Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by Self-Employed Anton Viktorovich Baranov (hereinafter referred to as the "Operator").
1.1. The Operator considers the highest priority and condition of its activities to be the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Operator’s 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://wingman.tilda.ws/.
2. Key Terms 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 personal data processing (except when processing is necessary to clarify personal data).
2.3. Website– a collection of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://wingman.tilda.ws/.
2.4. Personal Data Information System– a set of personal data contained in databases and the information technologies and technical means enabling their processing.
2.5. Depersonalization of Personal Data– actions resulting in the impossibility of determining, without additional information, the affiliation 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 with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator– a state body, municipal body, legal entity, or individual organizing and/or carrying out the processing of personal data independently or jointly with others, as well as determining 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 directly or indirectly related to an identified or identifiable User of the website https://wingman.tilda.ws/.
2.9. Personal Data Permitted for Dissemination– personal data to which access by an unlimited number of persons has been granted by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in accordance with the Personal Data Law (hereinafter referred to as "Personal Data Permitted for Dissemination").
2.10. User– any visitor to the website https://wingman.tilda.ws/.
2.11. Provision of Personal Data– actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of Personal Data– any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-Border Transfer of Personal Data– the 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 the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Key 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;
• Continue processing personal data without the subject’s consent if grounds specified in the Personal Data Law exist, in case of withdrawal of consent or a request to cease processing;
• Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations under the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
• Organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• Respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• Provide the authorized body for the protection of personal data subjects with necessary information within 10 days of receiving a request;
• Publish or otherwise ensure unrestricted access to this Policy;
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, or dissemination, as well as from other unlawful actions;
• Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in cases and manner prescribed by the Personal Data Law;
• Perform other duties stipulated by the Personal Data Law.

4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

• Obtain information regarding the processing of their personal data, except in cases provided by federal laws;
• Demand the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose;
• Impose a condition of prior consent when processing personal data for marketing purposes;
• Withdraw consent to the processing of personal data or submit a request to cease processing;
• Appeal to the authorized body for the protection of personal data subjects or in court against unlawful actions or inaction of the Operator;
• Exercise other rights provided by Russian legislation.

4.2. Personal data subjects are obliged to:

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

4.3. Persons who provide the Operator with false information about themselves or about another personal data subject without the latter’s consent bear responsibility under Russian law.
5. Principles of Personal Data Processing
5.1. Processing is carried out lawfully and fairly.
5.2. Processing is limited to achieving specific, predefined, and lawful purposes.
5.3. Merging databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data relevant to the processing purposes may be processed.
5.5. The content and scope of processed data must correspond to the stated purposes.
5.6. Accuracy, sufficiency, and relevance of personal data must be ensured.
5.7. Storage must not exceed the period required by processing purposes unless otherwise stipulated by law or agreement.
6. Purposes of Personal Data Processing
7. Conditions of Personal Data Processing
7.1. Processing is carried out with the subject’s consent.
7.2. Processing is necessary for fulfilling obligations under Russian or international law.
7.3. Processing is required for the administration of justice or enforcement proceedings.
7.4. Processing is necessary for contract performance where the subject is a party, beneficiary, or guarantor.
7.5. Processing is needed to protect the Operator’s or third parties’ legitimate interests, provided the subject’s rights are not violated.
7.6. Processing involves publicly available personal data.
7.7. Processing is mandated by federal law for publication or disclosure.
8. Procedure for Collection, Storage, and Transfer of Personal Data
8.1. The Operator ensures security through legal, organizational, and technical measures.
8.2. Personal data is never transferred to third parties except as required by law or with the subject’s consent.
8.3. Users may update their data by emailing wingman.tme@gmail.com with the subject "Personal Data Update."
8.4. Processing continues until the purpose is achieved or consent is withdrawn.
8.5. Third-party services (e.g., payment systems) process data under their own policies; the Operator is not liable for their actions.
8.6. Restrictions on data transfer do not apply in cases of state or public interest under Russian law.
8.7. The Operator ensures confidentiality.
8.8. Storage duration is determined by processing purposes unless otherwise required by law.
8.9. Processing ceases upon achieving purposes, withdrawal of consent, or detection of unlawful processing.
9. Actions Performed by the Operator with Personal Data
9.1. The Operator collects, records, systematizes, stores, updates, retrieves, uses, transfers, depersonalizes, blocks, deletes, and destroys personal data.
9.2. Automated processing may involve transmission via telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. The Operator must notify the authorized body before initiating cross-border transfers.
10.2. Prior to notification, the Operator must obtain relevant information from foreign authorities/entities involved in the transfer.
11. Confidentiality of Personal Data
The Operator and persons granted access must not disclose or disseminate personal data without consent, unless required by federal law.
12. Final Provisions
12.1. Users may seek clarifications by emailing wingman.tme@gmail.com.
12.2. This Policy remains effective indefinitely until replaced by a new version.
12.3. The current version is publicly available at https://wingman.tilda.ws/privasy.