PRIVACY POLICY 

1. Purpose and Applicability of this Privacy Policy 
www.alexanderboldachev.com (the "Website") are run by Alexander Boldachev, Switzerland 
(the "Operator"). The Operator cares about data protection and abides by the pertinent data protection laws. 


This Privacy Policy deals with the Operator's handling of information relating to an identified or identifiable natural person ("Personal Data" of "Data Subjects"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the cultural or social identity of that natural person (art. 4(1) of the European Data Protection Regulation "GDPR"). In addition, "Personal Data" subject to the Swiss Data Protection Act ("DPA") comprises data of legal entities, too. 
This Privacy Policy applies only to the Website but does not apply to any third-party 
websites that may be linked to the Website. Any third party website will be governed by its own privacy policy. 
2. Controller 
Alexander Boldachev, aforementioned, is the controller in the sense of art. 4(7) GDPR. 
3. Collection of Personal Data 
For the Purpose of Purchasing Musical Recordings or Booking Skype Lessons 
The Operator obtains Personal Data if the User submits such information on the Website in order to purchase musical recordings or to book a Skype lesson with the Operator. 
The Operator processes the User's Personal Data in line with art. 13(2)(a) DPA and art. 
6(1)(b) GDPR for the following purposes: 
 to fulfill his obligation to make the purchased musical recordings available to the User 
in accordance with the Terms and Conditions of alexanderboldachev.com; 
 in order to enable the User to participate in the booked Skype lesson in accordance 
with the Terms and Conditions of alexanderboldachev.com. 
The Operator also processes data that cannot be assigned to any person. These are data that do not personally identify you, including anonymous information and aggregated data. 
This information helps the Operator to better understand how users use the Website. 


For Feedback 
If the User contacts the Operator to ask a question, provide feedback or register a complaint, 
the Operator will record any Personal Data and other content that the User submits in his communication so that he can effectively respond to the question, feedback or complaint. 
The Operator reserves the right to use this information, in any manner permitted by law, to respond to the User's communication. 
The processing of Personal Data for feedback processing is based on art. 13(1) DPA and art. 
6(1)(f) GDPR. 
Due to the User's activity on the Website 
When the User uses the Website, the Operator receives and stores certain information, 
which may include Personal Data. Examples include IP addresses, browser types, domain names, and other statistical data regarding the User. The Operator may use this data in line with art. 13(1) DPA and art. 6(1)(f) GDPR in a way that does not disclose any personally 
identifiable information, including, but not limited to, for the purpose of developing the 
Website or its services. 

Cookies 
The Operator may send cookies to the User's computer in order to uniquely identify the browser and improve the quality of the Website. The term “cookies” refers to small pieces of information that a website sends to a user's hard drive while he is viewing the website. The 
The operator may rely on both session cookies (which expire once the User closes his browser) 
and persistent cookies (which stay on the User's computer until he deletes them). Persistent cookies can be removed by following the browser help directions. If the User chooses to disable cookies, some areas of the Website may not work properly or at all. The use of cookies is based on art. 13(1) DPA and art. 6(1)(f) GDPR. 
4. Disclosure of Personal Data 
The Operator will not sell Personal Data. He may, however, disclose such information in the 
following circumstances: 
(a) In the process of delivering purchased recordings or setting up the Skype 
connection 
The Operator may disclose information to distributors in order to ensure the fulfillment of his contractual obligations. This is based on art. 13(1) DPA and art. 6(1)(f) GDPR. 
(b) Legal obligation 
In response to a request for information if the Operator believes such disclosure is in accordance with applicable law, regulation or legal processes, or as otherwise required by any applicable law, rule or regulation. The legal basis for processing to fulfill a legal obligation is art. 13(1) DPA and art. 6(1)(c) GDPR. 
(c) Violation of Terms and Conditions 
If the Operator believes the User's actions are in violation of the Terms and 
Conditions and this Privacy Policy, or to protect the rights, property, and safety of the 
Operator or others. In this case, the transfer is based on art. 13(1) DPA and art. 
6(1)(f) GDPR. 
5. Security 
The Operator takes commercially reasonable steps to protect Personal Data from loss, 
misuse, unauthorized access, disclosure, alteration or destruction. 
However, the Operator cannot guarantee that all Internet or email transmission is fully secure or error-free. Therefore, the Operator cannot be held liable for intercepted information sent via the Internet or for third parties misusing Personal Data. 
The User should, therefore, take special care in deciding what information to submit on the 
Website and keep the above in mind when disclosing any Personal Data to the Operator or to any other party via the Internet. 
6. Retention Period 
The Operator stores Personal Data for as long as it is necessary for the purpose for which it was collected or for fulfilling legal obligations, such as statutory retention periods. 
7. The User's Rights 
Upon request, the Operator will inform the User, in accordance with the applicable statutory provisions, whether and, if so, which Personal Data the Operator has stored about the User. 
Such information may be demanded at any time and free of charge. The User has the right to receive the Personal Data the Operator holds about him in a common format. He may further demand the correction and/or deletion of his Personal Data. 
For this purpose or if any questions about the processing of Personal Data arises, please contact the Operator at boldachev.harp@gmail.com. Please note that the User who asserts any of the above rights will be requested to provide sufficient identification to the Operator. 

The User also has the right to file a complaint with the relevant data protection authority. 
8. Existence of an Automated Decision-Making Process 
The Operator refrains from automatic decision-making or profiling. 
9. Changes to this Privacy Policy 
Within the framework of the pertinent regulation, the Operator is free to change this Privacy 
Policy at any time. The new version will always be posted on the Website. 
These changes will be effective immediately for any new User and will become effective for an existing User through continued use of the Website after the effective date of the posted change. 
© Alexander Boldachev, 2020, Version 1