PERSONAL DATA PRIVACY POLICY
OF LIMITED LIABILITY COMPANY "65 GIGABYTES"
This Personal Data Privacy Policy (hereinafter referred to as the "Privacy Policy") defines the procedure for processing personal data and measures to ensure the security of personal data of individuals who are Users of the website: https://65apps.com.
The provisions of this Privacy Policy are developed in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as "Federal Law 152").
The Operator is obliged to publish or otherwise provide unrestricted access to this Privacy Policy in accordance with Part 2, Article 18.1 of Federal Law 152.
By using the Website, the User unconditionally agrees to this Policy and the specified terms of processing their personal data. In case of disagreement with these terms, the User must refrain from using the Website and its services that require the provision of the User's personal data.
DEFINITIONS AND TERMS
The following key terms are used in this Privacy Policy:
· Automated processing of personal data - processing of personal data using computer technology;
· Blocking of personal data - temporary suspension of personal data processing (except when processing is necessary to clarify personal data);
· Personal data information system - a set of personal data contained in databases and the information technologies and technical means that ensure their processing;
· Depersonalization of personal data - actions that make it impossible to determine the ownership of personal data to a specific subject without additional information;
· Processing of personal data - any action (operation) or set of actions (operations) performed with personal data, with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
· Operator - Limited Liability Company "65 Gb Software" (abbreviated name: " 65 Gb" LLC, Taxpayer Identification Number (INN): 1832096063, Primary State Registration Number (OGRN): 1121832001389), which independently or jointly with others organizes and/or carries out processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
· Personal data - any information relating to a directly or indirectly identified or identifiable individual (subject of personal data);
· Provision of personal data - actions aimed at disclosing personal data to a specific person or specific group of persons;
· Dissemination of personal data - actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including publication in mass media, placement in information and telecommunication networks, or providing access in any other way;
· Website - https://65apps.com;
· Website Services - functions and capabilities provided on the Website for Users, the use of which requires the provision of the User's personal data;
· Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual or foreign legal entity;
· Destruction of personal data - actions resulting in the impossibility of restoring the content of personal data in the personal data information system and/or destruction of physical media containing personal data.
1. GENERAL PROVISIONS
1.1. Under this Privacy Policy, the User's personal data includes:
1.1.1. Personal data that the User provides about themselves when filling out feedback forms while using the Website (User's last name, first name, patronymic, email), including other personal data provided at the User's discretion, as well as when filling out a candidate questionnaire for the purpose of further contractual relationships (the scope of personal data is established in clause 4.1.1 of this Policy).
1.1.2. Data that is automatically transmitted to the Website's services during their use through the software installed on the User's device, including IP address, cookie data, information about the User's browser (or other program used to access the services), technical characteristics of the equipment and software used by the User, date and time of access to services, addresses of requested pages and other similar information.
1.1.3. This Privacy Policy applies only to the Website https://65apps.com.
1.1.4. The Website does not control and is not responsible for third-party websites that the User may access via links available on the Website.
2. PURPOSES OF PROCESSING USERS' PERSONAL DATA
2.1. The Operator, using the Website, collects and stores only those personal data that are necessary to ensure communication with the User, including for further negotiations, when establishing relationships with the User, including subsequent execution of agreements and contracts, except when the law provides for mandatory storage of personal information for a period established by law.
If the Operator receives a notice from the User about withdrawal of consent to the processing of personal data, the Website stops processing the User's personal data within a period not exceeding 10 working days from the moment of receipt.
The notice of withdrawal of consent to the processing of personal data is sent to the email address: welcome@65apps.com, as well as by written request to the Operator's legal address.
2.2. The Website processes the User's personal data for the following purposes:
2.2.1. Identification of the User registered on the Website.
2.2.2. Establishing feedback with the User, including sending notifications, requests regarding the use of the Website, provision of services, processing requests and applications from the User.
2.2.3. Determining the User's location to ensure security and prevent fraud.
2.2.4. Confirming the accuracy and completeness of personal data provided by the User.
2.2.5. Providing the User with effective customer and technical support in case of problems related to the use of the Website.
3. PRINCIPLES AND CONDITIONS FOR PROCESSING USERS' PERSONAL INFORMATION
3.1. The Operator processes personal data based on the following principles:
· Legality and fair basis;
· Limiting the processing of personal data to achieving specific, predetermined and lawful purposes;
· Preventing the processing of personal data incompatible with the purposes of collecting personal data;
· Preventing the merging of databases containing personal data processed for incompatible purposes;
· Processing only those personal data that meet the purposes of their processing;
· Compliance of the content and volume of processed personal data with the stated purposes of processing;
· Preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;
· Ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
· Destruction or depersonalization of personal data upon achieving the purposes of their processing or in case of loss of the need to achieve these purposes, if the Operator cannot eliminate the violations of personal data, unless otherwise provided by federal law.
3.2. The Operator processes personal data if at least one of the following conditions is met:
· The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
· The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation and performance of the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
· The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
· The processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor;
· 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 goals, provided that the rights and freedoms of the subject of personal data are not violated;
· Processing of personal data is carried access to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data);
· Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
3.3. The confidentiality of the User's personal data is maintained, except in cases where the User voluntarily provides information about himself for general access to an unlimited number of persons.
3.4. The processing of the User’s personal data is carried out for the period necessary to achieve the purpose of processing the User’s personal data, but no more than 3 (three) calendar months (or until the User’s withdrawal of consent), by the following methods: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data, including in personal data information systems with or without the use of automation tools. The processing of Users’ personal data is carried out in accordance with Federal Law No. 152-FZ of July 27, 2006, "On Personal Data."
3.5. In the event of loss or disclosure of the User’s personal data provided through the Website, the Operator shall inform the User about such loss or disclosure.
3.6. The Operator shall take the necessary organizational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.
3.7. The Operator, together with the User, shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.
3.8. The Operator has the right to delegate the processing of personal data to another person, provided that the User has given written consent (unless otherwise stipulated by federal law), based on an agreement concluded with such person. The person processing personal data on behalf of the Operator must comply with the principles and rules of personal data processing stipulated by the current legislation on personal data.
4. RIGHTS AND OBLIGATIONS
4.1. User’s Rights
4.1.1. When providing personal data through the Website, the User confirms their consent to the Operator for the processing of personal data, including:
· Last name, first name, patronymic;
· Date (day, month, year) and place of birth;
· Actual residential address;
· Registration address (place of residence/stay);
· Contact phone number, email address, and/or other means of communication;
· Citizenship details;
· Type, series, number of identity document, issuing authority, and date of issue;
· Taxpayer Identification Number (TIN);
· Individual Insurance Account Number (SNILS);
· Education and/or qualification details (including institution name, graduation year, education level, qualification, document details);
· Marital status, family composition (degree of kinship, names, dates, and places of birth);
· Employment details, including previous workplaces, periods, and work experience;
· Military service details and military registration documents (series, number, issue date, issuing authority);
· Foreign language proficiency;
· Documents permitting residence and employment in the Russian Federation (for foreign citizens);
· Temporary residence permits, residence permits for education purposes (for temporary residents), or permanent residence permits (for permanent residents);
· Other personal data voluntarily provided by the User.
The User understands "processing of personal data" as any action (operation) or set of actions performed with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, anonymization, blocking, deletion, or destruction of personal data. The User’s consent to processing remains valid until withdrawn.
The User makes the decision to provide their personal data and gives consent freely, voluntarily, and in their own interest.
4.1.2. The User has the right to obtain information from the Operator regarding the processing of their personal data, unless restricted by federal laws. The User may request the Operator to clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, as well as take legal measures to protect their rights.
4.1.3. Decisions producing legal consequences for the User or otherwise affecting their rights and interests based solely on automated personal data processing are prohibited, except where permitted by federal laws or with the User’s written consent.
4.1.4. The User retains all rights under Federal Law No. 152-FZ of July 27, 2006, "On Personal Data," and other regulations governing personal data processing.
4.2. User’s Obligations
4.2.1. The User must provide only their own personal data in the scope required by the Website’s forms.
4.3. Operator’s Rights
4.3.1. The Operator has the right to process the User’s personal data provided through the Website.
4.3.2. The Operator may request additional information from the User if necessary for processing purposes.
4.3.3. The Operator may transfer personal data to third parties only with the User’s consent or as required by law.
4.3.4. The Operator may use cookies and other technologies to collect User data but must notify and obtain consent if legally required.
4.3.5. The Operator may take measures to protect personal data from unauthorized access, leakage, or other violations.
4.4. Operator’s Obligations
4.4.1. The Operator must use the obtained information solely for the purposes stated in this Privacy Policy.
4.4.2. The Operator must keep confidential information secret, not disclose it without the User’s prior written consent, and refrain from selling, exchanging, publishing, or otherwise disseminating the User’s personal data, except as provided in this Policy.
4.4.3. Legal, organizational, and technical measures must be implemented to protect personal data from unauthorized access, destruction, modification, blocking, copying, distribution, or other unlawful actions.
4.4.4. The Operator must block personal data upon the User’s request or if inaccurate data or unlawful actions are detected during verification.
5. TRANSFER TO THIRD PARTIES
5.1. The Website may transfer the User’s personal information to third parties in the following cases:5.1.1. The User has consented to such actions.
5.1.2. The transfer is necessary for the User to use a specific service or to fulfill an agreement.
5.1.3. The transfer is required by Russian or applicable law under established legal procedures.
5.1.4. In case of the Website’s sale, the buyer assumes all obligations under this Policy regarding the acquired personal data.
5.2. Cross-border transfer of personal data is permitted only with the User’s written consent. The Operator must ensure that the foreign country provides adequate protection for personal data subjects before such transfer.
5.3. For hosting and maintaining the Website, including storing and processing User data, the Operator may engage providers under agreements ensuring data security.
5.3.1. By using the Website and its services, the User consents to the transfer of their personal data to the Operator’s service providers for Website operation.
6. PERSONAL DATA SECURITY
6.1. Security Measures
The Operator ensures the security of processed personal data by implementing legal, organizational, and technical measures required by federal law.
To prevent unauthorized access, the Operator applies the following measures:
· Appointing officials responsible for data processing and protection;
· Limiting access to personal data;
· Informing personnel of legal and internal requirements;
· Managing storage and handling of data carriers;
· Identifying security threats and developing threat models;
· Creating a personal data protection system;
· Testing security measures for readiness and effectiveness;
· Restricting user access to information resources;
· Logging actions in personal data systems;
· Using antivirus and system recovery tools;
· Applying firewalls, intrusion detection, vulnerability analysis, and encryption where necessary.
7. LIABILITY
7.1. The Operator is liable for damages caused by failure to protect the User’s personal data under Russian law.
7.2. The Operator is not liable if the disclosed personal data:
· Was already public;
· Was received from a third party before the Operator;
· Was disclosed with the User’s consent.
8. ADDITIONAL TERMS
8.1. This Privacy Policy and the relationship between the User and the Operator are governed by Russian law.
8.2. The Operator may amend this Policy without the User’s consent.
8.3. The updated Policy takes effect upon publication on the Website, unless otherwise stated.
OF LIMITED LIABILITY COMPANY "65 GIGABYTES"
This Personal Data Privacy Policy (hereinafter referred to as the "Privacy Policy") defines the procedure for processing personal data and measures to ensure the security of personal data of individuals who are Users of the website: https://65apps.com.
The provisions of this Privacy Policy are developed in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as "Federal Law 152").
The Operator is obliged to publish or otherwise provide unrestricted access to this Privacy Policy in accordance with Part 2, Article 18.1 of Federal Law 152.
By using the Website, the User unconditionally agrees to this Policy and the specified terms of processing their personal data. In case of disagreement with these terms, the User must refrain from using the Website and its services that require the provision of the User's personal data.
DEFINITIONS AND TERMS
The following key terms are used in this Privacy Policy:
· Automated processing of personal data - processing of personal data using computer technology;
· Blocking of personal data - temporary suspension of personal data processing (except when processing is necessary to clarify personal data);
· Personal data information system - a set of personal data contained in databases and the information technologies and technical means that ensure their processing;
· Depersonalization of personal data - actions that make it impossible to determine the ownership of personal data to a specific subject without additional information;
· Processing of personal data - any action (operation) or set of actions (operations) performed with personal data, with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
· Operator - Limited Liability Company "65 Gb Software" (abbreviated name: " 65 Gb" LLC, Taxpayer Identification Number (INN): 1832096063, Primary State Registration Number (OGRN): 1121832001389), which independently or jointly with others organizes and/or carries out processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
· Personal data - any information relating to a directly or indirectly identified or identifiable individual (subject of personal data);
· Provision of personal data - actions aimed at disclosing personal data to a specific person or specific group of persons;
· Dissemination of personal data - actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including publication in mass media, placement in information and telecommunication networks, or providing access in any other way;
· Website - https://65apps.com;
· Website Services - functions and capabilities provided on the Website for Users, the use of which requires the provision of the User's personal data;
· Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual or foreign legal entity;
· Destruction of personal data - actions resulting in the impossibility of restoring the content of personal data in the personal data information system and/or destruction of physical media containing personal data.
1. GENERAL PROVISIONS
1.1. Under this Privacy Policy, the User's personal data includes:
1.1.1. Personal data that the User provides about themselves when filling out feedback forms while using the Website (User's last name, first name, patronymic, email), including other personal data provided at the User's discretion, as well as when filling out a candidate questionnaire for the purpose of further contractual relationships (the scope of personal data is established in clause 4.1.1 of this Policy).
1.1.2. Data that is automatically transmitted to the Website's services during their use through the software installed on the User's device, including IP address, cookie data, information about the User's browser (or other program used to access the services), technical characteristics of the equipment and software used by the User, date and time of access to services, addresses of requested pages and other similar information.
1.1.3. This Privacy Policy applies only to the Website https://65apps.com.
1.1.4. The Website does not control and is not responsible for third-party websites that the User may access via links available on the Website.
2. PURPOSES OF PROCESSING USERS' PERSONAL DATA
2.1. The Operator, using the Website, collects and stores only those personal data that are necessary to ensure communication with the User, including for further negotiations, when establishing relationships with the User, including subsequent execution of agreements and contracts, except when the law provides for mandatory storage of personal information for a period established by law.
If the Operator receives a notice from the User about withdrawal of consent to the processing of personal data, the Website stops processing the User's personal data within a period not exceeding 10 working days from the moment of receipt.
The notice of withdrawal of consent to the processing of personal data is sent to the email address: welcome@65apps.com, as well as by written request to the Operator's legal address.
2.2. The Website processes the User's personal data for the following purposes:
2.2.1. Identification of the User registered on the Website.
2.2.2. Establishing feedback with the User, including sending notifications, requests regarding the use of the Website, provision of services, processing requests and applications from the User.
2.2.3. Determining the User's location to ensure security and prevent fraud.
2.2.4. Confirming the accuracy and completeness of personal data provided by the User.
2.2.5. Providing the User with effective customer and technical support in case of problems related to the use of the Website.
3. PRINCIPLES AND CONDITIONS FOR PROCESSING USERS' PERSONAL INFORMATION
3.1. The Operator processes personal data based on the following principles:
· Legality and fair basis;
· Limiting the processing of personal data to achieving specific, predetermined and lawful purposes;
· Preventing the processing of personal data incompatible with the purposes of collecting personal data;
· Preventing the merging of databases containing personal data processed for incompatible purposes;
· Processing only those personal data that meet the purposes of their processing;
· Compliance of the content and volume of processed personal data with the stated purposes of processing;
· Preventing the processing of personal data that is excessive in relation to the stated purposes of their processing;
· Ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
· Destruction or depersonalization of personal data upon achieving the purposes of their processing or in case of loss of the need to achieve these purposes, if the Operator cannot eliminate the violations of personal data, unless otherwise provided by federal law.
3.2. The Operator processes personal data if at least one of the following conditions is met:
· The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
· The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation and performance of the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
· The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
· The processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor;
· 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 goals, provided that the rights and freedoms of the subject of personal data are not violated;
· Processing of personal data is carried access to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data);
· Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
3.3. The confidentiality of the User's personal data is maintained, except in cases where the User voluntarily provides information about himself for general access to an unlimited number of persons.
3.4. The processing of the User’s personal data is carried out for the period necessary to achieve the purpose of processing the User’s personal data, but no more than 3 (three) calendar months (or until the User’s withdrawal of consent), by the following methods: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data, including in personal data information systems with or without the use of automation tools. The processing of Users’ personal data is carried out in accordance with Federal Law No. 152-FZ of July 27, 2006, "On Personal Data."
3.5. In the event of loss or disclosure of the User’s personal data provided through the Website, the Operator shall inform the User about such loss or disclosure.
3.6. The Operator shall take the necessary organizational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.
3.7. The Operator, together with the User, shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.
3.8. The Operator has the right to delegate the processing of personal data to another person, provided that the User has given written consent (unless otherwise stipulated by federal law), based on an agreement concluded with such person. The person processing personal data on behalf of the Operator must comply with the principles and rules of personal data processing stipulated by the current legislation on personal data.
4. RIGHTS AND OBLIGATIONS
4.1. User’s Rights
4.1.1. When providing personal data through the Website, the User confirms their consent to the Operator for the processing of personal data, including:
· Last name, first name, patronymic;
· Date (day, month, year) and place of birth;
· Actual residential address;
· Registration address (place of residence/stay);
· Contact phone number, email address, and/or other means of communication;
· Citizenship details;
· Type, series, number of identity document, issuing authority, and date of issue;
· Taxpayer Identification Number (TIN);
· Individual Insurance Account Number (SNILS);
· Education and/or qualification details (including institution name, graduation year, education level, qualification, document details);
· Marital status, family composition (degree of kinship, names, dates, and places of birth);
· Employment details, including previous workplaces, periods, and work experience;
· Military service details and military registration documents (series, number, issue date, issuing authority);
· Foreign language proficiency;
· Documents permitting residence and employment in the Russian Federation (for foreign citizens);
· Temporary residence permits, residence permits for education purposes (for temporary residents), or permanent residence permits (for permanent residents);
· Other personal data voluntarily provided by the User.
The User understands "processing of personal data" as any action (operation) or set of actions performed with or without automation tools, including collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, anonymization, blocking, deletion, or destruction of personal data. The User’s consent to processing remains valid until withdrawn.
The User makes the decision to provide their personal data and gives consent freely, voluntarily, and in their own interest.
4.1.2. The User has the right to obtain information from the Operator regarding the processing of their personal data, unless restricted by federal laws. The User may request the Operator to clarify, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose, as well as take legal measures to protect their rights.
4.1.3. Decisions producing legal consequences for the User or otherwise affecting their rights and interests based solely on automated personal data processing are prohibited, except where permitted by federal laws or with the User’s written consent.
4.1.4. The User retains all rights under Federal Law No. 152-FZ of July 27, 2006, "On Personal Data," and other regulations governing personal data processing.
4.2. User’s Obligations
4.2.1. The User must provide only their own personal data in the scope required by the Website’s forms.
4.3. Operator’s Rights
4.3.1. The Operator has the right to process the User’s personal data provided through the Website.
4.3.2. The Operator may request additional information from the User if necessary for processing purposes.
4.3.3. The Operator may transfer personal data to third parties only with the User’s consent or as required by law.
4.3.4. The Operator may use cookies and other technologies to collect User data but must notify and obtain consent if legally required.
4.3.5. The Operator may take measures to protect personal data from unauthorized access, leakage, or other violations.
4.4. Operator’s Obligations
4.4.1. The Operator must use the obtained information solely for the purposes stated in this Privacy Policy.
4.4.2. The Operator must keep confidential information secret, not disclose it without the User’s prior written consent, and refrain from selling, exchanging, publishing, or otherwise disseminating the User’s personal data, except as provided in this Policy.
4.4.3. Legal, organizational, and technical measures must be implemented to protect personal data from unauthorized access, destruction, modification, blocking, copying, distribution, or other unlawful actions.
4.4.4. The Operator must block personal data upon the User’s request or if inaccurate data or unlawful actions are detected during verification.
5. TRANSFER TO THIRD PARTIES
5.1. The Website may transfer the User’s personal information to third parties in the following cases:5.1.1. The User has consented to such actions.
5.1.2. The transfer is necessary for the User to use a specific service or to fulfill an agreement.
5.1.3. The transfer is required by Russian or applicable law under established legal procedures.
5.1.4. In case of the Website’s sale, the buyer assumes all obligations under this Policy regarding the acquired personal data.
5.2. Cross-border transfer of personal data is permitted only with the User’s written consent. The Operator must ensure that the foreign country provides adequate protection for personal data subjects before such transfer.
5.3. For hosting and maintaining the Website, including storing and processing User data, the Operator may engage providers under agreements ensuring data security.
5.3.1. By using the Website and its services, the User consents to the transfer of their personal data to the Operator’s service providers for Website operation.
6. PERSONAL DATA SECURITY
6.1. Security Measures
The Operator ensures the security of processed personal data by implementing legal, organizational, and technical measures required by federal law.
To prevent unauthorized access, the Operator applies the following measures:
· Appointing officials responsible for data processing and protection;
· Limiting access to personal data;
· Informing personnel of legal and internal requirements;
· Managing storage and handling of data carriers;
· Identifying security threats and developing threat models;
· Creating a personal data protection system;
· Testing security measures for readiness and effectiveness;
· Restricting user access to information resources;
· Logging actions in personal data systems;
· Using antivirus and system recovery tools;
· Applying firewalls, intrusion detection, vulnerability analysis, and encryption where necessary.
7. LIABILITY
7.1. The Operator is liable for damages caused by failure to protect the User’s personal data under Russian law.
7.2. The Operator is not liable if the disclosed personal data:
· Was already public;
· Was received from a third party before the Operator;
· Was disclosed with the User’s consent.
8. ADDITIONAL TERMS
8.1. This Privacy Policy and the relationship between the User and the Operator are governed by Russian law.
8.2. The Operator may amend this Policy without the User’s consent.
8.3. The updated Policy takes effect upon publication on the Website, unless otherwise stated.