1. General ProvisionsThis Personal Data Processing Policy is drafted in accordance with Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”), and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by NextUp (hereinafter referred to as the “Operator”).

1.1. The Operator considers the protection of human and civil rights and freedoms in the processing of personal data — including the protection of the right to privacy, personal and family confidentiality — to be a top priority and essential condition of its operations.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors of the website https://www.nextupmedia.ru.

2. Key Terms Used in This Policy2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of processing of personal data (except where processing is necessary to update such data).

2.3. Website – a collection of graphical and informational materials, as well as software and databases, accessible online at: https://www.nextupmedia.ru.

2.4. Personal data information system – a set of databases containing personal data and information technologies used for their processing.

2.5. Depersonalization of personal data – actions making it impossible to identify a specific User or subject without additional information.

2.6. Processing of personal data – any action or set of actions performed with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.

2.7. Operator – a government body, municipal authority, legal or natural person that organizes and/or carries out processing of personal data, determines the purposes, scope, and actions related to such data.

2.8. Personal data – any information directly or indirectly related to an identified or identifiable User of the website.

2.9. Personal data allowed by the subject for dissemination – data made publicly accessible by the data subject through explicit consent in accordance with the Personal Data Law.

2.10. User – any visitor of the website https://www.nextupmedia.ru.

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

2.12. Dissemination of personal data – any actions aimed at disclosing data to an indefinite number of people or making it publicly available.

2.13. Cross-border transfer of personal data – transfer of personal data to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data – actions leading to the permanent and irreversible elimination of personal data.