Personal Data Processing Policy

Personal Data Processing Policy

1. General provisions

This Personal Data Processing Policy is developed under the requirements of The Federal Law No. 152-FZ «On Personal Data» and defines the personal data processing procedure and measures to secure personal data undertaken by Private Entrepreneur Eremeev D.A. (hereinafter — Operator).

1.1. The Operator in conducting its activities prioritizes observing rights and freedoms of a person and citizen in processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator Policy for personal data processing (hereinafter — Policy) applies to all information which the Operator may obtain about the visitors of website

2. Basic Terms and Definitions used in the Policy

2.1. Automated personal data processing — personal data processing via PC software;

2.2. Personal data blocking – temporary interruption of personal data processing (except where processing is required for personal data update);

2.3. Website — the entirety of graphic and informational materials as well as software and databases that make them available online at;

2.4. Personal data information system – a set of personal data included into personal data databases, as well as the software and tools used for their processing;

2.5. Personal data depersonalisation – actions making it impossible to identify personal data as related to a certain User or other data subject without involving additional information;

2.6. Personal data processing – any action (activity) or a series of actions (activities) performed towards personal data with or without the software, including the personal data acquisition, recording, systematisation, accumulation, storage, alignment (update, alteration), extraction, use, transfer (distribution, presentation, providing access), depersonalisation, blocking, deleting and annihilation;

2.7. Operator – state authority, municipal authority, legal or private person, who severally or jointly arranges and (or) performs personal data processing, as well as defines the aims of personal data processing, the scope of personal data subject to processing and personal data handling;

2.8. Personal data – any information related directly or indirectly to a specific or defined User of website;

2.9. User — any visitor of website;

2.10. Personal data presentation – actions aimed at personal data disclosure to particular person or certain group of persons;

2.11. Personal data distribution – any actions aimed at personal data disclosure to uncertain group of persons (personal data transfer) or at general public getting acquainted with personal data, including personal data publication in the media, posting in the information and telecommunication networks or providing access to personal data in any other way;

2.12. Cross-border transfer of personal data – personal data transfer to a foreign country to a foreign government body, foreign natural or legal person;

2.13. Personal data annihilation – any actions making it impossible to restore personal data in the personal data information system and/or resulting in the destruction of tangible personal data carriers.

3. The Operator may process the following User personal data

3.1. Surname, name, patronymic;

3.2. E-mail address;

3.3. Phone numbers;

3.4. Photographs;

3.5. Citizenship certificate;

3.6. Particulars of person’s ID;

3.7. Taxpayer identification number, date of registration, particulars of registration at the tax authority certificate;

3.8. Mandatory pension insurance certificate number, date of registration in mandatory pension insurance system;

3.9. Obligatory medical insurance policy number;

3.10. Actual address and residency address;

3.11. Information on education, occupation, career and qualifications, academic degree particulars;

3.12. Marital status and family members’ details;

3.13. Financial situation details;

3.14. Income details;

3.15. Indebtedness details;

3.16. Information on previous jobs and work experience, military service, military registration;

3.17. The site also gathers and processes anonymised data on visitors (incl. «cookies») via web analytics tools (Yandex Metrics and Google Analytics etc.).

3.18. The abovementioned data is referred to as a general term Personal Data further in this Policy.

4. Purposes of personal data processing

4.1. The purpose of User personal data processing — informing the User by sending e-mails; conclusion, execution and termination of civil contracts; providing User with access to services, information and/or materials on website.

4.2. The Operator is also entitled to send the User notifications on new products and services, special offers and different events. The User can always unsubscribe from information messages by sending a letter to Operator’s e-mail titled «Waiver of notices about new products and services and special offers».

4.3. Anonymised User data collected via web analytics tools is used to collect information on User activities on the site to improve site quality and content.

5. Legal foundation of personal data processing

5.1. The Operator processes User personal data only if such was filled in and/or sent by the User himself/herself via special forms at site By filling out relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent of this Policy.

5.2. The Operator processes anonymised User data if this is allowed by User browser settings (saving «cookies» and using JavaScript is enabled).

6. Procedure for acquisition, storage, transfer and other types of processing personal data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation for personal data protection.

6.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

6.2. User personal data shall under no circumstances be transferred to third parties, except for cases related to the enforcement of the legislation in power.

6.3. Should an inaccuracy be discovered in the personal data, the User may independently update the information by sending a notice titled «Personal data update» to the Operator’s e-mail address

6.4. The period of personal data processing is indefinite.  The User can withdraw his/her consent for personal data processing at any time by sending a notice titled «Withdrawal of personal data processing consent» to the Operator’s e-mail address

7. Cross-border transfer of personal data

7.1. Before starting cross-border transfer of personal data the Operator shall ascertain that the foreign state where the personal data is planned to be transferred  ensures proper protection of personal data subject rights.

7.2. Cross-border transfer of personal data to foreign states that fail to meet the abovementioned requirements can be conducted only with written consent of the personal data subject to cross-border transfer of his/her personal data and/or in executing the agreement to which the personal data subject is the party. 

8. Final provisions

8.1. The user may get any clarification on matters pertaining to his/her personal data by contacting the Operator via e-mail

8.2. This document will reflect all changes to the personal data processing policy made by the Operator.  The policy is valid indefinitely until replaced with an updated version.

8.3. The recent version of the Policy is freely available on the Internet at

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