Personal Data Processing Policy

This document (hereinafter referred to as the “Policy”) describes the terms and conditions for processing personal data provided by you as a personal data subject (hereinafter referred to as the “Data Subject”) to SVOiKontrakt.ru as the personal data operator (hereinafter referred to as the “Operator”).

The Policy is drawn up in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (hereinafter referred to as the “Personal Data Law”).

The provisions of the Policy apply only when the Data Subject visits the Operator’s website http://svoconsult.ru.

1. General Provisions

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of the Data Subject during the processing of their personal data, including the protection of the rights to privacy, personal, and family secrets.

1.2. The Policy applies to all information that the Operator may receive about Data Subjects visiting the website http://svoconsult.ru.

2. Basic Concepts Used in the Policy

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

2.2. Blocking of personal data — temporary termination of the processing of personal data (except for cases where processing is necessary to clarify personal data).

2.3. Website — a collection of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address http://svoconsult.ru.

2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data to a specific Data Subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Personal Data (PD) — any information relating directly or indirectly to a specific Data Subject.

2.8. Cookies — these are small text files placed on a personal computer or mobile device in order to analyze the activity of the Data Subject on the Website http://svoconsult.ru. They are collected using the Yandex.Metrica web analytics service.

2.9. Data Subject/User — a natural person to whom the PD relates and who visited the Website http://svoconsult.ru.

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

2.11. Destruction of personal data — any actions as a result of which PD are destroyed irrevocably with the impossibility of further restoration of the content of PD in the personal data information system and/or the destruction of physical media of PD.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right:

  • To receive from the Data Subject reliable information and/or documents containing PD.
  • In case of withdrawal by the Data Subject of consent to the processing of PD, as well as the sending of a request to terminate the processing of PD, the Operator is entitled to continue processing PD without the consent of the Data Subject if there are grounds specified in the Personal Data Law.
  • To 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 regulatory legal acts adopted in accordance with it.

3.2. The Operator is obliged:

  • To provide the Data Subject, at their request, with information concerning the processing of their PD.
  • To organize the processing of personal data.
  • To respond to appeals and requests from Data Subjects and their legal representatives.
  • To report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information.
  • To provide unrestricted access to this Policy regarding the processing of PD by publishing the Policy on the Website.
  • To take legal, organizational, and technical measures to protect PD from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of PD, as well as from other unlawful actions in relation to PD.
  • In case of a PD leak, notify the authorized body within 24 hours from the moment such an incident is detected, and take other measures in accordance with the law.

4. Basic Rights and Obligations of the Data Subject

4.1. The Data Subject has the right:

  • To receive information concerning the processing of their PD, unless such a right is limited in accordance with the legislation of the Russian Federation.
  • To require the Operator to clarify their PD, block or destroy them if the PD are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing.
  • To withdraw consent to the processing of PD. The Operator is obliged to stop processing PD upon withdrawal by the Data Subject, unless otherwise provided by the legislation of the Russian Federation.
  • To appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator.

4.2. The Data Subject is obliged:

  • To provide the Operator with reliable data about themselves.
  • To inform the Operator about the clarification (update, change) of their PD.

5. Principles of Personal Data Processing

5.1. Processing of PD is carried out on a legal and fair basis.

5.2. Processing of PD is limited to the achievement of specific, predetermined, and legitimate goals.

5.3. It is not allowed to merge databases containing PD, the processing of which is carried out for purposes incompatible with each other.

5.4. Only PD that meet the purposes of their processing are subject to processing.

5.5. The content and volume of the processed PD correspond to the stated purposes of processing.

5.6. The accuracy of PD, their sufficiency, and, in necessary cases, relevance to the purposes of processing PD are ensured.

5.7. Storage of personal data is carried out in a form that allows determining the subject of PD, no longer than the purposes of processing PD require.

5.8. The Operator does not disclose PD to third parties and does not distribute PD without the consent of the Data Subject, unless otherwise provided by the Policy and the legislation of the Russian Federation.

5.9. The Operator does not process personal data of a special category, including data on political, religious, and other beliefs, or private and intimate life.

5.10. The Operator does not carry out cross-border transfer of PD.

5.11. Conditions for PD processing:

  • The Data Subject must confirm their consent to the processing of personal data transmitted through the Operator’s Website, either by filling in a special field or by the very fact of sending data.
  • The fact of using the Operator’s Website by the Data Subject means that the Data Subject gives consent to the processing of their personal data, including contact phone numbers, location information, OS type and version, browser type, device type, screen resolution, referral source, language, and IP address.
  • Consent to the processing of personal data is valid indefinitely and can be revoked by sending a statement to the Operator in free written form to the address info@svoikontrakt.ru.

Personal Data Processing by Yandex.Metrica Web Analytics Service

6.1. The consent of the Data Subject to the collection of cookies using the Yandex.Metrica web analytics service means that the Data Subject has also given consent to the transfer of the specified data to Yandex (Yandex LLC; PSRN 1027700229193, 16 Leo Tolstoy St., Moscow, 119021, Russia) for processing.

6.2. PD collected using cookies cannot identify the Data Subject but can help the Operator improve the Website. Information will be transferred to Yandex and stored on Yandex servers. Yandex processes this information in the manner established in the terms of use of the Yandex Metrica service.

6.3. The Data Subject can refuse the use of cookies by selecting the appropriate settings in their browser or using the tool at: yandex.ru/support/metrika/general/opt-out.html.

7. Purposes of Personal Data Processing

7.1. Analysis of statistical and analytical information about Website Users who have left an application for consultation:

  • Personal data — Name, Phone number
  • Categories of users — Website Users who left an application for consultation
  • Legal grounds — consent of the Data Subject to the processing of their PD
  • Types of processing — Collection, recording, systematization, accumulation, storage, destruction (update, change), and depersonalization
  • Processing methods — Mixed processing
  • Processing periods — from the date of provision of consent until the goal is achieved or consent is withdrawn

7.2. Collection of statistical information about User actions on the Website to improve its quality:

  • Personal data — cookies
  • Categories of users — Website Users
  • Types of processing — Collection, recording, systematization, accumulation, storage, destruction, and depersonalization
  • Processing periods — from the date of provision of consent until the goal is achieved or consent is withdrawn

7.3. Providing consultations on services posted on the Operator’s Website for the conclusion of a civil law contract:

  • Personal data — Name, Phone number
  • Processing methods — Mixed processing
  • Processing periods — from the date of provision of consent until the goal is achieved or consent is withdrawn

8. Procedure for Collection, Storage, Transfer, and Other Types of PD Processing

8.1. All PD are stored on the territory of the Russian Federation.

8.2. The Operator records, systematizes, accumulates, stores, and updates personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

8.3. Storage of PD is carried out until the goal for which they were collected is achieved or to comply with the legislation of the Russian Federation.

8.4. In case the Data Subject decides to update or delete their PD, they send a request to the Operator’s email info@svoikontrakt.ru marked “Update of personal data”.

8.5. The Operator ensures the safety of PD and takes all possible measures to exclude unauthorized access by third parties.

8.6. The Operator does not transfer PD to third parties, except as provided by law or with consent:

8.6.1. Third party for statistics — YANDEX LLC (16 Leo Tolstoy St., Moscow, 119021, Russia).

8.6.2. Third party for lead processing — 1C-Bitrix LLC (9th Floor, 2 Entuziastov Blvd., Moscow, 109544, Russia).

9. Confidentiality of Personal Data

9.1. The Policy establishes the terms for the exchange and disclosure of confidential information, including business, technological, and financial data.

9.2. Confidential information does not include information that is or becomes public through no fault of the receiving party, or is legally obtained from other sources.

9.3. Obligations of the parties:

  • Use confidential information exclusively for the purposes of using the Website or concluding a contract.
  • Take all necessary measures to prevent leaks.
  • Do not disclose or reproduce materials to third parties without prior written consent, except as required by law.

10. Final Provisions

10.1. The User can get any clarifications regarding the processing of their PD by contacting the Operator via email info@svoikontrakt.ru.

10.2. The Operator reserves the right to make changes to the Policy at any time.

10.3. This document will reflect any changes to the Policy. The Policy is valid indefinitely until replaced by a new version.

10.4. The current version of the Policy is freely available on the Internet at http://svoconsult.ru/us/privacy/.

10.5. Operator contact information: +7 (906) 005-09-54.