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/.
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 and anonymised 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;
- 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 anonymised 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 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;
- responding to user enquiries sent by email;
- complying with the requirements of the legislation of the Russian Federation.
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 user’s consent – with respect to the use of cookies and the Yandex Metrica web analytics service;
- the necessity of processing technical data to ensure the operation of the website;
- the legitimate interests of the Operator relating to the functioning, security, and development of the website, provided that this does not infringe the rights and freedoms of the user;
- the necessity of considering a user’s enquiry, where the user has sent a message to the Operator on their own initiative;
- compliance with the requirements of 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 anonymised 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;
- ООО «Яндекс» – in connection with the use of the Yandex Metrica service;
- 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.
The Operator does not sell users’ personal data and does not provide them to third parties for independent advertising use.
8. Storage of Personal Data
Personal data are stored no longer than is necessary for the purposes of their processing.
Technical data collected by means of Yandex Metrica are stored in accordance with the settings of the service and the terms of its use.
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;
- anonymisation;
- 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.
11. Withdrawal of Consent to the Processing of Personal Data
The user has the right at any time to withdraw their consent to the processing of personal data by sending the corresponding notification to the Operator at:
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.