. By filling out the data fields on the Website the user of the Website accepts this Policy and grants his/her consent to the processing of his/her personal data in accordance with the procedure and on the conditions set out in this Policy.

6.4. By filling out the data fields with respect to the participants of events, the user of the Website warrants that the participants of events have granted their consent to the processing of their personal data in accordance with the procedure and on the conditions set out in this Policy. In such a case, the user of the Website also undertakes to notify such participants of events of the transfer of their personal data to Operator and warrants that notice will be given to this effect.

6.5. By accepting the terms of this Policy the user of the Website confirms that he/she knows his/her rights and obligations set out in current Russian legislation on personal data, including the right to access his/her personal data and to revoke his/her consent.

6.6. If the user of the Website does not intend to provide the personal data or does not accept this Policy, he/she must stop using the Website. In this case, Operator will not be able to ensure that the user can use the Website.

7. What other personal data can be processed?

7.1. Operator may collect information on users visiting the Website without the users providing the relevant information. Such information may be obtained by using various methods, means and online statistics and set-up tools (in particular, cookie files and services like Google Analytics and Yandex.Metrics). Operator may use such methods, means and tools to promote the work and services of Operator, to provide information about upcoming events by using target advertising as well as to make the Website more user friendly by creating profiles of registered users. Such methods, means and tools are not used for identifying unregistered users.

7.2. If the user of the Website does not agree to cookies files being stored on his/her device, he/she can independently disable this option in the browser configurations. The stored cookie files can be deleted at any time in the browser system configurations. The user of the Website can change the browser configurations to be able to accept or reject by default all cookie files or cookie files from specific websites, including the Website.

7.3. Disabling specific cookie files may prevent the use of specific sections or functions of the Website.

7.4. If the user of the Website does not agree with the Internet statistics and set-up methods, means and tools being used, he/she should stop using the Website. In this case, Operator will not be able to ensure that the user can use the Website.

8. Final provisions
8.1. This Policy is to be amended or supplemented if the corresponding changes or additions are made to current Russian legislation on personal data. The Policy may be amended at any time at the discretion of Operator. The current version of Operator’s Policy is always available for review by the public at large at its permanent address on the Website: www.spithf.ru/en/legal

8.2. All relationships involving Operator relating to the processing and protection of personal data which are not expressly reflected in this Policy will be regulated in accordance with Russian legislation on personal data.

8.3. The Policy was last updated on 11.10.2021.