The present Personal Data Processing and Protection Policy (hereinafter referred to as the Policy) of the Private Institution of Culture “Museum ‘Victoria — the Art of being Contemporary’” (hereinafter, the Institution) has been designed to provide a detailed description of our approach to collecting and processing personal data while using the https://v-a-c.org website (hereinafter, the Website).
While using the Website, the Institution may carry out collection and processing of certain personal data. The Policy provides a description of whose data we process, which data we process, with which purpose the processing is carried out, as well as other information on processing and protection of personal data.
The Institution does not control and is not liable for the third-party websites/services that the User may go to using links available at the Website, including the User’s data processed by third parties.
The Institution acts as personal data controller according to the definition of this term envisaged by the Federal Law No. 152-FZ dated 27.07.2006 ‘On personal data’ and other normative legal acts of the Russian Federation on personal data.
The Policy has been adopted to comply with the legislation of the Russian Federation on personal data processing and protection, ensure that the personal data subjects rights and freedoms are respected, ensure that personal data confidentiality is respected, as well as ensure that data processing is secure and that an unlimited number of people have access to the Policy.
Using the Website shall mean the User’s consent to the present Policy and the personal data processing procedure stipulated in it; in the event that the User disagrees with the terms, the User must refrain from using the Website.
Terms and Definitions
The present Policy uses the main terms and definitions in the following sense:
Institution means Private Institution of Culture “Museum ‘Victoria — the Art of Being Contemporary’” (Taxpayer Identification Number (INN): 7704457565, Main State Registration Number (OGRN): 1187700010871), registered address: 15 Bolotnaya Embankment, Yakimanka Territorial District, Moscow, 119072.
User means any individual, who is an Internet user and uses the Website in his/her own interest, as well as any individual in whose interest the user acts.
Website means the Institution’s website on the Internet information and telecommunications network at the following domain address: v-a-c.org.
Personal data mean any information relating directly or indirectly to a identified or identifiable individual (personal data subject).
Automated personal data processing means computer-assisted personal data processing.
Biometric personal data mean the information on a person’s physiological and biological characteristics that can be used to establish the person’s identity and which are used by the personal data controller to establish the subject’s identity.
Blocking personal data means a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).
Personal data information system means a set of personal data contained in databases and information technologies and technical means that ensure their processing.
Non-automated personal data processing means any operations with personal data provided that use, clarification, distribution, and destruction of personal data is carried out with the direct involvement of the individual.
Depersonalisation of personal data means actions that make it impossible to determine whether personal data belongs to a specific individual without using additional information.
Personal data processing means any action or operation or a set of actions or operations that are carried out with the usage of means of automation or without the usage of such means with personal data, including collection, recording, systematisation, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, and destruction of personal data.
Personal data that the personal data subject consents to distribute mean personal data that the personal data subject provides access to for an unlimited number of people by way of consenting to processing the personal data that the personal data subject consents to distribute.
Cross-border personal data transfer means personal data transfer to the territory of a foreign country, to the authorities of a foreign country, a foreign individual or a foreign legal entity.
Destruction of personal data means actions that make it impossible to restore the personal data content in information systems and/or that lead to the destruction of physical carriers of personal data.
Personal Data Subject Categories
Through the Website, the Institution carries out collection and processing of the personal data of the following categories of Users:
Website Visitors, meaning individuals who gain access to our Website;
Subscribers, meaning individuals who gave their consent to reсeiving our newsletters and information letters, invitations to events and other materials;
Applicants, meaning individuals who submitted their applications to us through an application form or via email. Applications may mean applications to participate in theatrical and entertainment events, cultural and learning events, or show and entertainment events held by the Institution; applications by candidates seeking to fill vacant positions at the Institution, as well as other categories of User applications.
Type of Personal Data Processed by the Institution
The Institution carries out processing of the following personal data of Website Visitors:
- IP address;
- information on the User’s device, operating system, and browser;
- Website pages visited by the User;
- day and time of the Website visit;
- information collected with the help of cookies.
Please note that the Institution does not use the aforementioned data to establish the Visitor’s identity (for example, the name). These data are processed for the purpose of administering the Website and improving its functioning.
The Institution carries out processing of the following personal data of Subscribers:
- contact information;
- preferences, meaning categories of information relating to which the User would like to receive materials.
The Institution carries out processing of the aforementioned personal data for sending out newsletters and information letters, as well as other materials.
The Institution carries out processing of the aforementioned personal data with the User’s consent. You may withdraw your consent at any moment and unsubscribe from the materials by using the special option contained in every newsletter.
The Institution carries out processing of the following personal data of Applicants:
- name, surname, patronym;
- contact information;
- any other information pertaining to the application.
The Institution uses the aforementioned data solely to ensure the User’s participation in theatrical and entertainment events, cultural and learning events, or show and entertainment events held by the Institution, to prepare the response to the applications of candidates seeking to fill vacant positions, as well as for other purposes the application is sent for. The Institution carries out processing of the
Personal Data Processing Methods
The Institution carries out automated and non-automated personal data processing (mixed processing).
While processing personal data, the Institution carries out the following actions or operations with the personal data: collection, recording, systematisation, accumulation, storage, clarification (update, modification), extraction, use, transfer (provision, access), depersonalisation, blocking, deletion, or destruction of personal data.
The amount and categories of processed personal data are determined by the Institution in accordance with the purposes of personal data processing and also depend on the personal data subject category. The Institution processes personal data based on the data minimisation principle pertaining to the stated purpose of processing. The maximum amounts of processed personal data are specified herein.
The Institution ensures that Users’ personal data confidentiality is respected and does not disclose them to third parties without the Users’ prior consent or other legal grounds.
The Institution ensures the personal data confidentiality, including by way of impementing legal, organisational, and technical measures of personal data protection from unsanctioned or unauthorised access, destruction, modification, restriction, copying, transfer, distribution, and other illegal actions with regard to personal data.
The Institution does not distribute personal data specified herein, unless otherwise provided by the present Policy. If necessary, the Institution asks the User for special consent to distribute.
Personal Data Processing Procedure and Conditions
The Institution does not process biometric personal data.
The Institution does not carry out cross-border personal data transfer. However, while the personal data subject visits the Website, his/her cookies will be used by the web analytics services, including ones developed by foreign companies. The information collected with the help of the cookies will be stored at the aforementioned services’ own servers. The description of the cookies used by web analytics services is provided in Appendix No. 1 hereto.
The Institution carries out the collection and processing of solely the information that is necessary for execution of the agreements with the User, unless the law requires mandatory reception and storage of certain information. The information is stored no longer than it is required by the purposes of the processing unless the storing period of such infomation is determined by the law of the Russian Federation.
The Institution does not verify personal data provided by the User. The Institution acts on the assumption that the User provides reliable and sufficient personal data and keeps the personal data up-to-date.
All the information about Users collected, stored and processed by the Institution is considered restricted access information, unless otherwise provided by the legislation of the Russian Federation or the present Policy.
The Institution takes all reasonable measures to protect the information about Users from destruction, corruption, or disclosure.
The Institution ensures the confidentiality of the relevant information within the limits and under the conditions established by the current legislation of the Russian Federation and the present Policy.
The Institution complies with the requirements of the legislation with respect to the localisation of storage and certain types of personal data processing, which means that recording, systematisation, accumulation, storage, clarification (update, modification) and extraction of the User’s personal data are carried out using databases located on the territory of the Russian Federation.
Period of Processing Users’ Personal Data. Destruction of Personal Data upon Expiration of the Processing Period
The period of processing Users’ personal data cannot exceed the period established by:
- the legislation of the Russian Federation;
- personal data subject, established either in his/her consent to personal data processing or in the application for withdrawal of consent to personal data processing.
In addition, under all circumstances, the processing of personal data cannot be longer than it is required by the personal data processing purposes. After the time limit for personal data processing is reached, the Institution will cease the processing of personal data. In addition, the processing of personal data is ceased by the Institution in the event of:
- amendment or abrogation of the normative legal acts setting legal grounds for personal data processing;
- detection of unlawful personal data processing carried out by the Institution;
- personal data subject’s withdrawal of consent to the processing of personal data in the event that the processing of such personal data is permitted only with the consent of the personal data subject according to the legislation.
Please note that in some instances the Institution may continue processing the User’s personal data after the User has withdrawn his/her consent if such processing is necessary to comply with our obligations under the applicable legislation or if such processing is required for the exercise of the rights and legitimate interests of the Institution.
After the time limit for personal data processing stipulated in the current section of the Policy is reached, the Institution will destroy the personal data unless otherwise stipulated either by the User’s consent to personal data processing or by the agreement between the Institution and the personal data subject.
Access to User Information
In addition to the Institution, the following parties have access to information about Users, subject to the requirements of the laws of the Russian Federation:
- individuals, whose rights and responsibilities associated with the access to the relevant information are established by the Federal Laws of the Russian Federation;
- partners of the Institution in relation to joint partner projects within the limits and on the terms established by the relevant documents defining their use, subject to their maintaining the confidentiality of information about Users;
- individuals and organisations that provide technical support of the Website of the Institution to the extent necessary for the implementation of such technical support, subject to their maintaining the confidentiality of information about Users.
Access to Third-Party Services and Internet Resources
User’s access to the Website may cause access to third-party services and Internet resources and the download of programming code and/or graphic objects from them (including those not visible when displaying Internet pages by the browser) used for advertising purposes and for collecting statistics.
Owners of Internet resources have the technical capacity to collect information about Users and independently determine the conditions for its use.
By configuring the software, the User has the ability to block requests for graphic images placed on third-party servers, but this may lead to loss of readability and errors when displaying resources.
While accessing webpages of third-party services and Internet resources through the Website pages, the User independently determines the limits of use of information about the User within the conditions and rules determined by the owners of such services and Internet resources. In addition, the latter have the technical capacity to access information stored on the browser side and are responsible for respecting the rights of users in connection with its use.
The User has the right to obtain the information on the processing of his/her personal data by the Institution unless otherwise provided by law.
The User has the right to demand that the Institution specify his/her personal data, its blocking or destruction in the event that personal data are inaccurate, outdated, incomplete, illegally obtained or not necessary for the stated purpose of personal data processing.
The User has the right to withdraw their consent to personal data processing provided that the Institution processes personal data on the basis of the personal data subject’s consent.
The User has the right to raise an objection against the personal data processing by the Institution, including by filing a complaint to a personal data subjects rights protection body or by filing a lawsuit with a competent cour.
The Institution considers appeals related to this Policy, including queries of users in connection with the processing of their personal data.
The response period for incoming appeals is 10 (ten) business days from the moment they were received. Anonymous requests are not considered. All correspondence sent by Users and addressed to the Institution (in the form of letters or emails) is perceived by the Institution as restricted access information.
The Institution has the right to make changes to this Policy while using the same method of informing users about the changes that is used to inform interested persons about this Policy.
In matters that are not regulated by this Policy, the Institution shall be governed by the requirements of the current legislation of the Russian Federation.
Nothing in this Policy may be construed as aimed at restriction on the rights and legitimate interests of personal data subjects.
Appendix No.1 to Private Institution of Culture “Museum ‘Victoria — the Art of Being Contemporary’” Personal Data Processing and Protection Policy
Cookies are small text files sent by a web server and stored on the user’s computer with the purpose of analysing the User’s activity. Information that is collected with the help of cookies does not reveal your identity, but it can help us improve the performance of our website.
· information on the previous visits of the website;
· referral sources;
· user’s identifier;
· IP address and the location of the device from which the Website was accessed;
· date and time of each session;
· actions on the Website.
We process cookies to the extent necessary to improve operation and optimisation of our Website.
We do not share, disclose, or exchange cookie information with third parties.
In the menu of most Internet browsers you will find information on how to prevent your browser from accepting new cookies, how to enable your browser to notify you when you receive a new cookie, and how to block cookies altogether. It should be noted that if cookies are blocked, you may not be able to use certain features of our Website.
If you do not want to receive cookies, you can change your browser settings to notify you when you receive them, or you can reject them altogether. You can also delete cookies that are already stored on your device. Please note that if you do this you may not be able to access certain parts of our Website. Some of our Website’s features may not be available to you and your personal settings and preferences may not be saved.
The Institution may periodically update this Policy. If we make changes to the Policy, we publish the updated text of the Policy on our Website. Please check this Policy regularly. All changes will be effective upon publication of updated Policy, but in cases where we have already collected information about you and/or where required by law, we may take additional steps to inform you of any changes to our Policy and may seek your consent to such changes.