1.General Provisions

This personal data processing policy determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Captain Works LTD (hereinafter referred to as the Operator).
1.1. The Operator sets as its primary goal and condition for its activities the observance of the rights and freedoms of a person and citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
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 receive about visitors to the website botcom.fi/darkmode.

2.Key Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address botcom.fi/darkmode.
2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions resulting in the impossibility of determining, without the use of additional information, the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including 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 that independently or jointly with other persons organizes and/or performs the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website botcom.fi/darkmode.
2.9. Personal data allowed by the subject of personal data for distribution – personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.10. User – any visitor to the website botcom.fi/darkmode.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to the general public, including publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign government authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or destruction of the material carriers of personal data.

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 subject of personal data;
— continue processing personal data without the consent of the subject of personal data if the subject of personal data withdraws consent to the processing of personal data or sends a request to cease processing personal data, provided there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation;
— respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— inform the authorized body for the protection of the rights of subjects of personal data upon its request of the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with personal data;
— cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.

4.Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— set a precondition of consent when processing personal data for promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data, as well as send a request to cease processing personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or in court the unlawful actions or inaction of the Operator when processing their personal data.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter bear responsibility in accordance with the current legislation.

5.Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful goals. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data concerning the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, their relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the subject of personal data, no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of the loss of necessity in achieving these purposes unless otherwise provided by federal law.

6.Purposes of Personal Data Processing
The purpose of processing informing the User by sending emails Personal datalast name, first name, patronymic email address phone numbers City Legal groundscharter (constituent) documents of the Operator contracts concluded between the operator and the subject of personal data Types of personal data processing collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data Sending informational emails to the email address

7.Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the goals provided for by the international treaty or the law for the implementation of the functions, powers, and obligations imposed by the current legislation on the operator.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, an act of another body, or an official, to be executed in accordance with the legislation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data is carried out, access to which an unlimited number of persons is granted by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

8.Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address ura@botcom.fi marked "Updating personal data."
8.4. The processing period for personal data is determined by achieving the purposes for which personal data was collected unless otherwise provided by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address ura@botcom.fi marked "Withdrawal of consent to personal data processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or agreed with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on processing or conditions for processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in the state, public and other public interests as defined by the current 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 identifying the subject of personal data, no longer than required by the purposes of personal data processing unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The condition for the termination of personal data processing may be the achievement of personal data processing goals, the expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, or the requirement to cease the processing of personal data, as well as the detection of unlawful processing of personal data.

9.List of Actions Performed by the Operator with the Received Personal Data 9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such.

10.Cross-Border Transfer of Personal Data
10.1. The Operator, before starting activities for the cross-border transfer of personal data, must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out a cross-border transfer of personal data (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.

11.Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data unless otherwise provided by federal law.

12.Final Provisions
12.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at ura@botcom.fi.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version. 12.3. The current version of the Policy is freely available on the internet at https://botcom.fi/privacy