Policy regarding the processing of personal data

1. General Provisions

This personal data processing policy is developed in accordance with the requirements of the Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the "Personal Data Law") and determines the procedure for processing personal data and measures for ensuring the security of personal data undertaken by Aurum Circle (hereinafter referred to as the "Operator").
1.1. The Operator’s primary goal and condition for carrying out its activities is to comply with the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://www.aurumcircle.it/

2.Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing equipment.
2.2. Blocking of personal data – temporary suspension of personal data processing (except when processing is necessary for the clarification of personal data).
2.3. Website – a set of graphic and informational materials, as well as software and databases that ensure their availability on the internet at the web address https://www.aurumcircle.it/.
2.4. Information system of personal data – a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Anonymization of personal data – actions that make it impossible to determine the ownership of personal data without using additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual, either independently or jointly with others, organizing and/or carrying out the processing of personal data and determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://www.aurumcircle.it/.
2.9. Personal data authorized by the subject of personal data for dissemination – personal data to which access is provided to an unlimited number of persons by the subject of personal data through consent for the processing of personal data authorized for dissemination as provided by the Personal Data Law (hereinafter referred to as "personal data authorized for dissemination").
2.10. User – any visitor to the website https://www.aurumcircle.it/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of people.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or at making personal data available to an unrestricted group of people, including the publication of personal data in the media, placement 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 government body, foreign physical person, or foreign legal entity.
2.14. Destruction of personal data – any actions that result in the permanent destruction of personal data with no possibility of recovery, and/or the destruction of physical carriers of personal data.

3.Operator's Rights and Obligations
3.1. The Operator has the right to:

• Receive reliable information and/or documents containing personal data from the subject of personal data.
• Continue processing personal data without the consent of the subject of personal data if the consent is revoked, as long as 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 the obligations stipulated by the Personal Data Law.

3.2. The Operator is obliged to:

• Provide the subject of personal data with information regarding the processing of their personal data upon request.
• Organize the processing of personal data in accordance with the current legislation of the Russian Federation.
• Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the Personal Data Law.
• Notify the authorized body for the protection of the rights of personal data subjects within 10 days of receiving a request.
• Publish or otherwise provide unlimited access to this Privacy Policy regarding personal data processing.
• Take legal, organizational, and technical measures to protect personal data from unauthorized access, destruction, alteration, blocking, copying, provision, dissemination, and other illegal actions.

4.Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

• Receive information regarding the processing of their personal data, except in cases specified by federal laws.
• Request the clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the processing purpose.
• Revoke consent for the processing of personal data.

File complaints about the unlawful actions or inactions of the Operator in processing their personal data.
4.2. Personal data subjects must:

• Provide reliable data about themselves.
• Notify the Operator about any updates to their personal data.

5.Principles of Personal Data Processing
5.1. Personal data is processed legally and fairly.
5.2. Personal data processing is limited to specific, predetermined, and lawful purposes.
5.3. Personal data should not be used for incompatible purposes.

6.Purposes of Personal Data Processing
Purpose of processing: Providing the User access to services, information, and materials on the website.
Personal data: Full name, email address, phone numbers, date and place of birth.

7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out based on the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals set by an international agreement of the Russian Federation or by law, to perform functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court decision, or the action of another body or official, which must be executed in accordance with the legislation of the Russian Federation on enforcement.
7.4. The processing of personal data is necessary to execute a contract, either as the party to the contract or as a beneficiary or guarantor of the contract, or for the conclusion of a contract at the initiative of the personal data subject or a contract in which the personal data subject is a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the realization of the legitimate rights and interests of the Operator or third parties or to achieve socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data that has been made available to an unlimited number of people by the personal data subject, or at their request (hereinafter referred to as publicly available personal data), is permitted.
7.7. The processing of personal data, which must be published or disclosed in accordance with federal law, is permitted.

8. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
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 the current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never be transferred to third parties, except as required by applicable law or if the subject of personal data has consented to the transfer for the execution of obligations under a civil law contract.
8.3. In case inaccuracies in personal data are identified, the User can update it independently by notifying the Operator at the email address info@aurumcircle.it with the subject "Personal Data Update."
8.4. The storage period for personal data is determined by the achievement of the processing purposes, unless a different period is specified by the contract or applicable law. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via email to info@aurumcircle.it with the subject "Withdrawal of Consent for Processing Personal Data."
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by these entities (Operators) according to their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third-party service providers.
8.6. The restrictions set by the subject of personal data on the transfer (except for granting access) or the processing of personal data do not apply to cases of processing personal data for state, public, or other public interests as defined by Russian Federation legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required for the processing purposes, unless the storage period is defined by federal law, contract, or other legal obligations.
8.9. The processing of personal data may cease once the processing purposes are achieved, the consent of the subject of personal data is withdrawn, or upon the request for termination of processing, or upon the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator conducts automated processing of personal data with the receipt and/or transfer of information through information and telecommunication networks or without such transmission.

10. Cross-Border Transfer of Personal Data
10.1. Before starting cross-border transfer activities, the Operator must notify the authorized body for the protection of personal data subjects’ rights about their intention to carry out cross-border data transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain the relevant information from foreign state authorities, foreign physical persons, and foreign legal entities to which the personal data will be transferred.

11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are required not to disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise specified by federal law.

12. Final Provisions
12.1. The User may receive any clarification on matters related to the processing of their personal data by contacting the Operator via email at info@aurumcircle.it.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://www.aurumcircle.it/policy.