Personal Data Processing Policy

This Personal Data Processing Policy defines the procedure for processing and protecting the personal data of users of the website dedicated to the work of the photographer Alexander Nagralyan and to the book “Living History”, located at: https://nagralyan.ru/.

This English text is provided for convenience only. The legally binding version of this Policy is the Russian one; in the event of any discrepancy between the English and Russian texts, the Russian version prevails.

The website does not provide for user registration, personal accounts, feedback forms, comments, or mailing lists. At the same time, when visiting the website, users’ technical data may be processed automatically, including through the Yandex Metrica web analytics service.

The current version of the Policy is permanently available on the website at: https://nagralyan.ru/privacy/

1. Operator of Personal Data

The operator of personal data is:

Anton Alexandrovich Nagralin

Email for enquiries regarding the processing of personal data: nagralyan.archive@yandex.ru

Website: https://nagralyan.ru/

Hereinafter referred to as the Operator.

2. Categories of Users Whose Data May Be Processed

The Operator may process the data of the following categories of users:

visitors to the website;
persons who contact the Operator by email on their own initiative.

3. What Data May Be Processed

When visiting the website, the following technical data may be processed automatically:

the user’s IP address;
the date and time of the website visit;
information about the browser and operating system;
the type of device;
the addresses of the pages visited;
the source of referral to the website;
information about the user’s actions on the website;
cookies and data stored in the browser’s local storage;
other technical data collected by the Yandex Metrica web analytics service.

If a user sends a message to the Operator’s email on their own initiative, the following may be processed:

the user’s email address;
a name or other information, if the user has provided it in the message;
the content of the enquiry;
technical data relating to the email correspondence.

The Operator does not request from users any special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, state of health, or intimate life, nor does it process biometric personal data for the purpose of identifying users. Should a user send such information to the Operator by email on their own initiative, it is processed only to the extent necessary to consider the enquiry, or is deleted if its processing is not required.

4. Purposes of Processing Personal Data

Users’ personal data and technical data are processed for the following purposes:

ensuring the functioning of the website and processing statistical information about visits to the website (including ensuring the correct operation of the website; analysing website traffic; improving the structure, content, and usability of the website; ensuring the security of the website; detecting and preventing technical failures and abuse);
providing responses to enquiries received by email.

5. Legal Grounds for Processing Personal Data

Personal data are processed in accordance with Federal Law No. 152-ФЗ of 27 July 2006 “On Personal Data”.

The legal grounds for processing are:

the Terms for Processing Personal Data Collected via Yandex Metrica – a contract concluded with the personal data subject (the user accepts the terms upon entering the website);
consent to the processing of personal data when responding to enquiries received by email (the user gives consent by sending an enquiry);
the exercise of the powers, duties, and functions of the Operator, in the cases established by the legislation of the Russian Federation.

6. Use of Cookies and Yandex Metrica

The website uses cookies and the Yandex Metrica web analytics service provided by ООО «Яндекс».

Yandex Metrica helps the Operator obtain statistical information about website traffic, users’ actions on the pages, the devices and browsers used, referral sources, and other technical parameters.

The Yandex Metrica service may use cookies and collect technical data, including the IP address, information about the browser, the device, the time of the visit, and the user’s actions on the website.

The user may restrict or disable the use of cookies in their browser settings. If cookies are disabled, certain features of the website or the statistical recording of visits may not work correctly.

The user may also use web analytics blocking tools provided by the browser or by third-party extensions.

7. Transfer of Data to Third Parties

The Operator does not transfer users’ personal data to third parties, except in the cases provided for by this Policy and by the legislation of the Russian Federation.

In order to ensure the operation of the website and to analyse traffic, data may be transferred to or made available to the following parties:

the hosting provider that hosts the website;
providers of technical services, where they are necessary for the administration and protection of the website.

Such parties process the data only to the extent necessary to provide the relevant services.

ООО «Яндекс» processes the technical data of website visitors not as an independent recipient but on the instructions of the Operator and on the terms of use of the Yandex Metrica service. The Operator bears responsibility to the user for the processing of these data.

The Operator does not sell users’ personal data and does not provide them to third parties for independent advertising use.

8. Periods of Processing Personal Data

Personal data are processed no longer than is necessary for the purposes of their processing, unless other periods are provided for by the legislation of the Russian Federation.

The periods for processing the technical data collected by Yandex Metrica and the storage periods for cookies are set out in the Terms for Processing Personal Data Collected via Yandex Metrica.

Data sent by a user by email are stored for the period necessary to consider the enquiry and for subsequent communication, unless a longer storage period is required in accordance with the legislation of the Russian Federation.

The user has the right to send the Operator a request for the deletion of their personal data.

9. Operations with Personal Data

The Operator may carry out the following operations with personal data:

collection;
recording;
systematisation;
accumulation;
storage;
updating (rectification);
use;
transfer in the cases provided for by this Policy;
blocking;
deletion;
destruction.

The processing of personal data may be carried out with the use of automation tools or without the use of such tools.

10. Protection of Personal Data

The Operator takes the necessary organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions.

Such measures may include:

restricting access to the administrative sections of the website;
the use of passwords and other access control means;
updating the website’s software;
the use of technical means to protect the website;
selecting reliable providers of hosting and technical services.

Consent as a legal ground applies to the enquiries that a user sends to the Operator by email on their own initiative. The user has the right at any time to withdraw that consent by sending the corresponding notification to the Operator at:

nagralyan.archive@yandex.ru

Upon receipt of the withdrawal of consent, the Operator ceases processing the user’s personal data, except in cases where further processing is permitted or required by the legislation of the Russian Federation.

The processing of technical data by means of Yandex Metrica is carried out not on the basis of consent but under a contract. The procedure for terminating such processing is set out in the Terms for Processing Personal Data Collected via Yandex Metrica.