Конфиденциальность

1. **General Provisions**

This personal data processing policy is compiled in accordance with the requirements of the Law of Ukraine "On Personal Data Protection" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data, carried out by PhotoHunter.PRO (hereinafter referred to as the Operator).

1.1. The Operator considers the protection of human and civil rights and freedoms when processing personal data, including the protection of privacy, personal and family secrets, as the most important goal and condition of its activities.

1.2. This policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can obtain about visitors to the website https://photohunter.pro.

2. **Basic Concepts Used in the Policy**

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website – a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://photohunter.pro.

2.4. Information system of personal data – a set of personal data contained in databases, and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data – actions that result in the impossibility of determining the belonging of personal data to a specific User or other subject of personal data without the use of additional information.

2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – a state body, municipal body, legal or physical person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://photohunter.pro.

2.9. Personal data permitted by the subject of personal data for distribution – personal data, access of an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for distribution).

2.10. User – any visitor to the website https://photohunter.pro.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publishing personal data in the media, posting in information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data – any actions resulting in the irrevocable destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and (or) the destruction of material carriers of personal data.

3. **Basic Rights and Obligations of the Operator**

3.1. The Operator has the right to:
– receive from the subject of personal data reliable information and/or documents containing personal data;
– in case of withdrawal by the subject of personal data of consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other laws.

3.2. The Operator is obliged to:
– provide the subject of personal data, upon his request, with information regarding the processing of his personal data;
– organize the processing of personal data in the manner prescribed by the current legislation;
– respond to appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
– notify the authorized body for the protection of the rights of subjects of personal data upon request of this body with the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
– take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions regarding personal data;
– stop the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and in cases provided by the Personal Data Law;
– perform other duties provided by the Personal Data Law.

4. **Basic Rights and Obligations of Subjects of Personal Data**

4.1. Subjects of personal data have the right to:
– receive information regarding the processing of his personal data, except in cases provided by law. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
– demand from the operator the clarification of his personal data, their blocking, or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
– to condition prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
– withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or inaction of the Operator in the processing of his personal data;
– exercise other rights provided by law.

4.2. Subjects of personal data are obliged to:
– provide the Operator with reliable data about themselves;
– inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the law.

5. **The Operator May Process the Following Personal Data of the User**

5.1. Last name, first name, middle name.

5.2. Email address.

5.3. Phone numbers.

5.4. Photographs.

5.5. Also, the site collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrika and Google Analytics and others).

5.6. The above data is hereinafter referred to as Personal Data in the text of the Policy.

5.7. The processing of special categories of personal data related to racial, national origin, political views, religious or philosophical beliefs, intimate life by the Operator is not carried out.

5.8.1. The User gives consent to the processing of personal data permitted for distribution directly to the Operator.

5.8.2. The Operator is obliged to publish information on the conditions of processing, on the presence of prohibitions and conditions on processing personal data permitted for distribution to an unlimited number of persons within three working days from the moment of receiving the specified consent of the User.

5.8.3. The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This request must include the last name, first name, middle name (if any), contact information (phone number, email address, or postal address) of the subject of personal data, as well as a list of personal data, the processing of which must be terminated. The specified personal data can be processed only by the Operator to whom it is sent.

5.8.4. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. **Principles of Personal Data Processing**

6.1. The processing of personal data is carried out on a lawful and fair basis.

6.2. The processing of personal data is limited to achieving specific, pre-determined, and lawful goals. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.

6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

6.4. Only personal data that meets the purposes of their processing is subject to processing.

6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance to the purposes of personal data processing are ensured.

 The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

6.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of personal data processing require, unless the period for storing personal data is established by federal law, a contract, a party to which, the beneficiary, or guarantor of which is the subject of personal data. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of the loss of the necessity to achieve these purposes unless otherwise provided by law.

7. **Purposes of Personal Data Processing**

7.1. The purpose of processing the User's personal data: providing the User with access to services, information, and/or materials contained on the website https://photohunter.pro.

7.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending an email to the Operator at admin@photohunter.pro with the note "Refusal of notifications about new products and services and special offers".

7.3. Anonymized User data collected using internet statistics services is used to collect information about the actions of Users on the site, improve the quality of the site, and its content.

8. **Legal Grounds for Personal Data Processing**

8.1. The legal grounds for the processing of personal data by the Operator are:
– The Law of Ukraine "On Personal Data Protection";
– laws, other regulatory legal acts in the field of personal data protection;
– consents of Users to the processing of their personal data, to the processing of personal data permitted for distribution.

8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User independently through special forms located on the website https://photohunter.pro or sent to the Operator via email. By filling out the relevant forms and/or sending his personal data to the Operator, the User expresses his consent to this Policy.

8.3. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (enabled saving of cookies and use of JavaScript technology).

8.4. The subject of personal data independently decides to provide his personal data and gives consent freely, by his will, and in his interest.

9. **Conditions for Personal Data Processing**

9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of Ukraine or a law, for the exercise of the functions, powers, and duties imposed by the legislation of Ukraine on the operator.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of Ukraine.

9.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.

9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals provided that this does not violate the rights and freedoms of the subject of personal data.

9.6. The processing of personal data is carried out, access to which is provided by an unlimited number of persons by the subject of personal data or at his request (hereinafter - publicly available personal data).

9.7. The processing of personal data subject to publication or mandatory disclosure in accordance with the law is carried out.

10. **Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing**

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's email address admin@photohunter.pro marked "Updating personal data".

10.4. The processing period for personal data is determined by achieving the purposes for which the personal data was collected unless another period is provided by the contract or current legislation. The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address admin@photohunter.pro marked "Withdrawal of consent to the processing of personal data".

10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or User is obliged to independently familiarize themselves in a timely manner with these documents. The Operator is not responsible for the actions of third parties, including those specified in this paragraph of service providers.

10.6. Restrictions established by the subject of personal data on the transfer (except access provision), as well as on the processing or conditions of processing (except access provision) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of Ukraine.

10.7. The Operator ensures the confidentiality of personal data during its processing.

10.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than the purposes of personal data processing require unless the period for storing personal data is established by federal law, a contract, a party to which, the beneficiary, or guarantor of which is the subject of personal data.

10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.

11. **List of Actions Performed by the Operator with Received Personal Data**

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

11.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunications networks or without such.

12. **Cross-border Transfer of Personal Data**

12.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer of personal data is supposed to be carried out provides reliable protection of the rights of subjects of personal data.

12.2. The cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements can be carried out only if there is written consent from the subject of personal data to the cross-border transfer of his personal data and/or the execution of a contract to which the subject of personal data is a party.

13. **Confidentiality of Personal Data**

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data unless otherwise provided by law.

14. **Final Provisions**

14.1. The User can obtain any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email admin@photohunter.pro.

14.2. This document will reflect any changes in the personal data processing policy by the Operator. The Policy is valid indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://photohunter.pro.

 

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