Personal Data Processing Policy

Operator: “Operator”, contact email: roman.kolpakov@gmail.com.
This Policy describes how the Operator processes personal data collected through the Website and feedback forms.
1. Purpose of ProcessingInforming the User by sending emails and/or phone calls/messages in response to inquiries submitted via the Website.

• 2. Personal Data ProcessedSurname, first name, patronymic (if applicable)
• Email address
• Phone number(s)
• 3. Legal GroundsThe Operator’s charter (founding) documents
• The User’s consent to the processing of personal data
• Other grounds provided by applicable laws and international treaties of the Russian Federation

4. Types (Methods) of ProcessingCollection, recording, systematization, accumulation, storage, destruction, and anonymization (de-identification) of personal data.
5. Conditions for Processing Personal Data5.1. Processing is carried out with the personal data subject’s consent.
5.2. Processing is necessary to achieve purposes prescribed by an international treaty or law, and to perform functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
5.3. Processing is necessary for the administration of justice or the execution of a court judgment or an act of another body/official to be executed under enforcement legislation of the Russian Federation.
5.4. Processing is necessary for the performance of a contract to which the personal data subject is a party/beneficiary/surety, or for entering into a contract at the subject’s initiative or a contract under which the subject will be a beneficiary or surety.
5.5. Processing is necessary to exercise the Operator’s or third parties’ rights and legitimate interests or to achieve socially significant purposes, provided the subject’s rights and freedoms are not violated.
5.6. Processing is carried out with respect to personal data made publicly available by the subject or at the subject’s request (“public personal data”).
5.7. Processing is carried out with respect to personal data subject to publication or mandatory disclosure under federal law.
6. Procedure for Collection, Storage, Transfer and Other ProcessingThe Operator ensures the security of personal data by legal, organizational, and technical measures necessary to fully comply with applicable personal data protection laws.
6.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorized access.
6.2. Personal data will never be transferred to third parties except where required by law or where the subject has consented to such transfer for the performance of a civil-law contract.
6.3. If inaccuracies are identified, the User may update personal data by emailing the Operator at roman.kolpakov@gmail.com with the subject line “Personal data update”.
6.4. The processing period is determined by the achievement of the purposes for which the data were collected, unless another period is set by contract or law. The User may withdraw consent at any time by emailing roman.kolpakov@gmail.com with the subject line “Withdrawal of consent to personal data processing”.
6.5. Information collected by third-party services (including payment systems, communication tools, and other service providers) is stored and processed by those parties under their own Terms of Use and Privacy Policies. The personal data subject should review those documents. The Operator is not responsible for third parties’ actions, including the service providers mentioned in this clause.
6.6. Restrictions set by the personal data subject on transfer (other than granting access) or on processing conditions of personal data permitted for distribution do not apply where processing is carried out in state, public, or other public interests as defined by the laws of the Russian Federation.
6.7. The Operator ensures the confidentiality of personal data during processing.
6.8. Personal data are stored in a form that allows identification of the subject for no longer than required for the purposes of processing, unless a longer period is established by federal law or contract to which the subject is a party/beneficiary/surety.
6.9. Processing shall cease upon achievement of the purposes of processing, expiry of consent, withdrawal of consent by the subject, a lawful demand to stop processing, or detection of unlawful processing.
7. Actions Performed by the Operator with Personal Data7.1. Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
7.2. Automated processing may be carried out, with or without transmission of information via information and telecommunication networks.
8. Cross-Border Transfer of Personal Data8.1. Before starting cross-border transfers, the Operator shall notify the authorized personal data protection authority of its intention to carry out such transfers (this notice is sent separately from the notice of intent to process personal data).
8.2. Prior to sending the notice specified above, the Operator shall obtain the necessary information from foreign state authorities, foreign individuals, or foreign legal entities to whom cross-border transfer is planned.
9. Confidentiality of Personal DataThe Operator and other persons who have obtained access to personal data must not disclose or distribute personal data to third parties without the subject’s consent, unless otherwise provided by federal law.
10. Final Provisions10.1. The User may obtain any clarifications regarding processing of their personal data by emailing roman.kolpakov@gmail.com.
10.2. Any changes to this Policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
10.3. The current version of the Policy is publicly available on the Website.