Are mobile phone number, e-mail and date of birth personal data?

Question

Data protection

Actually, I googled a lot, found a lot of different things, incl. and the official text of the law. From what I read, I realized that if a person, when registering, enters his e-mail, mobile phone number and indicates the day and month of birth (without indicating his full name and other personal data), then this combination will not be personal data with t.z. law of the Russian Federation and will not require the use of special software, as well as certification, etc.
e-mail / phone are used to reset the password, notification of a change in the status of the account.
date and month of birth - special offers of a personal type, congratulations by email.
Tell me, did I understand correctly or did I miss something?
Thank you!
PS the number of registered users will not exceed 220 people.

Answer 1

Well, there are some doubts about the mobile phone, but about email, etc. no claims

Answer 2

If the information does not allow you to identify a person, then no, this is not personal data.
The difficulty is that, in addition to laws, theoretically there are still decisions of the Higher Courts and Roskomnadzor documents that supplement and explain this law, in order to say for sure, they need to be found and studied (and I, of course, am too lazy).
But at first glance, no.

Answer 3

It won't, don't worry.
That's if you answer the real question.
If on the given - will be. With t.z. The law is personal data. But the Law divides into those that are identifying and those that are not. That is, just a photo - non-identifying, just a full name - too. Their combination - yes. It is assumed that the average person does not have access to databases of mobile numbers and the like.