Personal Data Processing Policy

1. General provisions

This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”. It describes how the self-employed individual Semen Aleksandrovich Krushin (the Operator) processes personal data and protects it.

The Operator regards the protection of human and civil rights and freedoms, including the rights to privacy and personal and family confidentiality, as a primary objective when processing personal data.

This Policy applies to all information that the Operator may obtain about visitors to the DGenius website.

2. Terms used in this Policy

• Automated processing of personal data means processing personal data using computer technology.
• Blocking personal data means temporarily suspending its processing, except where processing is required to clarify that data.
• Website means the collection of graphic and informational materials, software and databases that make the website available online.
• Personal data information system means the personal data contained in databases together with the technologies and technical means used to process it.
• Anonymisation means actions that make it impossible to determine, without additional information, which User the personal data belongs to.
• Processing personal data means any action or set of actions involving personal data, including collection, recording, organisation, storage, updating, use, transfer, anonymisation, blocking, deletion and destruction.
• Operator means a person who independently or jointly organises and performs personal data processing and determines its purposes.
• Personal data means any information relating directly or indirectly to an identified or identifiable website User.
• Personal data authorised for dissemination means data to which the data subject has granted access to an unlimited number of persons.
• User means any visitor to the website.
• Provision of personal data means actions intended to disclose personal data to a particular person or group of persons.
• Dissemination of personal data means actions intended to disclose personal data to an unlimited number of persons.
• Cross-border transfer of personal data means transferring personal data to a foreign state authority or to a foreign individual or legal entity.
• Destruction of personal data means actions after which the data cannot be restored.

3. The Operator’s rights and obligations

The Operator may request accurate information and documents from a data subject, independently determine the measures required to comply with personal data law, and continue processing without consent where the law provides a valid basis.

• Provide a data subject, upon request, with information about the processing of their personal data.
• Organise personal data processing in accordance with applicable Russian law.
• Respond to requests from data subjects and their legal representatives.
• Ensure that this Policy remains publicly accessible.
• Use legal, organisational and technical measures to protect personal data from unlawful or accidental access and other unlawful actions.
• Stop transferring or processing personal data and destroy it when required by law.
• Fulfil all other obligations established by personal data law.

4. Data subjects’ rights and obligations

• Receive information about the processing of their personal data in an accessible form.
• Request correction, blocking or destruction of data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose.
• Require prior consent before personal data is used to promote goods, work or services.
• Withdraw consent to personal data processing.
• Challenge unlawful acts or omissions by the Operator before the competent authority or a court.
• Provide accurate personal data and notify the Operator of corrections, updates or changes.
• Anyone who provides false information about themselves or another person’s data without that person’s consent is liable under applicable law.

5. Personal data the Operator may process

Telephone numbers.

The website may also collect and process anonymised visitor data, including cookies, through web analytics services such as Yandex Metrica, Google Analytics and similar services.

The information listed above is collectively referred to in this Policy as Personal Data.

The Operator does not process special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, or intimate life.

Consent to process personal data authorised for dissemination is obtained separately from other consents. Dissemination stops at the data subject’s request in the manner prescribed by law.

6. Personal data processing principles

• Personal data is processed lawfully and fairly.
• Processing is limited to specific, predetermined and lawful purposes.
• Databases processed for incompatible purposes are not combined.
• Only data relevant to the processing purposes is processed.
• The content and volume of processed data are proportionate to the stated purposes and are not excessive.
• The Operator maintains the accuracy, sufficiency and relevance of data and corrects it where necessary.
• Data is retained no longer than required for the processing purposes unless a different period is established by law or contract. Once those purposes are achieved, the data is destroyed or anonymised.

7. Purposes of personal data processing

The User’s personal data is processed to provide consultations and feedback.

The Operator may also notify the User about new products and services, special offers and events. The User may opt out by emailing manager@dgenius.ru with the subject “Opt out of product, service and special-offer notifications”.

Anonymised analytics data is used to understand User activity and improve the website and its content.

8. Legal grounds for processing personal data

• Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”.
• Federal laws and other regulations governing personal data protection.
• Users’ consent to process personal data and data authorised for dissemination.
• The Operator processes data only when a User submits it through a website form or by email. By submitting data, the User consents to this Policy.
• Anonymised data is processed when the User’s browser settings permit cookies and JavaScript.
• The User decides independently whether to provide personal data and gives consent freely, voluntarily and in their own interest.

9. Conditions for processing personal data

• Processing is carried out with the data subject’s consent.
• Processing is required for purposes established by an international treaty of the Russian Federation or by law.
• Processing is required for the administration of justice or enforcement of a court decision.
• Processing is required to perform a contract or enter into a contract at the data subject’s initiative.
• Processing is required to exercise the legitimate rights and interests of the Operator or third parties, provided the data subject’s rights and freedoms are respected.
• The data subject has made the processed data publicly accessible.
• The data must be published or disclosed under federal law.

10. Collection, storage, transfer and other processing

The Operator protects personal data through the legal, organisational and technical measures required by applicable law.

The Operator safeguards personal data and takes measures to prevent unauthorised access.

Personal data is not transferred to third parties except where required by law or where the data subject has consented to a transfer needed to perform obligations under a civil contract.

To correct inaccurate data, the User may email manager@dgenius.ru with the subject “Personal data update”.

Processing continues until the purposes for which the data was collected are achieved. The User may withdraw consent by emailing manager@dgenius.ru with the subject “Withdrawal of consent to personal data processing”.

Information collected by third-party services is stored and processed by those parties under their own terms and privacy policies. The Operator is not responsible for third-party actions.

The Operator keeps personal data confidential and retains it no longer than required for its purposes unless a different period is established by law or contract.

11. Actions performed with personal data

The Operator may collect, record, organise, accumulate, store, update, retrieve, use, transfer, anonymise, block, delete and destroy personal data.

The Operator performs automated processing with or without receiving and transmitting information over telecommunications networks.

12. Cross-border transfers

Before transferring personal data across borders, the Operator must ensure that the destination country provides reliable protection of data subjects’ rights.

Data may be transferred to a country that does not meet this requirement only with the data subject’s written consent or where necessary to perform a contract to which the data subject is a party.

13. Confidentiality

The Operator and any other person with access to personal data must not disclose or disseminate it without the data subject’s consent unless federal law provides otherwise.

14. Final provisions

For explanations about personal data processing, the User may contact the Operator at manager@dgenius.ru.

This document is updated when the Operator changes its personal data practices. It remains effective until replaced by a new version.

The current version of this Policy is publicly available on the DGenius website.