Approval date: “26” March 2026
1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter — the Policy) has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”, as well as other regulatory legal acts of the Russian Federation in the field of personal data.
1.2. This Policy defines the procedures for processing and measures to ensure the security of personal data taken by the Association of Ethnocultural Centers and Heritage Preservation Organizations “ECHO” (hereinafter — the Association, the Operator) in order to protect the rights and freedoms of individuals and citizens when processing their personal data.
1.3. The personal data operator is:
Association of Ethnocultural Centers and Heritage Preservation Organizations “ECHO”
Legal address: 185035, Republic of Karelia, Petrozavodsk, Lenin Square, 2
OGRN: 1141000001009
INN: 1001992649
KPP: 100101001
OKPO: 24804341
Director: Marina Vladimirovna Pyryakova, acting on the basis of the Charter.
1.4. This Policy applies to all information that the Operator may obtain about users:
- of the website https://etnoecho.ru/ and its sections, including https://etnoecho.ru/en/;
- of the Operator’s official communities on the VKontakte social network, including:
- when registering for events, workshops, meetings, lectures, exhibitions, festivals, and other projects;
- when contacting by phone, email, through the website, contact forms, community messages, and other communication channels.
1.5. This Policy is subject to publication and is freely available on the Internet.
2. Key Terms
For the purposes of this Policy, the following terms are used:
- personal data — any information relating directly or indirectly to an identified or identifiable individual;
- operator — a person who independently or jointly with others organizes and/or carries out the processing of personal data;
- processing of personal data — any action (operation) or set of actions performed on personal data;
- automated processing of personal data — processing of personal data using computer technology;
- personal data subject — an individual to whom the personal data relates;
- cookies — small text files stored on the user’s device when visiting a website.
3. Purposes of Personal Data Processing
The Operator processes personal data for the following purposes:
3.1. Ensuring website functionality
- ensuring proper operation of the website;
- ensuring website security;
- analyzing traffic;
- improving the structure, content, and functionality of the website.
3.2. Processing inquiries and communication
- processing incoming inquiries, messages, applications, and requests;
- providing feedback;
- interaction with users, event participants, partners, and other persons.
3.3. Organization and conduct of events
- registration and enrollment for workshops, meetings, lectures, excursions, exhibitions, festivals, and other events;
- communication with participants;
- organizational support of events;
- compiling participant lists.
3.4. Informational activities of the Association
- informing about the activities of the Association;
- publishing news, announcements, programs, materials, and reports;
- promotion of cultural, educational, and socially significant projects.
3.5. Compliance with the legislation of the Russian Federation
- fulfillment of obligations established by the legislation of the Russian Federation;
- protection of the rights and legitimate interests of the Operator.
4. Categories of Personal Data Subjects
The Operator may process personal data of the following categories of subjects:
- website users;
- visitors and subscribers of the Association’s official communities;
- persons who submitted inquiries;
- participants of events, workshops, programs, and projects;
- representatives of partner organizations;
- craftspeople, speakers, curators, experts, volunteers;
- other persons interacting with the Association within its statutory activities.
5. List of Processed Personal Data
5.1. When contacting the Association
The Operator may process:
- last name, first name, patronymic (if any);
- phone number;
- email address;
- content of the inquiry;
- other information voluntarily provided by the personal data subject.
5.2. When registering for events / workshops / projects
The Operator may process:
- last name, first name;
- phone number;
- email address (if provided);
- information necessary to organize participation;
- other data voluntarily provided by the user.
5.3. When using the website
The Operator may process:
- IP address;
- cookies;
- information about the browser, device, and operating system;
- date and time of visit;
- visited page addresses;
- referral source;
- user actions on the website;
- other technical and analytical data.
5.4. In communities and social networks
The Operator may process:
- profile name / nickname;
- information contained in the user’s message;
- contact details if voluntarily provided;
- other data submitted by the user on their own initiative.
The Operator does not process personal data that is not related to the stated purposes of processing.
6. Legal Grounds for Personal Data Processing
The Operator processes personal data on the following legal grounds:
- consent of the personal data subject;
- necessity of processing for carrying out the statutory activities of the Association;
- necessity of processing to organize the subject’s participation in events and projects;
- necessity for the performance of a contract or actions initiated by the subject;
- necessity to fulfill obligations предусмотренных законодательством Российской Федерации;
- other grounds provided for by the legislation of the Russian Federation.
7. Procedure and Conditions for Personal Data Processing
7.1. Personal data processing is carried out both with and without the use of automation tools.
7.2. The Operator has the right to perform the following actions with personal data:
- collection;
- recording;
- systematization;
- accumulation;
- storage;
- clarification (updating, modification);
- retrieval;
- use;
- transfer (provision, access);
- anonymization;
- blocking;
- deletion;
- destruction.
7.3. Personal data processing is carried out in compliance with the following principles:
- legality and fairness;
- limitation of processing to the achievement of specific, predetermined, and lawful purposes;
- prevention of processing incompatible with the purposes of data collection;
- avoidance of excessive personal data;
- ensuring accuracy, sufficiency, and relevance of data;
- storage of data no longer than required for processing purposes.
8. Personal Data Processing on the Website. Cookies and Analytics
8.1. The Operator’s website uses cookies and similar technologies.
8.2. Cookies are used for the following purposes:
- ensuring proper operation of the website;
- saving user preferences;
- analyzing traffic and user activity;
- improving the quality and usability of the website.
8.3. The website may use Yandex Metrica and other similar web analytics services.
8.4. Using these services, the following may be collected:
- IP address;
- cookie identifiers;
- information about user actions on the website;
- device and browser parameters;
- data about visited pages and visit time;
- other technical data.
8.5. The user may change cookie settings in their browser, including blocking or deleting cookies. In this case, some website functions may not work correctly.
8.6. Continued use of the website after the cookie notification is displayed, as well as actions предусмотренные интерфейсом сайта, means the user’s consent to the use of cookies and processing of relevant data in accordance with this Policy.
9. Sources of Personal Data
The Operator obtains personal data:
- directly from the personal data subject;
- through website forms;
- via email;
- by phone;
- through social media community messages;
- through event registration;
- automatically when using the website.
10. Transfer of Personal Data to Third Parties
10.1. The Operator may transfer personal data to third parties only in the following cases:
- if such transfer is necessary to achieve processing purposes;
- if the subject has given consent;
- if such obligation is provided for by the legislation of the Russian Federation.
10.2. Personal data may be transferred to:
- employees and authorized representatives of the Association;
- organizers, curators, masters, speakers, event hosts — only to the extent necessary to organize participation;
- contractors providing website operation, hosting, email, analytics, and other technical services;
- state authorities in cases предусмотренных законодательством Российской Федерации.
10.3. The Operator does not disseminate personal data without a legal basis.
11. Cross-border Transfer of Personal Data
11.1. The Operator does not carry out cross-border transfer of personal data, except in cases where it is objectively necessary for the functioning of certain technical services or is directly permitted by the legislation of the Russian Federation.
11.2. If such transfer is required, the Operator acts in accordance with the legislation of the Russian Federation.
12. Terms of Processing and Storage of Personal Data
12.1. Personal data is processed and stored no longer than required for processing purposes, unless otherwise established by the legislation of the Russian Federation.
12.2. Personal data is subject to deletion or destruction:
- upon achievement of processing purposes;
- when the need to achieve processing purposes is lost;
- upon withdrawal of consent by the personal data subject, if there are no other legal grounds;
- in other cases предусмотренных законодательством.
12.3. Approximate storage periods:
- user inquiries — up to 3 years after correspondence ends;
- event applications — up to 1 year after the event;
- analytical and technical website data — within the limits established by the services used and internal processing purposes.
13. Rights of the Personal Data Subject
The personal data subject has the right to:
- receive information about the processing of their personal data;
- require clarification, blocking, or destruction of their personal data;
- withdraw consent to personal data processing;
- appeal actions or inaction of the Operator to the authorized body or in court;
- exercise other rights provided for by the legislation of the Russian Federation.
14. Procedure for обращения Personal Data Subject
14.1. To exercise their rights, the personal data subject may send a request to the Operator:
Postal address: 185035, Republic of Karelia, Petrozavodsk, Lenin Square, 2
Email for requests: etnoecho@etnoecho.ru
14.2. It is recommended to include in the request:
- full name;
- contact details;
- a description of the request;
- information allowing identification of the applicant.
15. Measures to Ensure Personal Data Security
15.1. The Operator takes necessary and sufficient legal, organizational, and technical measures to protect personal data, including:
- restricting access to personal data;
- appointing a person responsible for organizing personal data processing;
- adopting internal regulatory acts;
- using passwords, antivirus protection, backups;
- monitoring compliance with legal requirements;
- preventing unauthorized access to data.
15.2. The Operator ensures the protection of personal data in accordance with the legislation of the Russian Federation.
16. Use of Social Networks
16.1. The Operator carries out informational and organizational activities through official communities, including:
16.2. By sending a message, application, comment, or other information through social networks, the user agrees to the processing of their personal data to the extent necessary to respond, communicate, or organize participation in an event.
16.3. This Policy applies to personal data received and further processed by the Operator in connection with such interaction.
17. Final Provisions
17.1. This Policy is valid indefinitely until replaced by a new version.
17.2. The Operator has the right to make changes to this Policy. The new version comes into force from the moment it is published on the website, unless otherwise provided by the new version.
17.3. The current version of the Policy is freely available on the website: https://etnoecho.ru/