1. General Provisions

This Personal Data Processing Policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter - the Law on Personal Data) and defines the procedure for processing personal data and security measures for personal data taken by COOLBIT LTD (hereinafter - the Operator).

1.1. The Operator sets as its primary goal and condition for carrying out its activities the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s Policy on Personal Data Processing (hereinafter - the Policy) applies to all information that the Operator may obtain about visitors to the website https://satoshkin-meetup.com.

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 cessation of processing personal data (except in cases 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, ensuring their availability on the Internet at the network address https://satoshkin-meetup.com.

2.4. Personal data information system - 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 inability to determine, without using additional information, the belonging of personal data 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 using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal or natural person who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines 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 that relates directly or indirectly to a specific or determinable User of the website https://satoshkin-meetup.com.

2.9. Personal data permitted by the subject of personal data for distribution - personal data, access to which by an unlimited number of persons is granted 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 Law on Personal Data (hereinafter - personal data permitted for distribution).

2.10. User - any visitor to the website https://satoshkin-meetup.com.

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 undefined circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunication 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 natural person, or a foreign legal entity.

2.14. Destruction of personal data - any actions that result 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 the event that the subject of personal data revokes consent to the processing of personal data, as well as, sends an appeal with a request to cease 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 Law on Personal Data;
  • to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and normative legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged:

  • to provide the subject of personal data, at their request, with information regarding the processing of their personal data;
  • to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • to respond to appeals and requests of subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
  • to notify the authorized body for the protection of the rights of subjects of personal data at the request of this body of the necessary information within 10 days from the date of receipt of such a request;
  • to publish or otherwise ensure unlimited access to this Policy on the processing of personal data;
  • to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
  • to cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Law on Personal Data;
  • to fulfill other obligations provided for by the Law on Personal Data.

4. Basic Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right:

  • to receive information concerning the processing of their personal data, except for cases provided for by federal laws. 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, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
  • to demand from the operator the clarification of their personal data, their blocking, or destruction in the event that personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
  • to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
  • to withdraw consent to the processing of personal data, as well as, to send a request to cease the processing of personal data;
  • to appeal to the authorized body for the protection of the rights of subjects of personal data or in court the unlawful actions or inaction of the Operator when processing their personal data;
  • to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged:

  • to provide the Operator with reliable data about themselves;
  • to inform the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the consent of the latter bear responsibility in accordance with the legislation of the Russian Federation.


5. Principles of Personal Data Processing

5.1. Personal data processing is carried out on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

5.3. It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. An excess of personal data processed in relation to the stated purposes of its processing is not permitted.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, their relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption 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 for the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which, the beneficiary or guarantor under which is the subject of personal data. Personal data processed is destroyed or depersonalized upon achievement of the processing purposes or in the event that the need to achieve these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of Processing: Informing the User through sending emails

Personal Data:

  • Last name, first name, patronymic
  • Email address
  • Telegram

Legal Basis:

  • Agreements concluded between the Operator and the subject of personal data

Types of Personal Data Processing:

  • Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
  • Sending informational emails to the email address

7. Conditions for Processing Personal Data

7.1. 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. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to carry out functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.

7.3. Processing of personal data is necessary for the administration of justice, the execution of a court decision, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary to fulfill an agreement to which the subject of personal data is a party, or the beneficiary or guarantor under which is the subject of personal data, as well as to conclude an agreement at the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor.

7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve publicly significant goals provided that the rights and freedoms of the subject of personal data are not violated.

7.6. Processing of personal data, access to which by an unlimited number of persons is granted by the subject of personal data or at their request (hereinafter - publicly available personal data) is carried out.

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the 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 prevent 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 the execution of current legislation or if the subject of personal data has given the Operator consent to transfer data to a third party to fulfill obligations under a civil law agreement.

8.3. In the event of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator’s email address coolbit.ltd@gmail.com marked “Personal Data Update.”

8.4. The processing period for 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 the agreement or current legislation.

The User can revoke their consent to the processing of personal data at any time by sending the Operator a notification by email to the Operator’s email address coolbit.ltd@gmail.com marked “Withdrawal of Consent to the Processing of Personal Data.”

8.5. All information collected by third-party services, including payment systems, means of communication, 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 with the indicated documents. The Operator is not responsible for the actions of third parties, including service providers indicated in this paragraph.

8.6. The prohibitions established by the subject of personal data on transfer (except for providing access), as well as on processing or processing conditions (except for obtaining access) 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 the Russian Federation.

8.7. The Operator, when processing personal data, 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 for the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which, the beneficiary or guarantor under which is the subject of personal data.

8.9. The condition for termination of 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, the withdrawal of consent by the subject of personal data or a request to cease the processing of personal data, as well as the detection 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, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the information received over information and telecommunication networks or without such.

10. Cross-border Transfer of Personal Data

10.1. The Operator, before commencing activities related to the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to carry out the processing of personal data).

10.2. The Operator, before submitting the aforementioned notification, is obliged to obtain the relevant information from the authorities of a foreign state, foreign natural persons, foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User can obtain any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator via email coolbit.ltd@gmail.com.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available online at https://satoshkin-meetup.com.

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