Personal data processing policy

This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by LLC "SalesSolution" (hereinafter referred to as the Operator) to ensure the security of personal data.

1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data — including the right to privacy, personal and family secrets — as one of its most important objectives and conditions for carrying out its activities.
2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the websit  https://salessolution.ru/.

1. Automated processing of personal data – the processing of personal data using computer technology.
2. Blocking of personal data – the temporary suspension of personal data processing (except in cases where processing is necessary to clarify the personal data).
3. Website – a collection of graphic and informational materials, as well as software and databases, made available on the Internet at  https://salessolution.ru/.
4. Personal data information system – a set of personal data contained in databases and the information technologies and technical tools used for its processing.
5. Depersonalization of personal data – actions that make it impossible to identify the personal data as belonging to a specific User or other data subject without the use of additional information.
6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
7. Operator – a legal entity that, independently or jointly with others, organizes and/or performs the processing of personal data, and also determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.
8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website.
9. Personal data permitted by the subject for distribution – personal data to which the data subject has granted access to an unlimited number of persons by giving consent to their processing in accordance with the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").
10. User – any visitor to the website.
11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data accessible to an unlimited number of persons, including publication in mass media, posting in information and telecommunication networks, or providing access to personal data by any other means.
13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state, to a foreign state authority, or to a foreign individual or legal entity.
14. Destruction of personal data – any actions that result in the irreversible destruction of personal data, making it impossible to restore the content of the personal data in a personal data information system and/or the destruction of tangible media containing personal data.

1. The Operator has the right to:
   • receive accurate information and/or documents containing personal data from the personal data subject;
   • continue processing personal data without the subject's consent in the event of withdrawal of consent or submission of a request to stop processing, if there are legal grounds as specified by the Personal Data Law;
   • independently determine the list and scope of measures necessary and sufficient to fulfill the obligations set forth by the Personal Data Law and relevant regulatory legal acts, unless otherwise specified by the Personal Data Law or other federal laws.
2. The Operator is obligated to:
   • provide the personal data subject, upon request, with information regarding the processing of their personal data;
   • organize the processing of personal data in accordance with the legislation of the Russian Federation;
   • respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
   • provide the authorized body for the protection of personal data subjects’ rights with the required information within 10 days of receiving an official request;
   • publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
   • take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and from other illegal actions;
   • cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data as specified by the Personal Data Law;
   • fulfill other obligations as prescribed by the Personal Data Law.

1. Personal data subjects have the right to:
   • receive information regarding the processing of their personal data, except in cases provided for by federal law. This information must be provided by the Operator in an accessible format and must not contain personal data relating to other subjects unless there are legal grounds for such disclosure. The scope and procedure for obtaining this information are defined by the Personal Data Law;
   • request that the Operator clarify, block, or delete their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the declared purpose of processing, and to take legal measures to protect their rights;
   • require prior consent to the processing of personal data for the purpose of promoting goods, works, and services in the market;
   • withdraw their consent to personal data processing, as well as submit a request to stop such processing;
   • appeal to the authorized body for the protection of the rights of personal data subjects or to the court in the event of unlawful actions or inaction by the Operator regarding the processing of their personal data;
   • exercise other rights granted by the legislation of the Russian Federation.
2. Personal data subjects are obligated to:
   • provide the Operator with accurate information about themselves;
   • inform the Operator of any clarifications (updates or changes) to their personal data.
3. Individuals who provide the Operator with false information about themselves, or personal data of another person without that person's consent, bear responsibility in accordance with the legislation of the Russian Federation.

1. The processing of personal data is carried out on a lawful and fair basis.
2. The processing of personal data is limited to the achievement of specific, pre-defined, and lawful purposes. Processing that is incompatible with the purposes of personal data collection is not permitted.
3. The merging of databases containing personal data processed for purposes that are incompatible with one another is not allowed.
4. Only personal data that is relevant to the stated purposes of processing is subject to processing.
5. The content and volume of processed personal data must correspond to the declared purposes of processing. Excessive data processing in relation to those purposes is not permitted.
6. Accuracy, sufficiency, and, where necessary, relevance of personal data must be ensured during processing. The Operator takes the necessary measures, or ensures that such measures are taken, to delete or clarify incomplete or inaccurate data.
7. Personal data must be stored in a format that allows identification of the personal data subject for no longer than is required to fulfill the purposes of processing, unless a longer retention period is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. Once the purposes of processing have been achieved, or when they are no longer necessary, the processed personal data must be destroyed or anonymized, unless otherwise provided by federal law.

The purpose of processing the User’s personal data is to provide the User with access to the services, information, and/or materials available on the website.

1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
2. The processing of personal data is necessary to achieve the goals established by an international treaty of the Russian Federation or by law, and to fulfill the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, or for the conclusion of a contract at the request of the personal data subject or a contract under which the subject will be a beneficiary or guarantor.
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 objectives, provided this does not violate the rights and freedoms of the personal data subject.
6. Personal data is processed when access to it has been granted by the subject to an unlimited number of persons or upon the subject’s request (hereinafter — publicly available personal data).
7. Personal data is processed when it is subject to publication or mandatory disclosure in accordance with federal law.

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

1. The Operator guarantees the confidentiality of personal data and takes all possible measures to prevent unauthorized access to such data.
2. The User’s personal data will never be transferred to third parties under any circumstances, except in cases required by applicable law or when the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
3. If any inaccuracies are found in the personal data, the User may update the information independently by sending a notification to the Operator’s email address:  personaldata@salessolution.ru  with the subject line “Update of Personal Data.”
4. The period of personal data processing is determined by the achievement of the purposes for which the data was collected, unless a different period is stipulated by a contract or applicable law.
   The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator via email at   personaldata@salessolution.ru   with the subject line “Withdrawal of Consent to Personal Data Processing.”
5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by such parties in accordance with their own User Agreements and Privacy Policies. The Operator is not responsible for the actions of such third parties.
6. Any restrictions set by the personal data subject on the transfer (except for access), as well as on the processing or conditions of processing of personal data permitted for distribution, shall not apply when such processing is carried out for state, public, or other legally significant interests as defined by the legislation of the Russian Federation.
7. The Operator ensures the confidentiality of personal data during processing.
8. The Operator stores personal data in a format that allows identification of the data subject for no longer than necessary to achieve the purposes of processing, unless a longer retention period is specified by federal law or a contract to which the data subject is a party, beneficiary, or guarantor.
9. The processing of personal data may be terminated upon achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, a request for termination of processing, or if unlawful processing is identified.

1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2. The Operator carries out automated processing of personal data, with or without the transmission and/or receipt of the processed information via information and telecommunication networks.

1. Before commencing any cross-border transfer of personal data, the Operator is required to notify the authorized body responsible for the protection of personal data subjects' rights of its intention to carry out such transfers (this notification must be submitted separately from the general notification of intent to process personal data).
2. Prior to submitting the above-mentioned notification, the Operator must obtain the necessary information from the foreign state authorities, foreign individuals, or foreign legal entities to whom the personal data is intended to be transferred.

The Operator and any other persons who have access to personal data are obliged not to disclose or distribute such data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

1. The User may request clarification on any matters related to the processing of their personal data by contacting the Operator via email at  personaldata@salessolution.ru.
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.
3. The current version of the Policy is publicly available on the Internet at the following address.