POLICY ON THE PROCESSING OF PERSONAL DATA ON THE WEBSITE ARTCENTER.INSPIROPROJECTS.RU/ RESTAURANT OF THE FUTURE LLC
1. GENERAL PROVISIONS
1.1. This document (hereinafter – the “Policy”) defines the policy regarding the processing of personal data of users of the website of LLC “RESTAURANT OF THE FUTURE” (hereinafter – the “Operator”) on the website in the information and telecommunications network Internet at https://artcenter.inspiroprojects.com/ (specify the domain name) (hereinafter – the “Website”).
1.2. This Policy has been developed in accordance with paragraph 2, part 1, article 18.1 of the Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”, as well as the Recommendations for drafting a document defining the operator’s policy regarding the processing of personal data, in the procedure established by Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”.
1.3. Pursuant to part 2, article 18.1 of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”, this Policy is published in open access on the Operator’s Website at https://artcenter.inspiroprojects.com/.
1.4. This Privacy Policy applies only to the Website. The Operator does not control and is not responsible for third-party websites that the User may access through links available on the Website.
1.5. Terms used in article 3 of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” are used in this Policy with the same meaning.
1.6. The following terms are also used in this Policy:
  • User – any individual visiting the Website and using the information, materials, and services of the Website. The User of the Website is a subject of personal data within the meaning of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”.
  • Website Services – interactive (dialogue) software components on the Website pages, used for integration with information systems and providing Website Users with certain opportunities to access information on the Website, namely: https://artcenter.inspiroprojects.com/ (hereinafter – Services, Website Services).
1.7. Rights and Obligations of the Operator
1.7.1. The Operator shall:
  • process personal data solely for the purposes specified in this Policy, in accordance with the legislation of the Russian Federation, and take measures necessary and sufficient to fulfill the obligations provided by Federal Law No. 152-FZ “On Personal Data” and the regulations adopted under it;
  • not disclose personal data without the User’s consent, unless otherwise provided by the applicable legislation of the Russian Federation;
  • process personal data in accordance with the principles and rules established by Federal Law No. 152-FZ “On Personal Data”;
  • organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation;
  • review User requests (or their legal representatives) regarding personal data processing and provide motivated responses;
  • provide the User (or their legal representative) with free access to their personal data;
  • take measures to clarify, block, or destroy the User’s personal data in cases stipulated by Federal Law No. 152-FZ “On Personal Data”.
1.7.2. The Operator has the right to:
  • independently determine the composition and range of measures necessary and sufficient to fulfill obligations provided by Federal Law No. 152-FZ “On Personal Data” and the regulations adopted under it, unless otherwise provided by Federal Law No. 152-FZ or other federal laws;
  • delegate the processing of personal data to another person with the User’s consent, unless otherwise provided by federal law, based on a contract with this person, including a state or municipal contract, or through an act adopted by a state or municipal authority;
  • continue processing personal data without the User’s consent if the User withdraws their consent, provided that grounds exist as specified in Federal Law No. 152-FZ “On Personal Data”;
  • receive from the User accurate information and/or documents containing personal data for the purposes of processing specified in section 2.2 of this Policy;
  • require the User to timely update their personal data.
1.8. Rights and Obligations of the User
1.8.1. The User shall:
  • ensure the accuracy of personal data provided to the Operator for the purposes of processing specified in section 2.2 of this Policy;
  • provide the Operator with information necessary for clarification (updating, modification) of the personal data provided.
1.8.2. The User has the right to:
  • obtain complete information regarding the processing of their personal data by the Operator, except in cases provided by Russian law;
  • clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the declared purpose of processing;
  • withdraw consent to the processing of personal data;
  • take legally provided measures to protect their rights;
  • appeal to the authorized body for the protection of personal data subjects or in court against unlawful actions or inaction of the Operator in processing their personal data.
The Operator and Users also have other rights and obligations provided by Russian legislation.

2. PURPOSES OF PERSONAL DATA PROCESSING
2.1. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing personal data incompatible with the purposes of collection is not permitted. Processed personal data must not be excessive relative to the stated purposes of processing. Only personal data that meets the purposes of processing shall be processed.
2.2. The Operator processes the User’s personal data for the following purposes:
2.2.1. Identification of the User registered on the Website.
2.2.2. Informing about the operation of the Website (Services), monitoring and improving the quality of Services.
2.2.3. Providing the User access to personalized Website resources.
2.2.4. Establishing communication with the User, including sending notifications and requests regarding the use of the Website, provision of services, performance of works, and processing User requests and applications.
2.2.5. Determining the User’s location to ensure security and prevent fraud involving the User’s personal data on the Website.
2.2.6. Creating a User account.
2.2.7. Providing effective customer and technical support to the User in case of issues related to the use of the Website.
2.2.8. Sending advertising to the User with their prior consent.

3. LEGAL BASIS FOR PERSONAL DATA PROCESSING
3.1. Legal grounds for processing personal data by the Operator include:
  • Constitution of the Russian Federation;
  • Civil Code of the Russian Federation;
  • Federal Law No. 149-FZ of December 26, 2008 “On Information, Information Technologies, and Information Protection”;
  • Federal Law No. 294-FZ of December 26, 2008 “On Protection of the Rights of Legal Entities and Individual Entrepreneurs in the Exercise of State and Municipal Control (Supervision)”;
  • Decree of the President of the Russian Federation No. 188 of March 6, 1997 “On Approval of the List of Confidential Information”;
  • Government Decree of the Russian Federation No. 1119 of November 1, 2012 “On Approval of Requirements for Personal Data Protection During Their Processing in Personal Data Information Systems”;
  • FSTEC Order No. 21 of February 18, 2013 “On Approval of the Composition and Content of Organizational and Technical Measures to Ensure Personal Data Security in Personal Data Information Systems”;
  • User consent to personal data processing on the Website.

4. SCOPE AND CATEGORIES OF PROCESSED PERSONAL DATA, CATEGORIES OF DATA SUBJECTS
4.1. The Operator may process personal data of the following Users: visitors of the Operator’s Website.
4.2. Personal data processed by the Operator include (as applicable):
  • User’s full name;
  • Place of residence (region/city);
  • Mobile phone number;
  • Email address;
  • Data automatically transmitted to the Website Services during their use via software installed on the User’s device, including: IP address, cookie data, browser information (or other software used to access the Services), technical characteristics of hardware and software used by the User, date and time of access to the Services, requested page addresses, browsing and query history on https://artcenter.inspiroprojects.com/ and its Services.
4.3. The Operator ensures that the content and volume of processed personal data correspond to the purposes of processing specified in section 2 of this Policy.
4.4. The Operator does not process biometric personal data or special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, or intimate life.

5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING
5.1. The Operator processes personal data in accordance with Russian legislation by the following methods:
  • Non-automated processing;
  • Automated processing, with or without transmission via information and telecommunications networks;
  • Mixed processing.
5.2. The actions performed by the Operator with the User’s personal data for the purposes specified in section 2.2 of this Policy include: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction.
5.3. Processing of personal data is carried out with the User’s consent, obtained in accordance with Federal Law No. 152-FZ “On Personal Data”, except in cases established by Russian law when processing may be carried out without such consent.
5.4. The User freely provides their personal data and gives consent of their own will and in their own interest.
5.5. The processing period is determined by achieving the purposes for which the personal data was collected, unless another period is provided by a contract with the User or applicable law. Processing may cease upon achieving the purpose, withdrawal of consent, or detection of unlawful processing.
5.6. Consent may be withdrawn by sending a written notice to the Operator.
5.7. The Operator ensures that personal data permitted for disclosure by the User is shared only in accordance with Russian law and the User’s consent.
5.8. The Operator implements legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, or other unlawful actions.
5.9. Personal data is stored in a form that allows the User to be identified, no longer than required by the purpose of processing, unless a longer period is established by law or contract.
5.10–5.14. The Operator complies with all legal requirements regarding confidentiality, protection, and notifications in case of unlawful or accidental disclosure.

6. BLOCKING, CLARIFICATION, AND DESTRUCTION OF PERSONAL DATA; USER REQUESTS
6.1–6.8. The Operator blocks, clarifies, or destroys personal data upon detection of unlawful processing, User request, or achieving the purpose, and responds to all User inquiries regarding personal data processing.

7. LIABILITY OF THE PARTIES
7.1. The Operator is liable for violation of Federal Law No. 152-FZ “On Personal Data” in accordance with Russian law.
7.2. The User may seek compensation for damages and/or moral harm in court. Compensation for moral harm is independent of material damages.

8. DISPUTE RESOLUTION
8.1. Disputes arising between the User and the Operator are resolved under Russian law.
8.2. Russian law governs this Policy and relations between the User and the Operator.

9. FINAL PROVISIONS
9.1. The Operator may amend the Policy without the User’s consent.
9.2. The new version takes effect upon publication on the Website, unless otherwise provided.
9.3. All suggestions or questions regarding the Policy should be sent to artcenter@spiro.vc.