Personal data processing policy for the kandinskylab.ai website
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (the "Personal Data Law") and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Denis Valeryevich Dimitrov (the "Operator").
1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data — including the protection of the rights to privacy, personal and family secrets — to be the most important goal and condition for carrying out its activities.
1.2. This policy of the Operator regarding the processing of personal data (the "Policy") applies to all information that the Operator may obtain about visitors of the website https://kandinskylab.ai.
2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and information materials, as well as computer programs and databases, that ensure their availability on the internet at the network address https://kandinskylab.ai.
2.4. Personal data information system — a set of personal data contained in databases, and the information technologies and technical means that ensure their processing.
2.5. De-identification of personal data — actions as a result of which it becomes impossible, without additional information, to determine that specific personal data belongs to a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, and destruction of personal data.
2.7. Operator — a government body, municipal body, legal entity, or natural person that, alone or jointly with others, organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of the personal data to be processed, and the 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://kandinskylab.ai.
2.9. Personal data permitted by the subject for distribution — personal data to which access by an unlimited number of persons has been granted by the subject of personal data through consent to the processing of personal data permitted for distribution, in the manner provided for by the Personal Data Law (the "personal data permitted for distribution").
2.10. User — any visitor of the website https://kandinskylab.ai.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publishing personal data in the media, posting it on information and telecommunication networks, or otherwise providing access to personal data.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is destroyed irrevocably, with the impossibility of further restoring its content in the personal data information system, and/or the physical media containing personal data are destroyed.
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4.1. Subjects of personal data have the right to:
4.2. Subjects of personal data are obliged to:
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another subject of personal data without that subject's consent, bear liability in accordance with the legislation of the Russian Federation.
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of its collection is not permitted.
5.3. The combining of databases containing personal data processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of its processing is not permitted.
5.6. When processing personal data, the accuracy of the personal data and its sufficiency are ensured, and, where necessary, its relevance to the purposes of processing. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the subject of personal data to be identified for no longer than is required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Personal data being processed is destroyed or de-identified once the purposes of processing have been achieved, or if the need to achieve them has been lost, unless otherwise provided by federal law.
The website kandinskylab.ai is a non-commercial showcase of Kandinsky Lab's research and open models. The Operator does not collect data through registration forms, user accounts, or payments. The processing of personal data is limited to the following:
| Purpose of processing | Analysis of website traffic and user behavior (web analytics) to improve the site; handling user inquiries sent by email |
|---|---|
| Personal data | Technical data about the site visitor (IP address, cookie data, browser and device information, on-site behavior data) collected by the Yandex.Metrica and Google Analytics web analytics services; and data voluntarily provided by the user when contacting via email (name, email address, contents of the message) |
| Legal grounds | Federal Law No. 149-FZ "On Information, Information Technologies, and the Protection of Information" dated 27.07.2006; user consent, expressed by continuing to use the website (with respect to analytics cookies) |
| Types of personal data processing | Collection, recording, accumulation, storage, use, de-identification |
Yandex.Metrica is used in Webvisor mode, meaning it records de-identified data about a visitor's interaction with the site's pages (cursor movements, clicks, scrolling) for analytics purposes. The processing of data by the Yandex.Metrica and Google Analytics services is separately governed by the respective policies of Yandex LLC and Google LLC.
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or to carry out 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, or the enforcement of a judicial act, an act of another body or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the subject of personal data, or an agreement under which the subject of personal data will be a beneficiary or guarantor.
7.5. 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 the rights and freedoms of the subject of personal data are not violated.
7.6. Processing is carried out of personal data to which access by an unlimited number of persons has been provided by the subject of personal data or at their request (the "publicly available personal data").
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.
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.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation, or where the subject of personal data has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law agreement.
8.3. If inaccuracies are found in their personal data, the User may update it independently by sending the Operator a notice to the Operator's email address kandinsky@kandinskylab.ai, marked "Personal data update."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by an agreement or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to kandinsky@kandinskylab.ai, marked "Withdrawal of consent to the processing of personal data."
8.5. All information collected by third-party web analytics services (Yandex.Metrica, Google Analytics) and other service providers is stored and processed by those parties (operators) in accordance with their own user agreements and privacy policies, which the subject of personal data may review independently on the respective services' websites. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions established by the subject of personal data on the transfer (other than granting access), processing, or conditions of processing (other than gaining access) of personal data permitted for distribution do not apply in cases where personal data is processed in the state, public, or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the subject of personal data to be identified for no longer than is required by the purposes of processing, unless the storage period is established by federal law, or an agreement to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. Grounds for ceasing the processing of personal data may include the achievement of the purposes of processing, the expiration of the subject's consent, withdrawal of consent by the subject, a request to cease processing, or the identification of unlawful processing of personal data.
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunication networks.
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out a cross-border transfer of personal data (such notice is sent separately from the notice of intent to process personal data).
10.2. Before submitting the above notice, the Operator must obtain the relevant information from the authorities of the foreign state, foreign natural persons, or foreign legal entities to whom the cross-border transfer of personal data is planned.
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator by email at kandinsky@kandinskylab.ai.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. 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://kandinskylab.ai/privacy/.