Personal Data Processing and Protection Policy

This English translation is provided for convenience only. In case of any discrepancy between the English and Russian versions, the Russian version prevails.

1. General provisions

This Personal Data Processing and Protection Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (the “Personal Data Law”) and determines the procedure for processing personal data and the measures to ensure the security of personal data taken by Intelligence Technologies LLC, INN 3665835541, registered under the laws of the Russian Federation at the address: 394018, Voronezh, Platonova St., 11/1, apt. 29 (the “Operator”).

1.1. The Operator’s most important objective and a condition for carrying out its activities is the observance of the rights and freedoms of the individual and citizen in the processing of their personal data, including the protection of the rights to the inviolability of private life and to personal and family secrets.

1.2. This policy of the Operator regarding the processing and protection of personal data (the “Policy”) applies to all information that the Operator may obtain about visitors to the website http://teh-intel.ru/.

2. Basic terms used in the Policy

2.1. Automated processing of personal data — processing of personal data by means of computer technology.

2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to rectify personal data).

2.3. Website — a set of graphic and information materials, together with the computer programs and databases that make them available on the Internet at the network address http://teh-intel.ru/.

2.4. Personal data information system — a set of personal data contained in databases, together with the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belong to a specific User or another data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual that, alone or jointly with other persons, organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website http://teh-intel.ru/.

2.9. Personal data authorized by the data subject for dissemination — personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized by the data subject for dissemination in the manner prescribed by the Personal Data Law (“personal data authorized for dissemination”).

2.10. User — any visitor to the website http://teh-intel.ru/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data known to an unlimited number of persons, including publication of personal data in the mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.

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

2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, making it impossible to subsequently restore the content of the personal data in the personal data information system, and/or the physical media containing personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the data subject;
• if the data subject withdraws consent to the processing of personal data or sends a request demanding that the processing of personal data be stopped, continue processing personal data without the data subject’s consent where there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the data subject, at the data subject’s request, with information concerning the processing of their personal data;
• organize the processing of personal data in the manner established by the applicable legislation of the Russian Federation;
• respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the authorized body for the protection of the rights of data subjects, at that body’s request, with the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision and dissemination of personal data, as well as against other unlawful actions in respect of personal data;
• stop the transfer (dissemination, provision, access) of personal data, stop the processing of and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
• perform other obligations provided for by the Personal Data Law.

4. Basic rights and obligations of data subjects

4.1. Data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• demand that the operator rectify, block or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and take measures provided for by law to protect their rights;
• make prior consent a condition for the processing of personal data for the purpose of promoting goods, works and services on the market;
• withdraw consent to the processing of personal data and send a demand to stop the processing of personal data;
• appeal against unlawful actions or omissions of the Operator in the processing of their personal data to the authorized body for the protection of the rights of data subjects or in court;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Data subjects are obliged to:

• provide the Operator with reliable data about themselves;
• notify the Operator of any rectification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves, or with information about another data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting the personal data is not permitted.

5.3. It is not permitted to combine databases containing personal data that are processed for purposes incompatible with each other.

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

5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of their processing.

5.6. When personal data are processed, their accuracy, sufficiency and, where necessary, relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or rectify incomplete or inaccurate data.

5.7. Personal data are stored in a form that allows the data subject to be identified for no longer than the purposes of processing personal data require, unless the storage period for personal data is established by federal law or by a contract to which the data subject is a party or under which the data subject is a beneficiary or guarantor. The personal data processed are destroyed or depersonalized once the purposes of processing have been achieved or if it is no longer necessary to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of processing and types of personal data.

6.1. Purposes of processing the User’s personal data:

• handling Users’ inquiries and requests received on the website https://teh-intel.ru/. Data: surname, first name, phone number, email address. Legal basis: consent of the data subject (Part 1 of Article 6 of Federal Law No. 152-FZ). Retention period: 3 years from the last interaction or withdrawal of consent.
• providing the User with access to the services, information and/or materials contained on the website https://teh-intel.ru/. Data: surname, first name, phone number, email address. Legal basis: consent of the data subject (Part 1 of Article 6 of Federal Law No. 152-FZ). Retention period: 3 years from the last interaction or withdrawal of consent.
• Analytics of Users’ visits to the website (Yandex Metrica). Data: IP address, cookies, browser and device type, behavior on the website. Legal basis: consent of the data subject (Part 1 of Article 6 of Federal Law No. 152-FZ), expressed by accepting the Cookie Policy. Retention period: 12 months or until consent is withdrawn. The data are processed on the servers of Yandex LLC in the territory of the Russian Federation.

6.2. Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data.

6.3. In the rest of the Policy, the data listed above are collectively referred to as “Personal Data”.

6.4. The Operator does not process special categories of personal data relating to racial or national origin, political views, religious or philosophical beliefs, or intimate life.

6.5. The User’s consent to the processing of personal data authorized for dissemination is executed separately from other consents to the processing of their personal data. In doing so, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of data subjects.

6.5.1. The User gives consent to the processing of personal data authorized for dissemination directly to the Operator.

6.5.2. The transfer of personal data authorized by the data subject for dissemination must be stopped at any time at the demand of the data subject. The personal data specified in such a demand may be processed only by the Operator to which it is addressed.

6.5.3. Consent to the processing of personal data authorized for dissemination ceases to be effective from the moment the Operator receives the demand referred to in clause 6.5.2 of this Policy regarding the processing of personal data.

7. Legal grounds for processing personal data.

7.1. The legal grounds for the processing of personal data by the Operator are:

• Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”;
• contracts concluded between the operator and the data subject;
• other regulatory legal acts in the field of personal data protection;
• Users’ consents to the processing of their personal data and to the processing of personal data authorized for dissemination.

7.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://teh-intel.ru/ or sent to the Operator by email. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

7.3. The Operator processes depersonalized data about the User if this is permitted in the User’s browser settings (saving of cookies and the use of JavaScript technology are enabled).

7.4. The data subject independently decides whether to provide their personal data and gives consent freely, of their own will and in their own interest.

8. Conditions for processing personal data

8.1. Personal data are processed with the consent of the data subject to the processing of their personal data.

8.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or to exercise the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

8.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

8.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party or under which the data subject is a beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.

8.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not violated.

8.6. Personal data to which access by an unlimited number of persons has been granted by the data subject or at the data subject’s request (“publicly available personal data”) are processed.

8.7. Personal data that are subject to publication or mandatory disclosure in accordance with federal law are processed.

9. Procedure for the collection, storage, transfer and other types of processing of personal data

9.1. The security of personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to comply in full with the requirements of applicable legislation in the field of personal data protection.

9.2. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

9.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.

9.4. If inaccuracies are found in the personal data, the User may update them independently by sending a notice to the Operator’s email address inbox@teh-intel.ru marked “Personal data update”.

9.5. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable legislation. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notice by email to the Operator’s email address inbox@teh-intel.ru marked “Withdrawal of consent to personal data processing”.

9.6. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

9.7. Prohibitions established by the data subject on the transfer (except for granting access) of personal data authorized for dissemination, as well as on their processing or conditions of processing (except for obtaining access), do not apply in cases where personal data are processed in the state, social and other public interests defined by the legislation of the Russian Federation.

9.8. When processing personal data, the Operator ensures the confidentiality of personal data.

9.9. The Operator stores personal data in a form that allows the data subject to be identified for no longer than the purposes of processing personal data require, unless the storage period for personal data is established by federal law or by a contract to which the data subject is a party or under which the data subject is a beneficiary or guarantor.

9.10. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiry of the data subject’s consent, the withdrawal of consent by the data subject or a demand to stop the processing of personal data, as well as the detection of unlawful processing of personal data.

9.11. Databases containing personal data of citizens of the Russian Federation are located on the Operator’s servers in the territory of the Russian Federation in accordance with the requirements of Article 18.1 of Federal Law No. 152-FZ. Analytics data collected through the Yandex Metrica service are stored on the servers of Yandex LLC (Russia, 119021, Moscow, Lva Tolstogo St., 16).

10. List of actions performed by the Operator with the personal data obtained

10.1. The Operator carries out the collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.

10.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained via information and telecommunication networks.

11. Cross-border transfer of personal data

11.1. Before starting cross-border transfers of personal data, the Operator must notify the authorized body for the protection of the rights of data subjects of its intention to carry out cross-border transfers of personal data (such notification is sent separately from the notification of the intention to process personal data).

11.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is planned.

12. Confidentiality of personal data

The Operator and other persons who have obtained access to personal data must not disclose personal data to third parties or disseminate them without the consent of the data subject, unless otherwise provided by federal law.

13. Final provisions

13.1. The User may obtain any clarifications on matters of interest concerning the processing of their personal data by contacting the Operator by email at inbox@teh-intel.ru.

13.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.

13.3. The current version of the Policy is freely available on the Internet at https://teh-intel.ru/docs/privacy/