Personal Data Processing Policy

1. General provisions

This Policy on the processing of personal data (the “Policy”) is developed pursuant to the requirements of Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”) and defines the procedure for processing personal data and the measures to ensure their security taken by Marat Rashidovich Gizatulin, an individual applying the special tax regime “Professional Income Tax” (self-employed), TIN 780230978940, address for correspondence: Leningrad Region, Lomonosovsky District, DNP Lesnaya Privilegiya, house 181 (the “Operator”).

The Operator considers respect for human and civil rights and freedoms during the processing of personal data — including protection of the rights to privacy and to personal and family secrets — to be one of its most important tasks. The Policy applies to all information the Operator may obtain about visitors of the aisdlc.tech website.

2. Key definitions

• Personal data — any information relating to a directly or indirectly identified or identifiable natural person (the data subject);
• Processing of personal data — any action (operation) or set of actions with personal data performed with or without automation;
• Operator — the entity that organises and/or carries out the processing of personal data and determines the purposes and composition of the data processed;
• Subject — a visitor of the site who has submitted their data through forms or otherwise;
• Cross-border transfer — the transfer of personal data to the territory of a foreign state.

3. Legal grounds for processing

The Operator processes personal data on a lawful and fair basis. Legal grounds: the Constitution of the Russian Federation; Law No. 152-FZ; the subject’s consent to the processing of personal data; contracts concluded between the Operator and the subject; other regulatory acts of the Russian Federation.

4. Purposes of processing personal data

• Reviewing and processing requests and enquiries submitted through the Site’s forms;
• Feedback, consulting and providing information about products and services;
• Concluding, performing and terminating civil-law contracts;
• Sending informational and advertising messages, subject to the subject’s consent;
• Complying with the requirements of the legislation of the Russian Federation.

5. Categories of subjects and composition of data

The Operator processes the personal data of the following categories of subjects: Site visitors, potential and existing clients, and their representatives.

• Full name;
• Organisation name and job title;
• Email address;
• Contact phone number;
• Other information voluntarily provided by the subject in an enquiry.

6. Principles and conditions of processing

Processing is limited to achieving specific, predefined and lawful purposes. Only data that meets the purposes of processing is processed; its content and scope correspond to the stated purposes and are not excessive. Processing is carried out with the subject’s consent or on another legal basis provided for by Article 6 of the Law.

7. Scope of actions and methods of processing

The Operator carries out the collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), anonymisation, blocking, deletion and destruction of personal data. Processing is performed in a mixed manner, with and without automation.

8. Storage and localisation

Recording, systematisation, accumulation, storage, clarification and retrieval of the personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation (Part 5, Article 18 of the Law). Personal data is stored no longer than the purposes of processing require, unless another period is established by law or contract.

9. Cross-border transfer

The Operator does not carry out cross-border transfer of personal data. Should such a transfer become necessary, it will be performed only in compliance with the requirements of Article 12 of the Law.

10. Entrusting processing to third parties

The Operator may entrust the processing of personal data to another party with the subject’s consent, on the basis of a concluded contract. Such party undertakes to comply with the principles and rules of processing, confidentiality and the data-security requirements provided for by the Law.

11. Security measures

• Appointing a person responsible for organising the processing of personal data;
• Issuing internal acts on the processing and protection of personal data;
• Applying legal, organisational and technical measures in accordance with Articles 18.1 and 19 of the Law;
• Restricting access to personal data and monitoring the measures taken;
• Assessing the harm that may be caused to subjects and identifying current threats.

12. Rights of the data subject

• Receive information about the Operator, its location and whether it holds the subject’s personal data;
• Demand clarification, blocking or destruction of data if it is incomplete, outdated, inaccurate or processed unlawfully;
• Withdraw consent to the processing of personal data;
• Appeal the Operator’s actions or inaction to the authorised body for the protection of data subjects’ rights (Roskomnadzor) or in court.

13. Enquiries and withdrawal of consent

The subject may send a request or a withdrawal of consent to the processing of personal data to the email address info@aisdlc.ru. The request must contain information that allows the subject to be identified. The Operator reviews the enquiry and provides a response within the periods established by the Law. Upon withdrawal of consent, the Operator ceases processing and destroys the data within the period established by the Law, unless there are other lawful grounds for processing.

14. Updates and final provisions

The Operator may amend this Policy. A new version takes effect from the moment it is posted on the Site, unless otherwise provided by that version. The current version is permanently available at aisdlc.tech/personal-data.

15. Operator details