Privacy policy

1. General Provisions This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006 (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by BitCluster (hereinafter referred to as the Operator).

1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets, as one of its most important goals and conditions for its activities.

1.2. This Policy 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://bitcluster.com/.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computing technology.

2.2. Blocking of personal data — temporary cessation of personal data processing (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 that ensure their availability on the Internet at https://bitcluster.com/.

2.4. Personal data information system — a set of personal data contained in databases and the information technology and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions resulting in the inability to determine the ownership of personal data to a specific User or another personal data subject without 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), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of personal data processing, the composition of 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://bitcluster.com/.

2.9. Personal data authorized by the personal data subject for dissemination — personal data to which the data subject has granted access to an unlimited number of persons by giving consent for processing in accordance with the Personal Data Law (hereinafter referred to as personal data authorized for dissemination).

2.10. User — any visitor to the website https://bitcluster.com/.

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

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication 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 state to an authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration in the personal data information system and/or destruction of personal data storage media.

3. Operator’s Rights and Obligations

3.1. The Operator has the right to:

• Obtain from the personal data subject accurate information and/or documents containing personal data;
• Continue processing personal data without the consent of the data subject if there are legal grounds specified in the Personal Data Law;
• Independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations stipulated by the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obligated to:

• Provide the data subject with information regarding the processing of their personal data upon request;
• Organize the processing of personal data in accordance with the requirements of Russian law;
• Respond to inquiries and requests from data subjects and their legal representatives in compliance with the Personal Data Law;
• Notify the authorized body for the protection of data subjects’ rights upon request within 10 days of receiving such a request;
• Publish or otherwise provide unrestricted access to this Policy regarding personal data processing;
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as other unlawful actions concerning personal data;
• Cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
• Fulfill other obligations stipulated by the Personal Data Law.

4. Data Subjects’ Rights and Obligations

4.1. Data subjects have the right to:

• Receive information regarding the processing of their personal data, except in cases stipulated by federal laws;
• Request the Operator to update, block, or delete their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing;
• Require prior consent for the processing of personal data for marketing purposes;
• Withdraw consent for personal data processing and demand the termination of personal data processing;
• File complaints with the authorized body for the protection of personal data subjects’ rights or in court regarding unlawful actions or inaction by the Operator;
• Exercise other rights provided by Russian law.

4.2. Data subjects are required to:

• Provide the Operator with accurate personal data;
• Notify the Operator of any updates or changes to their personal data.

4.3. Persons who provide inaccurate information about themselves or another personal data subject without consent bear responsibility in accordance with Russian law.

5. Principles of personal data processing

5.1. Personal data shall be processed on a lawful and fair basis.

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

5.3. Combining databases containing personal data that are processed for purposes that are incompatible with each other shall not be permitted.

5.4. Only personal data that meet the purposes of their processing shall be processed.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing shall not be permitted.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data shall be ensured. The Operator shall take the necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the personal data subject to be identified, for no longer than required for the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or depersonalized upon achieving the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing: informing the user by sending emails. Personal data: last name, first name, patronymic, email address, telephone numbers. Legal grounds: statutory (constituent) documents of the Operator. Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data.

7. Terms of personal data processing

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his personal data.

7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties imposed on 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 judicial act, an act of another body or official subject to execution 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 on 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. The processing of personal data is carried out, access to which is granted to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

7.7. The processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.

8. The procedure for collecting, storing, transferring and other types of processing of 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 unauthorized persons from accessing personal data.

8.2. 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 for the fulfillment of obligations under a civil law contract.

8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator’s e-mail address [email protected] with the subject line “Updating personal data”.

8.4. 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 the agreement or applicable legislation.

The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator’s e-mail address [email protected] with the subject line “Revocation of consent to the processing of personal data”.

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall 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 ensures the confidentiality of personal data when processing personal data.

8.8. The Operator shall store personal data in a form that allows the personal data subject to be identified for no longer than is required for the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.

8.9. The condition for termination of personal data processing may be the achievement of the personal data processing purposes, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or a requirement to terminate the personal data processing, as well as the identification of unlawful processing of personal data.

9. List of actions performed by the Operator with the received personal data

9.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (dissemination, provision, access), depersonalize, block, delete and destroy personal data.

9.2. The Operator shall carry out automated processing of personal data with or without receipt and/or transfer of the received information via information and telecommunication networks.

10. Cross-border transfer of personal data

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

10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of a foreign state, foreign individuals, and 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 gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final provisions

12.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail [email protected].

12.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://bitcluster.com/Privacy.