Privacy Policy
- This personal data processing policy is drawn up in accordance with applicable data protection law and defines the procedure for processing personal data and the measures taken by SHO MEDIA (hereinafter the "Operator") to ensure the security of personal data.
- The Operator regards respect for the rights and freedoms of individuals when processing their personal data — including the protection of the right to privacy and personal and family confidentiality — as the most important goal and condition for carrying out its activities.
- This policy of the Operator regarding the processing of personal data (hereinafter the "Policy") applies to all information the Operator may obtain about visitors to the website shoteam.media.
2. Key Terms Used in the Policy
- Automated processing of personal data — processing of personal data using computing equipment.
- Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
- Website — the set of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the Internet at the network address shoteam.media.
- Personal data information system — a set of personal data contained in databases, as well as the information technologies and technical means that ensure their processing.
- Anonymization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine that particular personal data belongs to a specific User or other data subject.
- Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, whether or not using automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
- Operator — a state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, the scope of personal data subject to processing, and the actions (operations) performed with personal data.
- Personal data — any information directly or indirectly relating to an identified or identifiable User of the website shoteam.media.
- Personal data permitted by the data subject for distribution — personal data to which access has been granted to an unlimited number of persons by the data subject themselves, by giving consent to the processing of personal data permitted for distribution, in the manner provided for by applicable data protection law.
- User — any visitor to the website shoteam.media.
- Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
- Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at allowing an unlimited group of persons to become acquainted with personal data, including publishing personal data in the media, posting it on information and telecommunications networks, or otherwise providing access to personal data.
- Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign public authority, or to a foreign individual or legal entity.
- Destruction of personal data — any actions as a result of which personal data is irrevocably destroyed with no possibility of further restoring its content in the personal data information system, and/or the physical media containing personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive reliable information and/or documents containing personal data from the data subject;
- if the data subject withdraws consent to the processing of personal data, continue processing the personal data without the data subject's consent where grounds for doing so exist under applicable data protection law;
- independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations set out in personal data legislation and adopted regulatory acts, unless otherwise provided by applicable data protection law and/or other local and/or international laws.
3.2. The Operator is obliged to:
- provide the data subject, upon their request, with information relating to the processing of their personal data;
- organize the processing of personal data;
- respond to requests and inquiries from data subjects and their legal representatives;
- report necessary information to the authorized body for the protection of data subjects' rights upon its request;
- publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, or distribution of personal data, and from other unlawful actions in respect of personal data;
- cease the transfer (distribution, provision, access), cease processing, and destroy personal data in the manner and in the cases provided for by applicable data protection law;
- fulfill other obligations provided for by applicable data protection law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by applicable data protection law. Information is provided by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there are lawful grounds for disclosing such personal data;
- require the Operator to correct their personal data, or to block or destroy it, if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, and to take other measures provided by law to protect their rights;
- set a condition of prior consent for the processing of personal data for purposes of promoting goods, works, and services on the market;
- require the deletion of their personal data and withdraw consent to its processing. To do so, a request must be sent to the email address shoteam.media@gmail.com with the subject line "Deletion of personal data and withdrawal of consent to its processing";
- appeal against unlawful actions or omissions of the Operator in the processing of personal data to the authorized body for the protection of data subjects' rights, or in court;
- exercise other rights provided for by applicable data protection law.
4.2. Data subjects are obliged to:
- provide the Operator with accurate information about themselves;
- notify the Operator of any clarification (updating, modification) of their personal data;
- independently monitor and stay informed of current changes to this Policy.
Persons who have provided the Operator with inaccurate information about themselves, or information about another data subject without that person's consent, bear liability in accordance with applicable law.
5. Personal Data the Operator May Process
- email address;
- phone numbers.
The site also collects and processes anonymized data about visitors (including cookies) using web analytics services (Google Analytics and others).
The data listed above is collectively referred to throughout this Policy as Personal Data.
The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.
Processing of personal data permitted by the data subject for distribution, from among special categories of personal data, is permitted provided the prohibitions and requirements set out in applicable data protection law are observed.
The User's consent to the processing of personal data permitted for distribution is executed separately from other consents to the processing of their personal data.
The User provides consent to the processing of personal data permitted for distribution directly to the Operator.
The Operator is obliged, no later than three business days from the receipt of such consent from the User, to publish information about the conditions of processing, as well as any prohibitions and conditions regarding the processing of personal data permitted for distribution to an unlimited group of persons.
The transfer (distribution, provision, access) of personal data permitted by the data subject for distribution must be discontinued at any time at the request of the data subject.
Such a request must contain:
- the last name, first name, and patronymic (if applicable);
- contact information (phone number, email address, or postal address) of the data subject;
- a list of the personal data for which processing must be discontinued.
The personal data specified in such a request may only be processed by the Operator to whom it was sent.
Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in clause 10.6 of this Policy on the processing of personal data.
6. Principles of Personal Data Processing
The processing of personal data is carried out on a lawful and fair basis.
The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of its collection is not permitted.
The merging of databases containing personal data processed for incompatible purposes is not permitted.
Only personal data that corresponds to the purposes of its processing is subject to processing.
The content and scope of the personal data processed must correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of its processing is not permitted.
When processing personal data, the accuracy and sufficiency of the data is ensured, and, where necessary, its relevance to the purposes of processing. The Operator takes the necessary measures and/or ensures they are taken to delete or correct incomplete or inaccurate data.
Personal data is stored in a form that allows the data subject to be identified for no longer than is required by the purposes of processing, unless a longer storage period is established by law. Processed personal data is destroyed or anonymized once the purposes of processing have been achieved or the need to achieve those purposes no longer exists, unless otherwise provided by law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data is:
- informing the User by sending emails;
- providing the User with access to the services, information, and/or materials contained on the website shoteam.media.
The Operator also has the right to send the User messages about new products and services, special offers, and various events. The User may always opt out of receiving informational messages by sending the Operator an email at shoteam.media@gmail.com with the subject line "Opt-out of notifications about new products, services, and special offers."
Anonymized User data collected via web analytics services is used to gather information about User actions on the site and to improve the quality of the site and its content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for the Operator's processing of personal data are:
- the Operator's founding documents;
- agreements concluded between the Operator and the data subject;
- applicable data protection law, as well as other local and/or international regulatory acts in the field of data protection;
- the Users' consent to the processing of their personal data, including consent to the processing of personal data permitted for distribution.
The Operator processes a User's personal data only where it is independently entered and/or submitted by the User via the special forms located on the shoteam.media website, or sent to the Operator by email. By completing the relevant forms and/or sending their personal data to the Operator, the User confirms their agreement with this Policy.
The Operator processes anonymized data about the User where this is permitted by the User's browser settings (i.e., cookies and JavaScript are enabled).
The data subject independently decides whether to provide their personal data and gives consent voluntarily, of their own free will, and in their own interest.
9. Conditions for Personal Data Processing
Personal data is processed with the consent of the data subject to the processing of their personal data.
Processing of personal data is necessary to achieve the purposes provided for the performance of the functions, powers, and duties assigned to the Operator.
Processing of personal data is necessary for the performance of an agreement to which the data subject is a party, as well as for concluding an agreement at the data subject's initiative, or an agreement under which the data subject will be a beneficiary or guarantor.
Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not thereby violated.
Personal data to which access has been granted to an unlimited group of persons by the data subject themselves, or at their request (hereinafter "publicly available personal data"), is processed.
Personal data subject to publication or mandatory disclosure in accordance with applicable law is processed.
10. Procedure for Collecting, Storing, Transferring, and Otherwise Processing Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable data protection law.
The Operator ensures the preservation of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
The User's personal data is never, under any circumstances, transferred to third parties, except in cases related to compliance with applicable law, or where the data subject has given the Operator consent to transfer data to a third party for the fulfillment of obligations under a civil-law agreement.
If inaccuracies in personal data are identified, the User may update it independently by sending a notice to the Operator's email address, shoteam.media@gmail.com, with the subject line "Update of personal data."
The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by an agreement or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator's email address, shoteam.media@gmail.com, with the subject line "Withdrawal of consent to the processing of personal data."
All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the relevant persons (Operators) in accordance with their own User Agreement and Privacy Policy. The data subject and/or User is obliged to independently and promptly review these documents. The Operator is not liable for the actions of third parties, including the service providers referred to in this clause.
Prohibitions established by the data subject on the transfer (other than the granting of access), as well as on the processing or conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases where personal data is processed in the state, public, or other public interests defined by applicable data protection law.
When processing personal data, the Operator ensures the confidentiality of personal data.
The Operator stores personal data in a form that allows the data subject to be identified for no longer than is necessary to achieve the purposes of processing personal data, unless a different storage period is established by law.
Grounds for discontinuing the processing of personal data may include the achievement of the purposes of processing, the expiration of the data subject's consent, or the discovery of unlawful processing of personal data. The User may also request the deletion of their personal data by sending a request to shoteam.media@gmail.com with the subject line "Deletion of personal data and withdrawal of consent to its processing."
11. List of Actions Performed by the Operator on Personal Data Received
The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.
12. Cross-Border Transfer of Personal Data
Before commencing a cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the personal data transfer is planned provides an adequate level of protection for the rights of data subjects.
Cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out with the written consent of the data subject to such transfer and/or in the performance of an agreement to which the data subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties and not to distribute personal data without the consent of the data subject, unless otherwise provided for by applicable data protection law.
14. Final Provisions
The User may obtain any clarifications on matters of interest relating to the processing of their personal data by contacting the Operator via email at shoteam.media@gmail.com.
This document will reflect any changes made by the Operator to its personal data processing policy. The Policy is valid indefinitely until replaced by a new version.