This Privacy Policy for processing personal data has been created in accordance with the requirements of the Dutch Personal Data Protection Act of July 6, 2000 (hereinafter referred to as the "Personal Data Act") and defines the procedures for processing personal data and measures taken to ensure the security of personal data by the Open Affect Holdings International B.V. (hereinafter referred to as the "Operator").
1.1. The Operator considers compliance with human and civil rights and freedoms regarding the processing of personal data, including the right to privacy, personal and family confidentiality, as its primary objective and condition for its activities.
1.2. This Privacy Policy (hereinafter referred to as the "Policy") applies to all information the Operator may obtain about visitors to the website https://wulfra.me.
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except when processing is necessary to clarify personal data).
2.3. Website — a set of graphical and informational materials, as well as software and databases, ensuring their availability on the internet at the network address https://wulfra.me.
2.4. Information system of personal data — a set of personal data contained in databases and ensuring their processing through information technologies and technical means.
2.5. Anonymization of personal data — actions that make it impossible to identify a User or another subject of personal data without additional information.
2.6. Processing of personal data — any action or set of actions performed with or without the use of automation tools concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal or natural person, independently or jointly with others organizing and/or performing the processing of personal data and determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information directly or indirectly related to an identified or identifiable User of the website https://wulfra.me.
2.9. Personal data authorized for dissemination — personal data that the subject of personal data has authorized for public access by providing consent for their processing as stipulated by the Personal Data Act (hereinafter referred to as "publicly available personal data").
2.10. User — any visitor to the website https://wulfra.me.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of people.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an undefined group of people (transferring personal data) or making personal data available to an unlimited group of people, including publication in the media, posting 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 a foreign country, a foreign government body, 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 recovering their content in the personal data information system and/or the destruction of the physical carriers of personal data.
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4.1. Processing is conducted lawfully and fairly.
4.2. Processing is limited to specific, predefined, and lawful purposes.
4.3. Only personal data relevant to the stated purposes are processed.
4.4. Accuracy and sufficiency of personal data are ensured during processing.
4.5. Personal data are stored no longer than required for the processing purposes unless otherwise stipulated by law.
| Purpose of Processing | Providing User access to services, information, and materials on the website |
|---|---|
| Personal Data |
|
| Legal Basis |
|
| Types of Processing |
|
7.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the fulfillment of functions, powers, and obligations assigned to 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 court ruling, or an act of another authority or official, subject to enforcement under the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, a beneficiary, or a guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the operator's or third parties' rights and legitimate interests or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data) are subject to processing.
7.7. Personal data are processed if their publication or mandatory disclosure is required by federal law.
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or when the personal data subject provides consent for the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address support@wulfra.me with the subject "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 otherwise specified by the contract or current legislation.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at support@wulfra.me with the subject "Revocation of Consent for Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties in accordance with their User Agreements and Privacy Policies. The personal data subject must familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including those mentioned in this clause.
8.6. Restrictions set by the personal data subject on the transfer (except for granting access) or processing conditions (except for obtaining access) of personal data authorized for dissemination do not apply in cases of processing personal data in public, governmental, or other significant public interests as determined by the laws of the Netherlands.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required for the purposes of processing personal data unless a longer storage period is established by federal law, a contract, or other applicable agreements.
8.9. The termination of personal data processing may occur upon achieving the processing purposes, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject, or upon a request to cease the processing of personal data, as well as when illegal processing of personal data is identified.
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunications networks or without them.
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
The Operator and other persons who have obtained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject unless otherwise provided by federal law.
12.1. The User can obtain any clarifications on issues of interest related to the processing of their personal data by contacting the Operator via email at support@wulfra.me.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at the following address: https://wulfra.me/?do=privacy_policy.