Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and the measures taken by [Operator] to ensure the security of personal data (hereinafter referred to as the Operator).

1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy, to be its most important objective and a necessary condition for carrying out its activities.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors of the website [Website URL], namely:

• personal data sent through feedback forms or by email;
• anonymized User data, if this is permitted in the User’s browser settings, including enabled storage of cookie files and use of JavaScript technology.

 

2. Key Terms Used in the Policy

2.1. Automated processing of personal data means processing personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is required to clarify personal data.

2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address [Website URL].

2.4. Personal data information system means a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Anonymization of personal data means actions resulting in the impossibility of determining, without additional information, whether personal data belongs to a specific User or another personal data subject.

2.6. Processing of personal data means any action or set of actions performed with or without the use of automation tools in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, retrieval, use, transfer, distribution, provision, access, anonymization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or carries out personal data processing, and also determines the purposes of personal data processing, the scope of personal data to be processed, and the actions performed with personal data.

2.8. Personal data means any information directly or indirectly relating to an identified or identifiable User of the website [Website URL].

2.9. Personal data permitted by the personal data subject for dissemination means personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in accordance with the procedure established by the Personal Data Law.

2.10. User means any visitor of the website [Website URL].

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons, including transfer of personal data, or at making personal data available to an unlimited number of persons, including publication of personal data in the mass media, posting in information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, to a foreign individual, or to a foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

— receive from the personal data subject reliable information and/or documents containing personal data;

— if the personal data subject withdraws consent to the processing of personal data, or sends a request to stop the processing of personal data, continue processing personal data without the consent of the personal data subject where there are grounds provided for by the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and the regulations 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 personal data subject, upon request, with information concerning the processing of his/her personal data;

— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;

— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;

— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;

— cease the transfer, dissemination, provision, and access to personal data, cease processing, and destroy personal data in accordance with the procedure and in the cases provided for by the Personal Data Law;

— fulfill other obligations provided for by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator to the personal data subject in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— require the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and also take measures provided by law to protect their rights;

— impose a condition of prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;

— withdraw consent to personal data processing and also submit a request to stop personal data processing;

— appeal unlawful actions or omissions of the Operator in the processing of personal data to the authorized body for the protection of the rights of personal data subjects or in court;

— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

— provide the Operator with accurate data about themselves;

— notify the Operator of any clarification, update, or change to their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed on a lawful and fair basis.

5.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.

5.3. The merging of databases containing personal data processed for purposes incompatible with each other is not permitted.

5.4. Only personal data that corresponds to the purposes of its processing shall be processed.

5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not permitted.

5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or if the need to achieve such purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Item	Description
Purpose of processing	Conclusion, performance, and termination of civil-law contracts
Personal data	Full name; email address; phone numbers; anonymized visitor data, including cookie files, collected using Internet statistics services, including Yandex Metrica, Google Analytics, and others
Legal grounds	Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection”
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 shall be processed with the consent of the personal data subject to the processing of his/her personal data.

7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, act of another authority, or act of an official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data is processed where access by an unlimited number of persons has been granted by the personal data subject or at his/her request.

7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

8. Procedure for Collection, Storage, Transfer, 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 safekeeping of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil-law contract.

8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address [Operator’s email address] marked “Personal Data Update.”

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or by current legislation. The User may withdraw his/her consent to personal data processing at any time by sending a notification to the Operator by email to [Operator’s email address] 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 such persons, acting as operators, in accordance with their User Agreement and Privacy Policy. The personal data subject shall familiarize himself/herself with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Restrictions imposed by the personal data subject on transfer, except for granting access, as well as restrictions or conditions on processing, except for obtaining access, of personal data permitted for dissemination shall not apply in cases where personal data is processed in state, public, or other public interests determined by the legislation of the Russian Federation.

8.7. The Operator shall ensure the confidentiality of personal data when processing it.

8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. The conditions for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to stop processing personal data, or identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Received

9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification, updating, modification, retrieval, use, transfer, distribution, provision, access, anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data with or without receipt and/or transfer of the received information via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data. Such notification shall be submitted separately from the notification of intention to process personal data.

10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom personal data is planned to be transferred.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User may obtain any clarifications on matters concerning the processing of his/her personal data by contacting the Operator by email at [Operator’s email address].

12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at [Website URL].