(in force since 31 May 2023)
1. GENERAL PROVISIONS
1.1. The Confidentiality Policy of the We Compete as One Charity Foundation (Personal Data Processing Policy) (hereinafter referred to as the “Policy”) has been prepared in accordance with the provisions of Article 18.1, Part 1, Clause 2 of the Federal Law of the Russian Federation On Personal Data dated 27.07.2006 No. 152-FZ and defines the purposes and principles of, and procedure for, processing the Personal Data of the Website User, rights and responsibilities of the User, obligations of the Operator, and contains the information on the arrangements made to protect the processed Personal data.
1.2. The purpose of this Policy is to ensure the protection of the User’s rights and freedoms in the processing of his Personal Data, including the protection of the privacy right, personal and family secrecy and physician-patient privilege, define the policy of the We Compete as One Charity Foundation (hereinafter referred to as the “Foundation”) as a personal data processing operator.
1.3. This Policy applies to all of the Personal Data the Operator receives from the Website User.
1.4. In case the User disagrees with the conditions of this policy, the User must immediately discontinue any use of the Website.
2. TERMS AND DEFINITIONS
2.1. “Operator” means the We Compete as One Charity Foundation (located at 123056, Moscow, Krasina st., 27, building 2, room 1/С) which independently organizes and carries out the Personal Data Processing, as well as determines the purposes of the Personal Data Processing, composition of the Personal Data to be processed, and acts (operations) performed with respect to the Personal Data.
2.2. “User” means a Personal Data subject (including a candidate for Charity Recipient (sportsmen sponsored by the Foundation) and/or his legal representative, a Website visitor, etc.);
2.3. “Website” means the website located in the Internet information and telecommunications network at: https://www.wcao.fund;
2.4. “Personal Data” means any information relating, directly or indirectly, to the defined or definable individual (Personal Data subject).
2.5. “Personal Data Processing” means any act (operation) or the totality of acts (operations) performed using or without using automation facilities with regard to the Personal Data, including the collection, systematization, accumulation, storage, ascertainment (updating, change), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of the Personal Data.
2.6. “Automated Personal Data Processing” means the Personal Data Processing using computing facilities.
2.7. “Personal Data Distribution” means the acts intended for disclosing the Personal Data to the public;
2.8. “Personal Data Provision” means the acts intended for disclosing the Personal Data to a certain person or certain circle of persons.
2.9. “Personal Data Anonymization” means the acts as a result of which it becomes impossible, without using additional information, to identify the Personal Data subject to whom the Personal Data belong.
2.10. “Personal Data Blocking” means a temporary discontinuance of the Personal Data Processing (unless such processing is necessary for the Personal Data Ascertainment).
2.11. “Personal Data Destruction” means the acts as a result of which it becomes impossible to restore the contents of the Personal data in the information system of Personal Data and (or) as a result of which the physical media bearing the Personal Data are destroyed.
2.12. “Cookie Files” means the data automatically transmitted to the Operator while using the Website through the software installed on the User’s device, including IP address, geographical position, browser details and type of the operating system of the User’s device, technical specifications of the hardware and software employed by the User, date and time of access to the Website. By accepting the terms and conditions of this policy, the User agrees to use the Cookie Files.
3. PURPOSES OF USER’S PERSONAL DATA PROCESSING
3.1. The User’s Personal Data are processed for the following purposes:
3.1.1. To identify the User who has created a user account (personal area).
3.1.2. To accept the User’s application (questionnaire) for participation in the Foundation’s Charitable Program.
3.1.3. To establish a two-way feedback with the User, including notices (requests) concerning the application (questionnaire) sent by the User, as well as efficient technical support to be rendered when any problems arise in connection with the use of the Website.
3.1.4. To send information materials and newsletters with the consent of the User.
3.1.5. To pursue statistical and other research subject to the compulsory Personal Data Anonymization.
4. CONDITIONS OF, AND PROCEDURE FOR, GIVING CONSENT TO PERSONAL DATA PROCESSING
4.1. The Operator has no obligation but has the right to check the Personal Data provided by the User. The Operator proceeds from the fact that in the Personal Data Provision on the Website the User is a legally capable person. In case of a legally incapable person using the Website, the consent to the Personal Data Processing should be given by the legal representative of the User who has reviewed and accepted the terms and conditions of the Personal Data Processing set out in this Policy.
Where the Operator becomes aware that the Personal Data have been received from a person under the age of 18 years (legally incapable) without the consent of his legal representative, the Operator will delete such information as soon as possible and will be entitled to block such person’s access to the Website.
4.2. The User accepts the terms and conditions of the Policy and gives the Operator his informed consent to his Personal Data Processing in compliance with this Policy and the Federal Law On Personal data dated 27.07.2006 No. 152-FZ:
4.2.1. When creating a user account (personal area) on the Website, for the Personal Data the User provides to the Operator: by filling out the questionnaire for the creation of a user account (personal area) in the Internet information and telecommunications network at: https://www.wcao.fund. The User will be deemed to have consented to his Personal Data Processing at the time he clicks the button “Register” / “Create user account” / “Create personal area” or any similar buttons.
4.2.2. When filling out the application (questionnaire) form for participation in the Foundation’s Charitable Program, for the Personal Data the User provides while filling out the application (form) in the Internet information and telecommunications network on the Website. The User will be deemed to have consented to the processing of his Personal Data inserted into the application (questionnaire) form fields at the time he clicks the button used to send the application (questionnaire) (such buttons may be called “Send” or similarly).
4.2.3. When filling out the feedback form, including a request, for the Personal Data the User provides while filling out the feedback form in the Internet information and telecommunications network on the Website. The User will be deemed to have consented to the processing of his Personal Data inserted into the feedback form fields at the time he clicks the button used to send the request (such buttons may be called “Send”, “Send request”, “Get advice” or similarly).
4.2.4. When making a subscription to the receipt of information materials and newsletters, for the Personal Data the User provides while filling out the form of subscription to the receipt of information materials and newsletters. The User will be deemed to have consented to his Personal Data Processing once he has ticked off the field “I agree with the conditions of Personal Data processing.”
4.2.5. In any use of the Website, for the Personal Data which are automatically transmitted to the Operator while using the Website through the software installed on the User’s device. The User will be deemed to have consented to his Personal Data Processing at the time he begins to use the Website.
4.3. By performing the acts described in Clause 4.2 above, the User gives the Operator his consent to the processing of the relevant Personal Data the list of which is comprised in Section 5 below, including the collection, systematization, accumulation, storage, ascertainment (updating, change), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of the Personal Data using or without using automation facilities in accordance with the purposes set out in Section 3 above.
4.4. The consent given by the User in accordance with this Policy to the Personal Data Processing will be in force from the date of such consent and during such period as will be necessary for achieving the purposes of the Personal Data Processing or up to the date of withdrawal by the User of such consent, unless otherwise contemplated by the current legislation of the Russian Federation. The consent given by the User in accordance with this Policy to the Personal Data Processing may be at any time withdrawn by the User. The User may revoke his consent to the Personal Data Processing given before by sending the pertinent statement to the address specified in Section 12 below by registered mail return receipt requested or to the email address specified in Section 12 below.
5. PERSONAL DATA PROCESSED BY OPERATOR
5.1. The User’s Personal Data Processing will be carried out by the Operator as follows:
| Purpose of using the Personal Data | Amount of the Personal Data processed |
| To identify the User creating a user account (personal area) (Clause 3.1.1 above) | — surname, given name and patronymic; — email address; — telephone number. |
| Date of accepting the User’s application (questionnaire) for participation in the Foundation’s Charitable Program (Clause 3.1.2 above) | — surname, given name and patronymic (in case the application is filed in relation a person under age, the data of his legal; representative will be also provided); — identity document details (series and (or) number; date and place of issuance, issuing authority; permanent registered address); — sex; — day, month and year of birth; — citizenship; — country and city of actual residence, telephone number, email address and user account addresses in social networks; — family status, family membership particulars, including the year of birth of children; — health condition details, including the data of the documents showing the health particularities (if any); — information on the children’s health condition (if there is a developmental disorder); — details of the level of education (higher, secondary, other) and specialty; — information on the place of employment (name); — details of sporting achievements (athletic title and category, etc.), including the data of the documents confirming sporting achievements; — other interest (hobby) details; — level of income; — social status; — details of participation in the work of any social, sports, socio-political and other organizations; — person’s color digital photograph. |
| To establish feedback with the User, including notices requests, applications concerning the use of the Website, as well as efficient technical support to be rendered when any problems arise in connection with the use of the Website (Clause 3.1.3 above) | — surname, given name and patronymic; — email address; — telephone number. |
| To send information materials and newsletters (Clause 3.1.4 above) | — surname, given name and patronymic; — email address; — telephone number. |
| Statistical and other research (Clause. 3.1.5 above) | —Cookie files. |
6. PERSONAL DATA PROCESSING
6.1. The Operator will process the Personal Data based on the following principles:
— legitimacy and justice;
— limitation of the Personal Data Processing by the achievement of any specific predetermined and lawful goals;
— non-admission of the Personal Data Processing which is incompatible with the purposes of the Personal Data collection;
— non-admission of integration of any databases containing the Personal Data whose processing is carried out for the purposes incompatible between themselves;
— processing only such Personal Data as answer the purposes of their processing;
— conformity of the contents and amount of the processed Personal Data with the declared purposes of processing;
— non-admission of the processing of any Personal Data which are superfluous with respect to the declared purposes of their processing;
— ensuring accuracy, adequacy and currency of the Personal Data as regards the purposes of the Personal Data Processing;
— destruction or anonymization of the Personal Data after the purposes of their processing being achieved or if the achievement of such purposes is no more required or if the User revokes his consent to the Personal Data Processing.
6.2. The Operator will carry out the User’s Personal Data Processing (collection, systematization, accumulation, storage, ascertainment (updating, change), retrieval) using the databases in the territory of the Russian Federation.
6.3. The User’s Personal Data Processing will be effected by the Operator either using or without using automation facilities.
6.4. The Operator and any other persons which have received access to the Personal Data are bound not to disclose the Personal Data to third parties and not to distribute them without the consent of the Personal Data subject, unless otherwise envisaged by a federal law.
6.5. The User’s Personal Data Processing will involve the following acts to be performed by the Operator: collection, recording, systematization, accumulation, storage, ascertainment (updating, change), retrieval, use, transmission (distribution, provision to third parties, access), anonymization, blocking, deletion, destruction.
6.6. The User’s Personal Data will be stored on electronic media. In processing the Personal Data for the purpose of processing (considering) the User’s application (questionnaire), the Operator may retrieve the Personal Data and store them on physical media. The Personal Data storage will be carried out until their destruction by the Operator (in case the User withdraws his consent to the Personal Data Processing) or until the expiration of the term of such consent whichever is the earlier.
6.7. The Operator is entitled to transfer the User’s Personal Data to third parties in the following events:
6.7.1. The User has consented to such acts.
6.7.2. Such transfer is required for the User using a particular service/resource or for the performance of a particular agreement or contract with the User.
6.7.3. The transfer is provided for by Russian or any other applicable law within the framework of the procedure prescribed by law.
7. USER’S RIGHTS
7.1. The User will decide that his Personal Data be provided and give his consent to their processing freely, of his own volition and in his own interest. The User will consent to the Personal Data Processing as per the procedure described in Section 4 above.
7.2. The User is entitled to obtain the information from the Operator regarding his Personal Data Processing.
7.3. The User is entitled to make his requests and claims to the Operator, including those related to the use of his Personal Data and withdrawal of his consent to the Personal Data Processing as per the procedure described in Clause 4.4 above.
7.4. The User may also exercise any other rights contemplated by the legislation of the Russian Federation in the area of personal data.
8. OBLIGATIONS OF PARTIES
8.1. The User is obligated to:
8.1.1. Provide the Personal Data information required for the Foundation to consider the User’s application (questionnaire) for participation in the Charitable Program.
8.1.2. Update and supplement the Personal Data information that has been furnished in case of a change in such information.
8.2. The Operator is obligated to:
8.2.1. Use the received information solely for the purposes set out in this Policy.
8.2.2. Cause the confidential information to be kept under seal of secrecy, do not disclose the Personal Data to third parties and do not distribute the same without the consent of the User.
8.2.3. Take measures for protecting the confidentiality of the User’s Personal Data in accordance with the procedure that is usually used for the protection of such information in the existing business intercourse.
8.2.4. Block the Personal Data relating to the corresponding User upon the request of the User or his legal representative or the authorized body in charge of protection of the rights of Personal Data subjects for the period of check in case unreliable Personal Data or unlawful acts are detected.
9. MEASURES TO BE TAKEN FOR PROTECTING PERSONAL DATA
9.1. The Operator will take necessary and sufficient legal, organizational and technical measures for protecting the information furnished by the Users from unlawful or occasional access, destruction, change, blocking, copying, distribution, as well as any other illicit acts of third parties with regard thereto.
Such acts, in particular, include:
— Appointment of a person responsible for the Personal Data Processing;
— Organizational (including, but not limited to, the limitation of the number of the Foundation’s employees having access to the Personal Data) and technical measures for securing the Personal Data safety when they are processed in the information systems;
— Control of the facts of unauthorized access to the Personal Data and arrangements for the prevention of such incidents in future;
— Control over the measures taken for ensuring the Personal Data safety and over the level of protection of the Personal Data information systems.
10. LIABILITY
10.1. For a breach of the procedure for treating the Personal Data, the Operator will be liable pursuant to the legislation of the Russian Federation.
10.2. In the event of loss or disclosure of the confidential information, the Operator will be not liable if this confidential information:
10.2.1. Became the public domain prior to its loss or disclosure.
10.2.2. Was received from a third party before being received by the Operator.
10.2.3. Was disclosed with the consent of the User.
11. CONCLUSIVE PROVISIONS
11.1. The Foundation is entitled to amend this Policy without the consent of the User. The User is bound to review the text of this Policy every time he newly uses the Website.
11.2. A new Confidentiality Policy will take effect as of the date it is published on the Website, unless otherwise provided for by the Confidentiality Policy as amended. The continued use of the Website or its services or resources after the publication of the Confidential Policy as amended means that this Policy and its terms and conditions are accepted by the User.
11.3. The current version of this Policy is always posted on the Website page at: https://www.wcao.fund.
11.4. This Policy and relationships between the User and the Operator will be governed by the current legislation of the Russian Federation.
12. OPERATOR’S PARTICULARS
| Full name | We Compete as One Charity Foundation |
| Address | 123056, Moscow, Krasina st., 27, building 2, room 1/С |
| Registering authority, date of registration | Directorate of the Federal Tax Service for the City of Moscow, 28.04.2022 |
| Email address | info@wcao.fund |
| Contact telephone number | 8 (800) 350-32-95 |
| OGRN/INN/KPP | 1227700251371/ 9703086110/ 770301001 |
| Person entitled to act without power of attorney | Rufova Elena Viktorovna (General Director) |