Personal Data Processing Policy

1.1. This Personal Data Processing Policy (the “Policy”) has been drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (“Law No. 152-FZ”) and other Russian laws and regulations on the processing and protection of personal data. It sets out how TV BRICS Joint Stock Company (the “Operator”) processes personal data and the measures it takes to keep that data secure.

1.3. This Policy applies to all personal data the Operator receives and processes, including the personal data of Website users. The Operator processes personal data both with and without the use of automated means.
1.4. By using the Website, users agree to this Policy and the terms for processing their personal data. Users who do not agree to the terms of this Policy must refrain from using the Website.
1.5. The Operator does not verify the accuracy of personal data provided by data subjects. It assumes that they provide accurate and sufficient personal data and keep it up to date.

2.1. The following key terms are used in this Policy:
• Personal data — any information that relates directly or indirectly to an identified or identifiable individual (the data subject).
• Operator — a state authority, municipal authority, legal entity or individual that, alone or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of processing, the personal data to be processed and the actions (operations) to be performed on it. For the purposes of this Policy, the Operator is JSC BRICS TV.
• Personal data processing — any action (operation) or set of actions (operations) performed on personal data, with or without the use of automated means, including collection, recording, organisation, accumulation, storage, rectification (updating or modification), retrieval, use, transfer (dissemination, provision or access), depersonalisation, blocking, deletion and destruction.
• Automated personal data processing — processing personal data using computer technology.
• Dissemination of personal data — actions intended to disclose personal data to an unspecified group of people.
• Provision of personal data — actions intended to make personal data available to a specific person or group of people.
• Blocking of personal data — temporarily suspending the processing of personal data, except where processing is needed to correct it.
• Destruction of personal data — actions that make it impossible to recover the content of personal data in a personal data information system and/or that destroy physical media containing personal data.
• Depersonalisation of personal data — actions that make it impossible to link personal data to a particular data subject without using additional information.
• Personal data information system — the personal data held in databases, together with the information technology and technical tools used to process it.
• User — any individual who uses the Operator’s Website.
• Cookie — a small piece of data sent by a web server and stored on a user’s device. The web client or browser sends it back to the web server each time the user tries to open a page on the relevant Website.
• Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.

3.1. TV BRICS Joint Stock Company is the Operator of personal data processed in connection with use of the Website. The Operator’s details are as follows:
Detail Value
Full company name TV BRICS Joint Stock Company
Abbreviated company name JSC BRICS TV
Company name in English TV BRICS Joint Stock Company (JSC BRICS TV)
Registered address 13 Rubtsov Lane, Basmanny Municipal District (intra-city municipality), Moscow, 105082, Russian Federation
Primary State Registration Number (OGRN) 1177746976142
Taxpayer Personal Identification Number (INN) / Tax Registration Reason Code (KPP) 7727329908 / 770101001
Telephone 8-800-333-55-88
Email address tvbrics@tvbrics.com
3.2. Data subjects may contact the Operator with any questions about the processing of their personal data by email at tvbrics@tvbrics.com or by post at: 13 Rubtsov Lane, Moscow, 105082, Russian Federation.

4.1. The Operator processes the personal data of the following categories of data subjects:
• Website users (visitors);
• people who send the Operator enquiries, questions, feedback or messages through the Website’s contact forms or using the contact details listed on the Website;
• people who subscribe to the Operator’s news and/or information mailing lists;

5.1. The Operator may process the following personal data that data subjects provide themselves when completing forms on the Website, submitting enquiries and/or otherwise communicating with the Operator:
• surname, first name and patronymic;
• email address;
• contact telephone number;
• other information that data subjects voluntarily include in their enquiries, feedback or messages.
5.2. When the Website is used, depersonalised user data may be collected and processed automatically, including through cookies and web analytics services. This may include:
• IP address;
• information from cookies;
• information about the browser or other software used to access the Website, and the technical specifications of the user’s hardware and software;
• the date and time of access to the Website, the addresses of pages requested and other similar information.
5.3. The Operator does not process special categories of personal data relating to racial or national origin, political opinions, religious or philosophical beliefs, health or intimate life, or biometric personal data, except where expressly provided for by Russian law.

6.1. The Operator processes personal data for the following purposes:
• to keep the Website running and give users access to its services and information;
• to review and respond to enquiries, questions, feedback and messages received from data subjects;
• to communicate with users, including sending notifications and requests;
• to send news and/or information mailings with the data subject’s consent;
• to improve the Website’s performance and ease of use, and to collect Website traffic statistics based on depersonalised data;
• to meet the Operator’s obligations under Russian law.

7.1. The Operator processes personal data on the following legal grounds:
• Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”;
• Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”;
• the data subject’s consent to the processing of their personal data;
• other Russian laws and regulations governing personal data processing.
7.2. The Operator processes users’ personal data on the basis of the data subject’s consent expressed through conduct indicating consent, such as completing and submitting a form on the Website or sending an enquiry. The Operator may also process personal data without the data subject’s consent in the circumstances provided for in Article 6 of Law No. 152-FZ.

8.1. The Operator processes personal data in line with the following principles:
• personal data is processed lawfully and fairly;
• processing is limited to specific, predetermined and lawful purposes; personal data must not be processed in ways that are incompatible with the purposes for which it was collected;
• databases containing personal data processed for incompatible purposes must not be combined;
• only personal data relevant to the purposes of processing may be processed;
• the content and amount of personal data processed must match the stated purposes and must not be excessive in relation to those purposes;
• personal data must be accurate, sufficient and, where necessary, up to date for the purposes of processing; the Operator takes, or ensures that others take, the necessary steps to delete or rectify incomplete or inaccurate data;
• personal data is kept in a form that allows the data subject to be identified for no longer than necessary for the purposes of processing, unless a retention period is set by law or contract.

9.1. The Operator collects, records, organises, accumulates, stores, rectifies (updates or modifies), retrieves, uses, transfers (provides or grants access to), depersonalises, blocks, deletes and destroys personal data.
9.2. Personal data of citizens of the Russian Federation is collected, recorded, organised, accumulated and rectified (updated or modified) using databases located in the Russian Federation, in accordance with Article 18(5) of Law No. 152-FZ.
9.3. Personal data is processed with the data subject’s consent, unless Russian law provides otherwise.
9.4. The Operator may transfer personal data to third parties in the following circumstances:
• the data subject has consented to the transfer;
• the transfer is provided for by Russian law and follows the prescribed procedure;
• the transfer is necessary to achieve the purposes of processing and is made to service providers engaged by the Operator, including hosting providers and providers of web analytics and mailing services, provided that they ensure the confidentiality and security of personal data when processing it.
9.5. As a general rule, the Operator does not transfer personal data across borders. If such a transfer becomes necessary, it is carried out in accordance with Article 12 of Law No. 152-FZ, including the requirement to notify the competent authority responsible for protecting data subjects’ rights in advance.
9.6. The Operator stops processing personal data and destroys it when the purposes of processing have been achieved or no longer need to be achieved; when the data subject withdraws consent to processing; when unlawful processing is identified; or when the consent or the personal data retention period expires.

10.1. The Website uses cookies and similar technologies to keep it functioning, make it easier to use and collect depersonalised Website traffic statistics.
10.2. Users can disable cookies in their browser settings at any time and delete cookies that have already been stored. Disabling cookies may make some Website features unavailable.
10.3. Third-party web analytics services that process depersonalised data about users’ activity on the Website may be used to collect and analyse Website traffic statistics.

11.1. Data subjects have the right to:
• receive information about the processing of their personal data, including confirmation that their data is being processed, the legal grounds and purposes of processing, the processing methods used, the Operator’s name and location, and the processing and retention periods, to the extent provided for in Article 14 of Law No. 152-FZ;
• request the rectification, blocking or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing;
• withdraw consent to the processing of their personal data;
• require the Operator to remedy unlawful actions involving their personal data;
• appeal against the Operator’s actions or omissions to the competent authority responsible for protecting data subjects’ rights (Roskomnadzor) or before a court;
• protect their rights and legitimate interests, including by seeking damages and/or compensation for non-material harm through the courts.
11.2. To exercise these rights, data subjects should send a request to the Operator at the email or postal address given in Section 3 of this Policy. The request must contain the information required by Article 14(3) of Law No. 152-FZ.

12.1. The Operator must:
• process personal data in accordance with Russian law;
• provide data subjects, on request, with information about the processing of their personal data, or give a reasoned refusal on lawful grounds;
• take the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions;
• rectify, block or delete personal data at the data subject’s request in the circumstances specified by law;
• stop processing and destroy personal data in the circumstances provided for by Russian law and this Policy.

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

14.1. Personal data processing and retention periods are determined by the purposes of processing and do not exceed the time needed to achieve those purposes, unless a different period is set by Russian law or contract.
14.2. Personal data processed on the basis of the data subject’s consent is kept until the purposes of processing have been achieved or the data subject withdraws their consent, unless Russian law provides otherwise.
14.3. Once the purposes of processing have been achieved, or if the data subject withdraws consent, personal data must be destroyed or depersonalised within the time limits set by Russian law, unless there are other legal grounds for continuing to process it.

15.1. This Policy is an internal document of the Operator and must be published on the Operator’s Website.
15.2. The Operator may amend this Policy. A new version takes effect when it is published on the Website, unless that version provides otherwise. The current version is always available on the Website at www.oshibok-net.ru.
15.3. This Policy and the relationship between the user and the Operator arising from its application are governed by the laws of the Russian Federation.
15.4. Any suggestions or questions concerning this Policy should be sent to: tvbrics@tvbrics.com.
15.5. This Policy takes effect upon approval and remains in force indefinitely until it is replaced by a new version.