PERSONAL DATA PROCESSING POLICY:

Contacts:

Individual Entrepreneur (IE) Viktoriya Viktorovna Denisyuk
OGRNIP (Primary State Registration Number for Individual Entrepreneurs): 318325600029940
TIN (Taxpayer Identification Number): 325000329412
Contact information: +7 919 296-13-48

1. Terms and Definitions

1.1. Company – Individual Entrepreneur Viktoriya Viktorovna Denisyuk, TIN 325000329412 (hereinafter referred to as the "Company").

1.2. User – an individual gaining access to applications, services, and information posted on the Website.

1.3. Website – the Company’s website located on the Internet at , including subdomains ***., as well as any other Company websites containing a link to this Agreement.

1.4. Agreement – this Agreement between the User and the Company, establishing the rules for using the Website, including graphic images, audiovisual content, design elements, textual information, documentation, software, downloadable files, and any other materials on the Website, as well as the terms and conditions for Users to post information and materials in the relevant open sections of the Website.

1.5. Automated Processing of Personal Data – processing of personal data using computer technology.

1.6. Blocking of Personal Data – temporary suspension of personal data processing (except where processing is necessary to clarify personal data).

1.7. Personal Data Information System – a set of personal data contained in databases and the information technologies and technical means enabling their processing.

1.8. Depersonalization of Personal Data – actions making it impossible to determine the affiliation of personal data to a specific subject without additional information.

1.9. Processing of Personal Data – any action (operation) or set of actions (operations) performed with personal data, including collection, recording, systematization, storage, updating, retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction.

1.10. Operator – a state body, municipal authority, legal entity, or individual organizing and/or processing personal data, either independently or jointly with others, and determining the purposes and composition of personal data processing.

1.11. Personal Data – any information relating to an identified or identifiable individual (data subject).

1.12. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or group.

1.13. Dissemination of Personal Data – actions aimed at disclosing personal data to an indefinite group of people (transfer of personal data) or making personal data publicly available, including publication in mass media or online.

1.14. Cross-Border Transfer of Personal Data – transfer of personal data to a foreign state, foreign authority, or foreign individual/legal entity.

1.15. Destruction of Personal Data – actions making it impossible to restore personal data in the information system and/or destroying physical storage media.

2. General Provisions, Method, and Processing Period of Personal Data

2.1. This document defines the Company’s policy regarding personal data processing and compliance with the requirements of Federal Law No. 152-FZ "On Personal Data" (July 27, 2006).

2.2. Processing of personal data is carried out, among other means, using the "Yandex Metrica" analytics tool.

2.3. The processing periods for personal data, including storage terms, are as follows:

For personal data of employees/former employees – 50 years (including employment period), with 4 years in the information system from the termination date.
For job applicants – until a hiring decision is made.
For family members of employees – 4 years after termination of social benefits/family leave.
For contractors under civil law agreements – 4 years after contract termination.
In any case, no later than the termination of the Company’s business activities as an individual entrepreneur.

2.4. The Company does not engage in cross-border transfer of personal data collected under this policy.

3. Personal Data Subjects

3.1. The Company processes personal data of the following individuals:

Employees.
Contractors under civil law agreements.
Job applicants.
Clients.
Registered website users.
Representatives of legal entities.
Suppliers (individual entrepreneurs).

4. Principles and Conditions of Personal Data Processing

4.1. The Company ensures personal data security against unlawful access, destruction, alteration, blocking, copying, or dissemination by implementing legal, organizational, and technical measures.

4.2. Processing and security comply with the Russian Constitution, Federal Law No. 152-FZ, and related regulations.

4.3. Processing principles include:

Lawfulness and fairness.
Purpose limitation.
Data minimization.
Accuracy and relevance.
Storage limitation.

4.4. The Company may engage third parties for processing under contractual obligations.

4.5. Third parties must comply with Federal Law No. 152-FZ and ensure confidentiality and security.

4.6. Personal data may be transferred if required by law.

4.7. Publicly available employee directories (with consent) may include names, positions, and contact details, removable upon request.

4.8. The Company destroys or anonymizes data when processing purposes are fulfilled.

5. Rights of Personal Data Subjects

5.1. Individuals have the right to:

Request confirmation of processing, purposes, methods, and recipients.
Demand correction, blocking, or deletion of inaccurate/illegally processed data.
Withdraw consent.
File complaints with Roskomnadzor or court.
Seek compensation for damages.

6. Personal Data Security

6.1. The Company implements measures to prevent unauthorized access, including:

Appointing responsible officers.
Restricting access.
Secure storage and handling.
Encryption and antivirus protection.
Access logs and intrusion detection.

7. Final Provisions

7.1. Other rights and obligations are governed by Russian personal data laws.

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