Personal Data Processing and Protection Policy

1. General Terms and Conditions

1.1. This Personal Data Processing and Protection Policy is compliant with the Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006; it describes the processing of personal data and measures the sole entrepreneur Dmitry Sergeyevich Mikhailov, Primary State Registration Number 319169000194634, (hereinafter, the Operator) undertakes to protect it.

1.2. When processing personal data, the Operator prioritizes and commits to respect the human and civil rights, including the right for privacy, both personal personal and family.

1.3. This Personal Data Processing and Protection Policy (hereinafter, the Policy) is applicable to all information the Operator can gather on users of the website. 


2. Terms and Definitions 

2.1. “Automated personal data processing” is a processing of personal data using computational tools.

2.2. “Blocking personal data” is a temporary suspension in personal data processing (except for cases, when the processing is required to actualize the personal data).

2.3. “Website” is a combination of graphic and information materials, as well as computational and database software for ensuring their availability at

2.4. “Personal data information system” is a combination of all personal data in databases, as well as technology and technical solutions implemented to process it.

2.5. “Personal data depersonalization” is actions to make it impossible to link personal data to a specific user or another personal data subject without additional information.

2.6. “Personal data processing” is any automated or manual operation or set of operations with personal data, including data collection, recording, systematization, storage, actualization (updating and modification), extraction, use, disclosure (spreading, providing, giving access), depersonalization, blocking, removal and destruction.

2.7. “Personal data” is any data, directly or indirectly related to a specific User of the website.

2.8. “User” is any visitor of the website.

2.9. “Disclosure of personal data” is any actions with the purpose of reveling personal data to a specific person or group of people.

2.10. “Personal data spreading” is any action with the purpose of disclosing personal data to the general public (disclosure of personal data) or allowing the general public to access the data, including revealing it in media, publishing it on telecommunication networks or providing access to it by other means.

2.11. “Transborder transfer of personal data” is a transfer of personal data to the territory of other states, foreign authorities, foreign individuals or legal entities.

2.12. “Personal data destruction” is any action to securely destroy personal data with no possibility to restore its contents in personal data information system or destroy physical mediums of the said data. 


3. User Personal Data Processing 

3.1. The Operator can process the following User’s personal data:

1. full name;

2. email address;

3. phone number;

4. The website also collects and process depersonalized visitors’ data (including cookies) using internet statistics services (Yandex.Metrika, Google Analytics, etc.).

3.2. The above-mentioned data will be referred to as Personal Data in this Policy. 


4. Goals of User’s Personal Data Processing 

4.1. The goal of User’s personal data processing is to provide them access to the services, information and/or materials on the website.

4.2. The Operator also has the right to notify the User about new products and services, special offers and various events. The User can decline receiving notifications by sending an email to the Operator at , labeling it “Decline to receive notifications about new products, services and special offers.”

4.3. Depersonalized User data collected via internet statistics services are used to collect information on user actions on the website and to improve the website’s quality and content. 


5. Legal Basis for Personal Data Processing 

5.1. The Operator processes the User’s personal data only when the User personally fills in/submits it through dedicated forms on the website. By filling in the forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.

5.2. The Operator processes depersonalized User data if it is enabled in the User’s browser settings (it saves cookies and JavaScript is on) 


6. Procedure of Collecting, Storage, Disclosure and Other Types of Processing Personal Data 

6.1. In order to protect the personal data the Operator processes, a number of legal, organizational and technical measures are implemented to comply with the current legislation on personal data protection.

6.2. The Operator ensures safety of the personal data and takes in good faith steps to prevent unauthorized access to it.

6.3. Under no circumstances the User’s personal data can be disclosed to third parties, except when required under the current legislation.

6.4. The User can update their personal data on their own if they see any mistakes. To do so, the User shall notify the Operator via email at labeling the email “Personal data actualization.”

6.5. The personal data can be processed indefinitely. The User can revoke their consent by notifying the Operator via email at , labeling the email “Revoking consent to process personal 


7. Transborder Personal Data Transfer 

7.1. Prior to a transborder personal data transfer, the Operator shall ensure that the foreign country, where the data is to be transferred, guarantees the rights of personal data subjects.

7.2. Transborder personal data transfer to countries that do not meet the above requirements, is only possible if the personal data subject gives a written consent to such transfer and/or under an agreement entered by the personal data subject. 


8. Cooperation with the Authorities 

8.1. Under certain conditions, the Operator can disclose personal data from their database to third parties: 

1. to fulfill court demands, requests and rulings;

2. as part of cooperation with law enforcement, investigation and other authorities. The Operator reserves the right to report any illegal activities without notifying the User first;

3. to prevent or help investigate breaches of law, e.g., fraud or stealing identification data;

4. to protect legal rights, property rights or website security, the Operator’s employees, other users or the society in general. 


9. Dispute Resolution 

9.1. Before initiating legal action on the User–Operator relations, it is necessary to submit a claim (written proposal for a settlement agreement).

9.2. The claimee notifies the claimant on the results of the claim consideration within fourteen (14) days from the day of reception.

9.3. If the parties failed to reach an agreement, the case is submitted to the Operator’s home court in accordance with the current Russian legislation.

9.4. This Policy and the User–Operator relations are subject to the current Russian legislation. 


10. Final Provisions 

10.1. The User can ask the Operator for clarification on anything of interest to them regarding their personal data processing via email at

10.2. All changes to the personal data processing policy made by the Operator will be displayed in this document. The Policy is valid indefinitely until replaced with a newer version.

10.3. The up to date version of the Policy is publicly available on internet at

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