Personal Data Processing Policy

This Personal Data Processing Policy (the Policy) sets out the purposes, conditions and procedure for processing the personal data that the operator receives through the website drkamilgadzhiev.ru (the website), and the measures taken to protect it. The Policy has been drawn up in accordance with Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (Law No. 152-FZ).

The Policy is published on the website in open access (Article 18.1(2) of Law No. 152-FZ).

The Policy applies to personal data that users submit through the website forms, to the technical data listed in section 11, and to patient materials published on the website (section 8).

The Policy does not apply to third-party websites and services linked from the website (social media, map services), or to medical records kept when medical care is provided at a medical organisation. Requests and submissions sent through the website are not medical records.

The texts of the consents a user gives when submitting the forms are published on the “Consent to the processing of personal data” page. Consent to the processing of personal data is given separately from acknowledging the Policy and from any other consent.

Key terms used in the Policy:

personal data — any information relating to a directly or indirectly identified or identifiable individual (the data subject);

processing of personal data — any action or set of actions performed with personal data, with or without automation, including collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer (dissemination, provision, access), depersonalisation, blocking, deletion and destruction;

dissemination of personal data — actions aimed at disclosing personal data to an indefinite range of persons;

provision of personal data — actions aimed at disclosing personal data to a specific person or a specific range of persons;

special categories of personal data — including data concerning health (Article 10 of Law No. 152-FZ);

cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign public authority, a foreign individual or a foreign legal entity.

The operator of the personal data received through the website is Kamil Farukhovich Gadzhiev, an individual, plastic surgeon (the operator). The operator is personally responsible for organising the processing of personal data.

Address for written requests concerning personal data processing: 56 Michurinsky Prospekt, bldg. 1, Moscow 119192.

Contact email for personal data matters: zero0564@mail.ru.

Medical care is provided at the MEDSI clinic, an independent medical organisation, at 56 Michurinsky Prospekt, bldg. 1, Moscow 119192. Medical care, its payment and medical records are governed by the patient's separate relationship with the clinic; the clinic processes the personal data it handles when providing medical care as an independent operator under its own rules. This Policy does not apply to such processing.

The website drkamilgadzhiev.ru is the doctor's personal website. It is not the official website of the MEDSI clinic; the MEDSI clinic does not own the website and is not the operator of the personal data received through it.

The operator may:

obtain from the data subject accurate information needed to consider their request;

entrust the processing of personal data to another person with the data subject's consent, unless otherwise provided by federal law, on the basis of a contract (Article 6(3) of Law No. 152-FZ);

continue processing personal data without the data subject's consent where Law No. 152-FZ provides grounds for this.

The operator must:

process personal data only for the purposes stated in the Policy and to the extent necessary to achieve them;

provide the data subject, on request, with information about the processing of their personal data and respond to requests within the periods stated in section 13;

take legal, organisational and technical measures to protect personal data (section 12);

stop processing and destroy personal data in the cases and within the periods provided for by Law No. 152-FZ (section 9);

ensure that the recording, systematisation, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the Russian Federation (Article 18(5) of Law No. 152-FZ);

notify Roskomnadzor in the cases and within the periods provided for by Law No. 152-FZ — including of the intention to process personal data (Article 22) and of incidents resulting in unlawful or accidental transfer of personal data (Article 21(3.1)).

The data subject has the right to:

obtain information concerning the processing of their personal data, including: confirmation of the fact of processing; the legal grounds and purposes of processing; the methods of processing used; the name and location of the operator; the personal data processed and its source; the periods of processing, including storage periods; information on cross-border transfer; information on any person processing data on the operator's behalf (Article 14(7) of Law No. 152-FZ);

demand that their personal data be clarified, blocked or destroyed if it is incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;

demand that the processing of their personal data be stopped;

withdraw their consent to processing and their consent to dissemination of personal data;

appeal against the operator's actions or omissions to the authority for the protection of the rights of personal data subjects or in court (Article 17 of Law No. 152-FZ).

The operator processes the personal data of the following persons:

website visitors — to the extent of the technical data listed in section 11;

users who have sent a consultation request;

authors of reviews and questions to the surgeon;

persons who have applied to take part in the Case of the Month project;

patients whose photographs, videos and stories are published on the website;

persons who have contacted the operator about the processing of personal data;

the operator's authorised persons who handle requests in the website's administrative panel.

Consultation request: name; phone number. Automatically — the interface language and the page from which the request was sent. The request form is intended only for contacting the user by phone: it does not ask for diagnoses, information on illnesses or contraindications, or medical documents.

Review: name; rating; review text; optionally — the procedure, a photograph and a note that the author would like the review published.

Question to the surgeon: name; procedure; question text; the doctor's answer; a note of consent to publication, if given.

Application to take part in the Case of the Month project: name; phone number; one or several categories (face, breast, body); a short description needed to get in touch; confirmation that the applicant is 18 or older; an application number in the format KM-XXXX-XXXX and its status. Photographs and detailed medical information are not collected through the form.

Patient materials published on the website: photographs (including “before” and “after”), videos, information on the procedure performed, the patient's story — to the extent permitted by the patient (section 8).

Requests concerning the processing of personal data: the information the data subject provides in the request, including the information required under Article 14(3) of Law No. 152-FZ.

The operator's authorised persons: the administrative panel account login and records of actions taken in it (section 11).

Data concerning health belongs to the special categories of personal data (Article 10 of Law No. 152-FZ). The website forms do not ask for it. If a user provides such data on their own initiative (for example, in the text of a review or question, or in an application description), it is used only to consider their request, is not published without their separate written consent and is destroyed as described in section 9. Please do not include in the forms any information that is not needed to consider your request.

Data concerning health that a user has provided in a question to the surgeon or in an application to the Case of the Month project is considered by a doctor — a person professionally engaged in medical activity and obliged to keep medical confidentiality (Article 10(2)(4) of Law No. 152-FZ). Such data is used only to consider the request.

Photographs are not used to establish identity and are not processed as biometric personal data.

Purposes of processing:

to contact the user by phone regarding their request and arrange a consultation. The phone number is used only for matters directly related to the request: clarifying the request, agreeing on a time, confirming the consultation. Consent to processing data in order to be contacted about a request is not consent to receive advertising;

to consider an application to take part in the Case of the Month project, contact the applicant and report the application status by its number;

to consider a review and pass it on to the doctor; to publish a review — only under the conditions of section 8;

to consider a question, prepare the doctor's answer and publish the question with the answer on the basis of the author's separate consent to dissemination (section 8);

to publish patient materials on the website — under the conditions of section 8;

to handle requests from data subjects;

to ensure the security of the website and the administrative panel.

Personal data from the website forms is not used for advertising mailings and is not passed on to advertising networks.

Legal grounds of processing:

the data subject's consent to processing (Article 6(1)(1) of Law No. 152-FZ). Consent is given by ticking a separate box before submitting a form; a form is not accepted without it. Acknowledging the Policy is not part of the consent. The date, time and version of the text under which consent was given are stored together with the consent;

for dissemination (publication) of personal data — a separate consent to dissemination (Article 10.1 of Law No. 152-FZ): in the question form — by a separate box without which the question is not sent (the doctor's answer is given by publication on the website); for reviews, patient materials and Case of the Month materials — by a written document signed by the patient (section 8);

for data concerning health published as part of patient materials — the patient's written consent (Article 10(2)(1) of Law No. 152-FZ) and their consent to the disclosure of information constituting medical confidentiality (Article 13(3) of Federal Law No. 323-FZ of 21 November 2011);

processing is also carried out in accordance with the Constitution of the Russian Federation, Law No. 152-FZ, Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Protection of Information”, Federal Law No. 323-FZ of 21 November 2011 “On the Fundamentals of Health Protection of Citizens in the Russian Federation” and Russian Government Resolution No. 1119 of 1 November 2012 “On approval of requirements for the protection of personal data when processed in personal data information systems”.

Personal data is published on the website only with a consent to dissemination given separately from any other consent (Article 10.1(1) of Law No. 152-FZ). Silence or inaction is not considered such consent (Article 10.1(8) of Law No. 152-FZ). Refusing consent to publication does not affect the ability to book a consultation and receive medical care.

Reviews. A review is never published automatically. It is published only after review and only if publication of the review is permitted in a written document signed by the patient (consent to dissemination); the operator checks that such a document exists before publication. The box “I would like my review to be published” in the form expresses a wish only and is not consent to dissemination. Without such a document or in case of doubt, the review is not published. The review text and rating are published, and the name, procedure and photograph — only if the document permits it; the date of publication is shown under the review.

Questions to the surgeon. The questions section is public: the form does not ask for contact details, and the author sees the doctor's answer on the website. A question is therefore sent together with a separate consent to dissemination; without it the question is not accepted. A question is published after review and the doctor's answer; the procedure, the question text and the doctor's answer are published, the author's name is not. For a personal question that should not be published, please use the consultation request form.

Case of the Month. Only persons aged 18 or over may take part in the project. The website form is used only to apply; the application is not published. Materials of a participant selected for the project are published only after a separate written consent has been executed with them, listing the specific materials and information permitted for publication. Information on treatment results constitutes medical confidentiality and is published only with the patient's written consent to its disclosure (Article 13(3) of Federal Law No. 323-FZ).

Patient materials — photographs (including “before” and “after”), videos, video stories, patient stories, reviews, information on the procedure (operation) performed and on treatment results — are published only with the patient's prior written consent executed as a document signed by them. The exact scope of permission — categories of materials and information, platforms (the website drkamilgadzhiev.ru, social media) and purposes (including advertising use) — is determined by that document. Permission for one category or platform does not extend to others: permission to publish on the website does not mean permission to publish on social media or in advertising; permission for a photograph does not extend to video; permission for a review does not extend to disclosing information about a medical intervention. The document separately covers the processing of personal data, its dissemination (Article 10.1 of Law No. 152-FZ), the use of the person's image (Article 152.1 of the Civil Code of the Russian Federation) and the disclosure of information constituting medical confidentiality (Article 13(3) of Federal Law No. 323-FZ). Without the relevant permission a material is not published. Earlier publication of a material on social media is not in itself consent to its publication on the website.

Consents that a user gives in the website forms are not consent to the publication of patient materials. Publication of patient materials on social media and their use in advertising are allowed only if the relevant platforms and advertising use are expressly permitted in the document signed by the patient. A patient's consent does not exempt advertising from the requirements of advertising law.

Information on the conditions of processing of personal data permitted by the data subject for dissemination, and on any prohibitions and conditions set by the data subject, is posted on the “Consent to the processing of personal data” page in the section on the conditions of dissemination no later than three working days after the relevant consent is received (Article 10.1(10) of Law No. 152-FZ).

In the consent to dissemination the data subject may prohibit the transfer of personal data to an indefinite range of persons and prohibit or set conditions on its processing by an indefinite range of persons (Article 10.1(9) of Law No. 152-FZ). To do so, send them to zero0564@mail.ru. Refusal to accept such prohibitions and conditions is not permitted.

Dissemination stops at any time at the data subject's request. The request must contain the surname, first name, patronymic (if any), contact details (phone number, email address or postal address) and the list of personal data whose processing is to be stopped (Article 10.1(12) of Law No. 152-FZ). The consent to dissemination ceases to have effect from the moment the request is received (Article 10.1(13) of Law No. 152-FZ); the operator stops dissemination without undue delay: the material is hidden from the website, after which its files and copies are deleted. The request can be sent to zero0564@mail.ru or to the address for written requests (section 13).

Personal data is stored no longer than necessary to achieve the purposes of processing, unless a different period is established by Russian law or another lawful ground for processing:

consultation requests — until work on the request is completed (contacting the user, booking the consultation or the user declining it);

questions to the surgeon — until the question is considered and answered, and published ones — while the consent to dissemination is in effect;

reviews — until the review is considered, and published ones — while the consent to dissemination is in effect;

applications to the Case of the Month project — until a decision on participation is made; materials of a project participant — while their written consent is in effect;

patient materials published on the website — while the patient's consent is in effect;

the administrative panel action log (section 11) — 1 year from the date of the entry;

backups — 30 days from the date on which the relevant backup was created. Upon expiry of this period, the backup is automatically deleted. Data deleted from the main website database or file storage may remain in previously created backups until the applicable retention period expires. Backups are used solely to restore the website in the event of a failure or data loss;

signed consent documents (written consents of patients, including participants of the Case of the Month project) — for the term of the consent and three years after it ends or is withdrawn — to protect the rights of the operator and the data subject in case of a dispute; the record of consent given through a website form (the fact of consent, date and time, the version of the consent text) is kept together with the request and destroyed together with it.

These periods do not apply to medical records: their storage periods are set by health protection law.

When the data subject or their representative, or Roskomnadzor, reports that personal data is inaccurate or processed unlawfully, the operator blocks the relevant personal data from the moment of such request for the period of verification, including at any person processing it on the operator's behalf (Article 21(1) of Law No. 152-FZ).

Inaccurate personal data is corrected within 7 working days of the submission of information confirming the inaccuracy (Article 21(2) of Law No. 152-FZ).

If unlawful processing is identified, the operator stops it within no more than three working days; if the processing cannot be made lawful, the personal data is destroyed within no more than ten working days of the date it was identified (Article 21(3) of Law No. 152-FZ).

Once the purpose of processing has been achieved, the operator stops processing the personal data and ensures its destruction within no more than 30 days of the date the purpose was achieved, unless otherwise provided by Russian law, a contract or another lawful ground for continued processing. The same applies to data whose legal ground for processing has ceased.

If consent to processing is withdrawn, the operator stops processing the personal data and ensures its destruction within 30 days of receipt of the withdrawal, if its retention is no longer required for the purposes of processing and there are no other grounds under Russian law for further processing (Article 21(5) of Law No. 152-FZ).

If personal data cannot be destroyed within the established period, it is blocked and destroyed within no more than six months, unless a different period is established by federal law (Article 21(6) of Law No. 152-FZ).

Personal data is processed with the use of automation. Data from the website forms is received only by the website server and stored in a database and a private file storage located in the Russian Federation.

The website, its database and file storage are hosted on computing resources (a virtual server and object storage) provided to the operator by Limited Liability Company "Beget" (OOO "Beget", TIN 7801451618, PSRN 1077847645590; address: office 726A, 8B Karla Faberzhe Square, St Petersburg, 195112, Russia) under a services contract. The website's servers, database and file storage are located in the Russian Federation (St Petersburg).

To protect against data loss, the operator performs backups of the website data. Backups are stored in encrypted form in private object storage provided to the operator by OOO "Beget". The storage is located in the Russian Federation (St Petersburg).

The contents of the backups, their retention period and the security measures applied are set out in Sections 9 and 12 of this Policy.

Requests from the website form go to the website's closed administrative panel; the consultation coordinator or a manager contacts the user by phone at the number they provided.

Requests and submissions in the closed administrative panel are accessible to the operator and the person authorised by the operator — the consultation coordinator. To book the user in for a consultation, the coordinator gives the managers who handle patient requests the information needed to contact the user (name, phone number, procedure of interest) — only orally (by phone or in person). The coordinator and the managers process personal data on the operator's instructions under instruction agreements (Article 6(3) of Law No. 152-FZ) and must keep personal data confidential. Administrative panel accounts are individual; they are issued only to those who need access to perform their duties and are disabled when their authority ends.

External contractors are given access to personal data only where there is a legal ground and, where required, an instruction to process personal data (Article 6(3) of Law No. 152-FZ).

The website is not technically connected to the MEDSI clinic and is not its technical interface. There is no integration with the MEDSI clinic's information systems. The operator and the persons authorised by the operator do not transfer personal data received through the website to the MEDSI clinic.

Data from the website forms is not transferred to messengers, social media, analytics or advertising systems. Cross-border transfer of personal data, if carried out, is carried out only in compliance with Article 12 of Law No. 152-FZ.

Personal data is not sold and is not passed on to third parties for advertising purposes. It may be provided to authorised public authorities in the cases provided for by Russian law.

The website does not offer sending requests via messengers: a consultation request is submitted only through the website form. If a user, on their own initiative, writes to the operator via third-party messengers or social networks, the conversation takes place on those services and is governed by their rules; please do not send medical documents or health information through them.

The contacts page shows a Yandex Maps map (YANDEX LLC, Russia). When the map loads, the visitor's browser contacts the servers of this service, which receive the IP address and technical information about the browser; this data is processed under the rules of the Yandex Maps service, not on the operator's instructions. The “Build route” button also opens the Yandex Maps service.

The website does not set cookies for visitors and uses no analytics or advertising counters. The embedded Yandex Maps map on the contacts page may set the service's own cookies under its rules.

A technical cookie is used only in the administrative panel — for authorised persons to sign in.

To protect the forms, the Case of the Month status check and the administrative panel sign-in from abuse, the server temporarily takes the sender's IP address into account in memory. The IP address is not stored with the submitted forms.

The administrative panel keeps an action log: on sign-in, sign-out, viewing and changing records, the account, the action, the type and number of the record, the IP address and the time are stored. On a failed sign-in attempt the IP address and time are stored, and the login entered — only if such an account exists. Passwords are never written to the log.

The website's server keeps a technical request log: the IP address, date and time, request method and the address of the requested page without parameters, and the response code and time. Browser information (User-Agent) and the address of the referring page (Referer) are not logged. The log is used to keep the website secure and operational, is kept for no more than 14 days and is then deleted automatically.

The operator personally organises the processing of personal data and monitors compliance with the Policy.

Only authorised persons have access to requests, through individual accounts. Passwords are stored only as secure hashes; the number of failed sign-in attempts is limited; sessions are time-limited; when an account is disabled its sessions end immediately; actions in the administrative panel are logged.

The visitor's browser never accesses the database directly: data is received and served only by the website server. Consent is checked on the server: a form is not accepted without it. Publishing a review, a question or Case of the Month materials without a record that the relevant consent has been checked is technically impossible.

Photographs are stored in private storage with no public access: visitors see only published materials. Uploaded files are checked by their content; service metadata (including location, date taken and device information) is automatically removed from photographs.

A Case of the Month application number only allows checking the status: the website returns the number, the status and the date it changed, without disclosing any other data.

Backups. A website data backup is created automatically every day. It includes a logical copy of the PostgreSQL database, including the administrative panel activity log, photographs from the private file storage, and the server settings required for recovery. The technical request log referred to in Section 11 of this Policy is not included in backups.

The backup is encrypted on the website server before being transferred to object storage using the age encryption tool. Only the encrypted copy is transferred to the storage. The decryption private key is kept by the operator and is not stored on the website server or by the provider. The backup storage is not publicly accessible and uses separate access credentials.

Automatic server backups provided by the hosting provider are not used.

Before technical maintenance, the operator may, where necessary, create a temporary server snapshot using the provider's tools. Such a snapshot is used solely for operational recovery in connection with the relevant maintenance work.

The ability to restore the website from a backup has been verified by actually restoring data into an isolated environment.

Data transmitted between the browser and the website is protected by encryption (HTTPS).

Send requests, demands and consent withdrawals to zero0564@mail.ru or in writing to: 56 Michurinsky Prospekt, bldg. 1, Moscow 119192 (marked “For K. F. Gadzhiev, personal data”).

A request for information must contain the number of the main identity document of the data subject or their representative, the date of issue of that document and the issuing authority, information confirming the data subject's relationship with the operator (for example, the date the form was submitted or the Case of the Month application number) and the signature of the data subject or their representative. The request may be sent as an electronic document signed with an electronic signature (Article 14(3) of Law No. 152-FZ).

Information is provided within 10 working days of receipt of the request. This period may be extended by no more than 5 working days with a reasoned notice stating the reasons for the extension.

A demand to stop processing is fulfilled within 10 working days of its receipt; this period may be extended by no more than 5 working days with a reasoned notice (Article 21(5.1) of Law No. 152-FZ).

When consent is withdrawn, processing stops and the data is destroyed within the periods stated in section 9. Publication is stopped as described in section 8.

Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor): 7 Kitaygorodsky Proezd, bldg. 2, Moscow 109992; information centre: +7 (495) 198-65-01; email: rsoc_in@rkn.gov.ru.

Roskomnadzor Office for the Central Federal District: 2 Starokashirskoye Shosse, bldg. 10, Moscow 115201; information line: +7 (495) 587-44-85; email: rsockanc77@rkn.gov.ru.

The Policy may be updated. A new version takes effect upon publication on this page.

The date of the latest change is shown at the beginning of the document. Changes affecting consents already given are not applied retroactively.

Matters not covered by the Policy are governed by Russian law.