Personal Data Processing Policy
1. General Provisions

This Personal Data Processing Policy is developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and outlines the procedure for processing personal data and the measures taken by Global Ad Stream (hereinafter referred to as the Operator) to ensure personal data security.

1.1. The Operator’s primary goal and condition for conducting its activities is the protection of human rights and freedoms during the processing of personal data, including the right to privacy and protection of personal and family secrets.

1.2. This Policy applies to all information that the Operator may obtain regarding visitors to the website https://globaladstream.com.
2. Basic Terms Used in the Policy

2.1. Automated Personal Data Processing – processing of personal data using computer technology.

2.2. Blocking Personal Data – temporary suspension of personal data processing (except where processing is necessary to clarify personal data).

2.3. Website – the collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the address https://globaladstream.com.

2.4. Personal Data Information System – a system consisting of personal data stored in databases and the information technologies and technical means that support their processing.

2.5. Anonymization of Personal Data – actions that prevent the identification of personal data without the use of additional information.

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

2.7. Operator – a state body, municipal body, legal entity, or individual who, independently or in cooperation with other entities, organizes and/or performs personal data processing and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) to be performed with personal data.

2.8. Personal Data – any information related to an identified or identifiable User of the website https://globaladstream.com.

2.9. Personal Data Permitted for Distribution by the Data Subject – personal data to which access is granted to an unlimited circle of individuals by the data subject through consent for processing personal data, as allowed by the Personal Data Law (hereinafter – personal data permitted for distribution).

2.10. User – any visitor to the website https://globaladstream.com.

2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific individual or a specific group of individuals.

2.12. Distribution of Personal Data – any actions aimed at disclosing personal data to an indefinite circle of individuals (transfer of personal data) or making personal data available to an unlimited circle of individuals, including publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data by any other means.

2.13. Cross-Border Transfer of Personal Data – the transfer of personal data to a foreign state’s authorities, foreign physical persons, or foreign legal entities.

2.14. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data with no possibility of further recovery or restoration of personal data content in the personal data information system and/or the destruction of physical media of personal data.
3. Operator's Basic Rights and Obligations

3.1. The Operator has the right to:
  • Obtain accurate information and/or documents containing personal data from the data subject;
  • Continue processing personal data without the data subject’s consent if consent is withdrawn, based on grounds specified in the Personal Data Law;
  • Independently determine the composition and range of measures necessary to fulfill the obligations set out in the Personal Data Law and other applicable legal acts.

3.2. The Operator is obliged to:
  • Provide the data subject with information about the processing of their personal data upon request;
  • Organize personal data processing in accordance with Russian Federation law;
  • Respond to requests and inquiries from data subjects and their legal representatives as required by the Personal Data Law;
  • Notify the authorized body on personal data rights protection within 10 days of receiving a request from the authority;
  • Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
  • Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, or dissemination, as well as other illegal actions;
  • Cease the transfer, processing, or distribution of personal data, and delete personal data in accordance with the provisions of the Personal Data Law;
  • Comply with other obligations specified in the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:
  • Obtain information regarding the processing of their personal data, except where federal laws provide otherwise;
  • Request clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose;
  • Demand prior consent for processing personal data for marketing purposes;
  • Withdraw consent for processing personal data and request the cessation of processing;
  • Appeal to the authorized body for protection of personal data rights or seek judicial review of illegal actions or inactions of the Operator in processing their personal data;
  • Exercise other rights under Russian Federation law.

4.2. Data subjects are obliged to:
  • Provide the Operator with accurate personal data;
  • Notify the Operator of any updates or changes to their personal data.

4.3. Individuals providing inaccurate information about themselves or another data subject without their consent are liable under Russian Federation law.
5. Principles of Personal Data Processing

5.1. Personal data processing must be lawful and fair.

5.2. Personal data processing is limited to achieving specific, predefined, and legitimate purposes.

5.3. The merging of personal data databases is prohibited if the purposes of their processing are incompatible.

5.4. Only personal data that is necessary for the stated purpose of processing will be processed.

5.5. The content and scope of personal data being processed must align with the stated processing goals.

5.6. The accuracy, sufficiency, and relevance of personal data must be ensured, with necessary measures taken to update or correct incomplete or inaccurate data.

5.7. Personal data must be stored in a form that allows identification of the data subject for no longer than necessary to achieve the processing goals unless otherwise required by law or contract.
6. Purposes of Personal Data Processing
7. Conditions for Processing Personal Data

7.1. Personal data is processed with the consent of the data subject.

7.2. Processing is necessary for fulfilling functions required by international treaties or Russian law.

7.3. Personal data processing is required for the execution of judicial acts or other legal obligations.

7.4. Personal data processing is necessary for the performance of contracts involving the data subject or for entering into contracts at their request.

7.5. Processing is necessary to protect the legitimate interests of the Operator or third parties, provided that the rights and freedoms of the data subject are not violated.

7.6. Processing occurs for personal data made publicly available by the data subject.

7.7. Processing is required for the publication or disclosure of personal data under Russian law.
8. Collection, Storage, Transfer, and Other Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures to fully comply with the personal data protection requirements of current legislation.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access.

8.2. Personal data will not be transferred to third parties except as required by law or if the data subject has consented to the transfer for the fulfillment of a civil contract.

8.3. In case of data inaccuracies, the User can update them by notifying the Operator via email at info@globaladstream.com.

8.4. The period for personal data processing is determined by the achievement of the processing purposes, unless a different period is specified by contract or law. The User may withdraw their consent at any time by emailing info@globaladstream.com.

8.5. Information collected by third-party services, including payment systems, communication services, and other providers, is stored and processed according to their user agreements and privacy policies. The Operator is not responsible for the actions of third parties.

8.6. Restrictions imposed by the data subject on the transfer or processing of personal data do not apply if processing is required by state, public, or other lawful interests as defined by Russian law.

8.7. The Operator ensures the confidentiality of personal data during processing.

8.8. The Operator stores personal data in a form that allows identification of the data subject only as long as necessary to achieve the processing goals.
9. Operator’s Actions with Personal Data

9.1 The Operator collects, records, systematizes, accumulates, stores, updates, extracts, uses, transfers, anonymizes, blocks, deletes, and destroys personal data.

9.2. The Operator may process personal data automatically, including the transmission of received data over information networks.
10. Cross-Border Transfer of Personal Data

10.1. The Operator must notify the authorized body of their intention to carry out cross-border transfers of personal data.

10.2. The Operator must obtain the necessary information from foreign authorities or entities prior to such transfers.
11. Confidentiality of Personal Data

The Operator and others who have access to personal data are prohibited from disclosing or distributing personal data to third parties without the data subject’s consent, unless otherwise stipulated by federal law.
12. Final Provisions

12.1. Users can obtain clarification on personal data processing matters by contacting the Operator via email at info@globaladstream.com.

12.2. This Policy will reflect any changes in the Operator’s personal data processing practices. The Policy is effective indefinitely until replaced with a new version.

12.3. The current version of the Policy is available online at https://globaladstream.com/privacy.
© Global Ad Stream, 2025