1. General provisions This policy of personal data processing is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter - the Personal Data Law) and defines the procedure of personal data processing and measures to ensure the security of personal data taken by IE Odunlami Serge Fokas (hereinafter - the Operator). 1.1 The Operator sets as its most important goal and condition of its activity the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal and family secrecy. 1.2 This Operator's policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about the visitors of the website https://africacallingforum.com/
2. Basic concepts used in the Policy 2.1 Automated processing of personal data - processing of personal data by means of computer equipment. 2.2 Blocking of personal data - temporary cessation of personal data processing (except for cases when 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://africacallingforum.com/ 2.4 Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing. 2.5. Personal data depersonalization - actions, as a result of which it is impossible to determine without using additional information whether personal data belong to a particular User or other subject of personal data. 2.6 Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation means or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data. 2.7 Operator - a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data. 2.8 Personal Data - any information relating directly or indirectly to a specific or identifiable User of https://africacallingforum.com/ 2.9. Personal data authorized by the subject of personal data for dissemination - personal data, access to which is provided by the subject of personal data to an unlimited number of persons by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data authorized for dissemination). 2.10. User - any visitor of the website https://africacallingforum.com/ 2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons. 2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number of persons, including disclosure of personal data in 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 country to a foreign government authority, a foreign individual or a foreign legal entity. 2.14. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed.
3. Basic Rights and Obligations of the Operator 3.1. The Operator has the right to:
Receive reliable information and/or documents containing personal data from the data subject;
In the event of withdrawal of consent to the processing of personal data by the data subject, the Operator has the right to continue processing personal data without the consent of the data subject 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 stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
Provide the data subject, at their request, with information relating to the processing of their personal data;
Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
Respond to requests and inquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
Provide the authorized body for the protection of the rights of personal data subjects with the necessary information within 30 days from the date of receipt of such a request;
Publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
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 in relation to personal data;
Terminate the transfer (distribution, provision, access) of personal data, terminate processing and destroy personal data in the manner and in cases provided for by the Personal Data Law;
Fulfill other obligations stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects 4.1. Data subjects have the right to:
Receive information related to the processing of their personal data, except for cases stipulated by federal laws. The information shall be provided to the data subject by the Operator in an accessible form and shall not contain personal data relating to other data subjects, 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 Personal Data Law;
Demand from the Operator the clarification of their personal data, their blocking or destruction if 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;
Set a condition of prior consent to the processing of personal data for the purpose of promoting goods, works, and services on the market;
Withdraw consent to the processing of personal data;
Appeal to the authorized body for the protection of the rights of personal data subjects or to the court against illegal actions or inaction of the Operator in the processing of their personal data;
Exercise other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects are obligated to:
Provide the Operator with reliable information about themselves;
Inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another data subject without the latter's consent shall be liable in accordance with the legislation of the Russian Federation.
5. Personal data that may be processed by the Operator 5.1. Surname, name, patronymic. 5.2. Phone numbers. 5.3. The website also collects and processes anonymized data about visitors (including "cookie" files) using web analytics services (Yandex Metrica, Google Analytics, and others). 5.4. The above data are hereinafter referred to as Personal Data. 5.5. The Operator does not process special categories of personal data relating to racial, national origin, political opinions, religious or philosophical beliefs, or intimate life. 5.6. The processing of personal data permitted for distribution, including special categories of personal data specified in part 1 of Article 10 of the Personal Data Law, is allowed if the prohibitions and conditions stipulated by Article 10.1 of the Personal Data Law are observed. 5.7. The User's consent to the processing of personal data permitted for distribution shall be formalized separately from other consents to the processing of their personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects. 5.7.1. The User shall provide the Operator with consent to the processing of personal data permitted for distribution directly. 5.7.2. The Operator is obligated to publish information about the processing conditions, the existence of prohibitions and conditions for the processing of personal data permitted for distribution by an unlimited circle of persons, no later than three working days from the date of receipt of the specified consent of the User. 5.7.3. 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 surname, name, patronymic (if any), contact information (telephone number, email address, or mailing address) of the subject of personal data, as well as a list of personal data, the processing of which must be terminated. The personal data specified in this request may only be processed by the Operator to whom it is addressed. 5.7.4. Consent to the processing of personal data permitted for distribution shall cease to be valid from the moment the Operator receives the request specified in clause 5.7.3 of this Personal Data Processing Policy.
6. Principles of Personal Data Processing 6.1. Personal data processing shall be carried out on a lawful and fair basis. 6.2. Personal data processing shall be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed. 6.3. The merging of databases containing personal data processed for purposes incompatible with each other is not allowed. 6.4. Only personal data that meet the purposes of their processing shall be subject to processing. 6.5. The content and scope of processed personal data shall correspond to the stated processing purposes. Excessive processing of personal data relative to the stated processing purposes is not allowed. 6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data. 6.7. Personal data shall be stored in a form that allows for the identification of the data subject, no longer than is necessary for the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or in case the achievement of these purposes is no longer necessary, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing 7.1. The purposes of processing the User’s personal data are:
Informing the User by sending emails;
Conclusion, execution, and termination of civil law contracts;
Providing the User with access to services, information, and/or materials contained on the website https://africacallingforum.com/
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 privacy@sergephocas.me with the note "Unsubscribe from notifications about new products, services, and special offers". 7.3. Anonymized User data collected using web analytics services are used to collect information about User actions on the website, improve the quality of the website 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 Operator’s statutory documents;
Agreements concluded between the Operator and the data subject;
Federal laws and 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 they are filled in and/or sent by the User independently through special forms located on the website https://africacallingforum.com/ or sent to the Operator by email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy. 8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (saving "cookie" files and using JavaScript technology is enabled). 8.4. The data subject independently decides on the provision of their personal data and gives consent freely, by their own will and in their interest.
9. Conditions for Processing of Personal Data 9.1. Personal data processing is carried out with the consent of the data subject to the processing of their personal data. 9.2. Processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation. 9.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings. 9.4. Processing of personal data is necessary for the performance of an agreement to which the data subject is a party or a beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the data subject or an agreement under which the data subject will be a beneficiary or guarantor. 9.5. Processing of personal data is necessary for the realization of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the data subject. 9.6. Processing of personal data is carried out, access to which is provided by the subject of personal data to an unlimited circle of persons, either at their request (hereinafter referred to as publicly available personal data). 9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
10. Procedure for the 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 for the full compliance with the requirements of the 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 prevent unauthorized access to personal data. 10.2. 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 in the event that the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of 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's email address privacy@sergephocas.me with the note "Personal Data Update". 10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by an agreement or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator by email to the Operator's email address privacy@sergephocas.me with the note "Withdrawal of consent to the processing of personal data". 10.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreements and Privacy Policies. The subject of personal data and/or the User is obligated to independently and timely familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause. 10.6. Prohibitions on the transfer (except for providing access), as well as on the processing or conditions for processing (except for obtaining access) of personal data permitted for distribution, established by the subject of personal data, shall not apply in cases of processing of personal data in state, public, and other public interests, as determined by the legislation of the Russian Federation. 10.7. The Operator shall ensure the confidentiality of personal data when processing personal data. 10.8. The Operator shall store personal data in a form that allows for the identification of the data subject, no longer than is necessary for the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the data subject is a party, beneficiary, or guarantor. 10.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the validity period of the data subject's consent or the withdrawal of consent by the data subject, as well as the discovery of illegal processing of personal data.
11. List of Actions Performed by the Operator with Received Personal Data 11.1. The Operator shall carry out the collection, recording, systematization, accumulation, storage, refinement (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data. 11.2. The Operator shall carry out automated processing of personal data with the receipt and/or transfer of received information via information and telecommunication networks or without using such networks.
12. Cross-border Transfer of Personal Data 12.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory it is intended to transfer the personal data provides reliable protection of the rights of personal data subjects. 12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of their personal data and/or the performance of an agreement 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 obligated not to disclose to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.
14. Final Provisions 14.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email. 14.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version. 14.3. The current version of the Policy is freely available on the Internet at https://africacallingforum.com/en/privacy-policy.