Privacy Policy

1. This Regulation on Personal Data Processing (hereinafter referred to as the Regulation, this Regulation) is developed by Artooine Galleries LLC (hereinafter referred to as the Operator) and shall apply in accordance with clause 2 of part 1 of article 18.1 of the Federal Law No. 152-FZ "On Personal Data". 1 of Article 18.1. of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data". This Regulation sets out the Operator's policy in relation to the processing of personal data.

2. All issues related to the processing of personal data not regulated by this Regulation shall be resolved in accordance with the applicable laws of the Russian Federation in the field of personal data. This Regulation and amendments to it shall be approved by the Head of the Operator and shall be introduced by order of the Operator.

3. In accordance with paragraph 1 of Article 3 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", personal data of customers and natural persons means any information relating to a customer or natural person directly or indirectly identified or identifiable on the basis of such information (hereinafter - personal data).

4. Artuin Gallery Ltd. is the operator who organises and/or carries out the processing of personal data and determines the purpose and content of personal data processing.

5. The purpose of processing personal data is

Ensuring the protection of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family confidentiality;

provision of services by the Operator to natural and legal persons related to the Operator's business activities, including contact by the Operator with such persons, including by e-mail, telephone, at the address provided by the person concerned;

sending advice, answers to those contacted via means of communication and the contractual details they have provided;

Promoting the Operator's goods, works and services on the market through direct contact with the potential consumer by means of communication (only permitted with the prior consent of the personal data subject).

6. The processing is organised by the Operator on the principles of:

The lawfulness of the purposes and methods of personal data processing, and the integrity and fairness of the Operator's activities;

The accuracy of personal data, their adequacy for the purposes of processing, and the inadmissibility of processing personal data that is excessive in relation to the purposes stated in the collection of personal data;

only process personal data that is suitable for the purposes for which it is being processed;

The content and scope of the processed personal data shall be consistent with the stated processing purposes. The personal data processed must not be excessive in relation to the stated purposes of processing;

The inadmissibility of combining databases containing personal data whose processing is incompatible with each other;

Ensuring the accuracy of personal data, their adequacy and, where necessary, their relevance in relation to the purposes of personal data processing. The operator shall take necessary measures or ensure that such measures are taken to delete or clarify incomplete or inaccurate data;

The storage of personal data in a form that identifies the personal data subject for no longer than is required for the purposes of personal data processing.

7. Processing of personal data shall be carried out in compliance with the principles and rules stipulated by Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and this Regulation.

8. Personal data shall be processed with or without the use of automation.

9. In accordance with the set goals and objectives, the Operator shall appoint a person responsible for organising the processing of personal data before the commencement of personal data processing.

The person responsible for the organisation of personal data processing receives instructions directly from the Operator's executive body and is accountable to it.

The person responsible for the organisation of personal data processing may issue and sign a notice stipulated in parts 1 and 3 of Article 22 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data".

10. The Operator's employees directly involved in personal data processing must be familiarised, prior to commencing work, with the provisions of Russian Federation legislation on personal data, including personal data protection requirements, documents defining the Operator's policy on personal data processing, local acts on personal data processing, with this Regulation and amendments to it.

11. When processing personal data, the Operator shall apply legal, organisational and technical measures to ensure the security of personal data in accordance with Art. 19 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data".

12. When collecting personal data using information and telecommunication networks, the Operator shall publish in the relevant information and telecommunication network a document defining its policy on personal data processing and information on implemented requirements to protection of personal data, as well as provide access to the said document using the means of the relevant information and telecommunication network.

13. Conditions for the processing of personal data by the Operator. Personal data may be processed in the following cases:

the processing of personal data is necessary to achieve the purposes set out in an international treaty of the Russian Federation or by law, to carry out and fulfil the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation;

Processing of personal data is necessary for execution of an agreement, a party to which or a beneficiary or guarantor under which the personal data subject is a party, including in case the operator exercises its right to assign rights (claims) under such an agreement, as well as for conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor;

processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject if obtaining the consent of the personal data subject is not possible;

the processing of personal data is necessary for the exercise of the rights and lawful interests of the Operator or third parties or to achieve socially important objectives, provided that the rights and freedoms of the personal data subject are not infringed thereby;

Personal data is processed for statistical or other research purposes, with the exception of the purposes specified in Article 15 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", subject to the mandatory depersonalisation of personal data;

Personal data is processed and access to which is granted to an unlimited number of persons by the personal data subject or at his or her request;

Personal data subject to publication or compulsory disclosure under federal law is processed.

14. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than the purposes of its processing, and it shall be destroyed when the purposes of processing are achieved or when it is no longer necessary to achieve them in the manner prescribed by the Regulation on the storage of personal data with the Operator.

15. Personal data processed in information systems shall be protected against unauthorised access and copying. Security of personal data during its processing in information systems shall be ensured by the personal data protection system, including organisational measures and information protection means. Technical and software tools shall meet the requirements established in accordance with the legislation of the Russian Federation to ensure information protection.

16 Interaction with federal executive authorities regarding the processing and protection of personal data of the subjects whose personal data is processed by the Operator is carried out within the framework of the legislation of the Russian Federation.

1. Personal data subjects or their representatives have the rights stipulated in the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" and other laws and regulations governing the processing of personal data.

2. the operator shall ensure the rights of subjects of personal data in accordance with the procedure laid down in Chapters 3 and 4 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data".

3. The operator is obliged to provide the personal data subject or his representative with the opportunity to become acquainted with the personal data relating to that personal data subject, free of charge, at the operator's location during the operator's working hours.

4. A data subject's right of access to their personal data may be restricted in accordance with federal laws.

5. If the personal data subject is represented by a representative, the representative's authority shall be confirmed by a power of attorney drawn up in the prescribed manner.

6. Where a personal data subject has given written consent to the use of personal data, a simple written form shall be sufficient for such consent.

7. The operator guarantees the security and confidentiality of the personal data used.

8. The processing of personal data for the purpose of promoting goods, works and services on the market through direct contact with the potential consumer by means of communication is permitted only with the prior consent of the personal data subject.

1. The operator shall have the following procedure for obtaining personal data:

When applying for the Operator's services, the client provides the data set out in the relevant forms.

The operator does not obtain or process personal data about the client's race, political views, religious and philosophical beliefs, health status, intimate life, unless the law provides otherwise.

3. In cases directly related to employment matters, in accordance with Article 24 of the Constitution of the Russian Federation, the Organisation is only entitled to receive and process data on the private life of the client with the client's written consent.

4. If the client accepts the offer placed on the Operator's website or concludes another agreement with the Operator, the processing of the client's personal data shall be carried out in order to fulfil the relevant agreement, which came into force as a result of the client accepting the terms of the offer or concluding another agreement respectively.

5. The operator is also entitled to process the personal data of clients who have contacted the operator by natural persons only with their consent to use the personal data.

Customer consent to the processing of personal data is not required in the following cases:

personal data is publicly available;

The processing of personal data is carried out on the basis of a federal law establishing its purpose, the conditions for obtaining personal data and the range of subjects whose personal data is to be processed, as well as certain powers of the Organisation;

at the request of the competent state authorities in cases provided for by federal law;

processing of personal data for the purpose of performing the contract concluded with the Operator;

Personal data shall be processed for statistical or other scientific purposes, provided that the personal data is depersonalised;

processing of personal data is necessary to protect the life, health or other vital interests of the client if obtaining his or her consent is not possible.

5. The operator shall ensure the safe storage of personal data, including

The storage, collection, accounting and use of documents containing personal data shall be organised in the form of a separate archive of the Operator.

Personal data shall be stored in a form that allows identification of the personal data subject for no longer than is required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalised upon attainment of the processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.

1. Personal data shall be transferred in compliance with the following requirements:

It is forbidden to disclose personal data to a third party without the client's written consent, except when necessary to prevent a threat to the client's life, health or in other cases provided for by law;

not share personal data for commercial purposes without the written consent of the data subject;

To warn persons receiving personal data that the data may only be used for the purposes for which it is communicated and to require these persons to confirm that this rule has been complied with;

Allow access to personal data only to specifically authorised persons, and these persons shall only be entitled to receive personal data that is necessary for the performance of specific functions;

not ask for information about the client's health status, except for information that relates to the client's ability to fulfil his obligations under the contract with the operator;

Pass on the client's personal data to its representatives in accordance with the procedure prescribed by Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".

1.. The right of access to personal data shall be

the Head of the Operator;

the Operator's employees working with a particular client;

accountancy staff;

employees who provide technical support for the Operator's activities.

2. Customers have the following rights in order to ensure the protection of personal data:

to be fully informed about their personal data and the processing of that data;

free free access to their personal data, including the right to obtain copies of any record containing personal data, except as required by federal law;

to identify their representatives for the protection of their personal data;

to request the deletion or correction of incorrect or incomplete personal data or data processed in violation of the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data".

1. Persons guilty of breaching the procedure for handling personal data shall bear disciplinary, administrative, civil or criminal liability in accordance with federal laws.

2. The heads of structural units of the Operator shall be personally responsible for the performance of the duties of their subordinates.

Regulation on personal data processing

The user, by submitting an application on https://artwingallery.com (hereinafter also the website), creating an account and/or agreeing to the offer on the website, accepts this Consent to the processing of personal data.

The user, acting freely, willingly and in his own interest, confirming his legal capacity, gives his consent to Artooine Gallery Ltd. to process his personal data both with and without the use of automation for the purposes of processing incoming requests from individuals (users) for advice, sending comments to individuals (users); analysis of the actions of individuals (users) on the site and the functioning of the site; perform obligations under the offer agreement, adopted by Herewith:

1. Consent is given for the use of my following personal data: Surname, first name, patronymic; contact telephone numbers; e-mail addresses; place of work and position held; address; location details; operating system type, version, browser language; type of device and its screen resolution; pages opened by the user; ip address.

The processing of my personal data may include the following: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction.

This consent may be withdrawn by sending the personal data subject (user) or his/her representative the following mail: info@artwingallery.com. In the event that the data subject (user) withdraws consent to the processing of personal data, proceed with the processing of such personal data in the cases contemplated by Clauses 2-11 of Part 1 of Article 6, Clauses 2-10 of Part 2 of Article 10, Clause 2 of Article 11 of the Federal Law of 27.07.2006 No 152-FZ "On Personal Data".

This consent is given for an indefinite period of time and is valid for the entire duration of personal data processing.