PERSONAL DATA PROCESSING POLICY

as amended on 04.08.2025

1. GENERAL PROVISIONS

1.1. This document (hereinafter referred to as the Policy) defines the policy regarding the processing of personal data of the Operator OOO "ES-U" (TIN: 9725025993, OGRN: 1197746714274).
1.2. This Policy has been developed in compliance with the requirements of paragraph 2 of part 1 of Article 18.1 of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data). The Policy has been developed taking into account the requirements of the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation in the field of personal data.
1.3. This Policy applies to all operations performed by the Operator with personal data, with or without the use of automation tools.
1.4. This Policy is subject to update in the event of changes in the legislation of the Russian Federation on personal data.

2. BASIC CONCEPTS USED IN THE POLICY

2.1. For the purposes of this Policy, the following terms are used in the following meaning:
Personal data - any information related to a directly or indirectly determined or determinable individual (subject of personal data).
Operator - a government agency, municipal body, legal entity or individual that independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
Subject of personal data - any person whose personal data the operator has received.
The website is a collection of graphic and information materials, as well as computer programs and databases that make them available on the Internet at the network address https://sever-yug.com;
Personal data processing is any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
Automated processing of personal data is the processing of personal data using computer technology;
Distribution of personal data is actions aimed at disclosing personal data to an indefinite number of persons.
Provision of personal data is actions aimed at disclosing personal data to a specific person or a specific number of persons.
Blocking of personal data is a temporary cessation of the processing of personal data (except in cases where the processing is necessary to clarify personal data).
Destruction of personal data – actions that make it impossible to restore the content of personal data in the personal data information system and (or) that make it impossible to destroy the tangible media of personal data.
Depersonalization of personal data – actions that make it impossible to determine the ownership of personal data by a specific subject of personal data without using additional information.
Personal data information system – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign government agency, a foreign individual or a foreign legal entity.
Consent to the processing of personal data is the voluntary performance of implicative actions by the Subject of personal data when filling out the Application on the website https://sever-yug.com, namely, putting a mark in the appropriate column, which is provided for the expression by the Subject of personal data of consent to the processing of the personal data provided by him and unconditional acceptance of the procedure and conditions of the Public offer for the conclusion of an agreement for the paid provision of a set of information and consulting services and this Policy regarding the processing of personal data.

3. PRINCIPLES AND PURPOSES OF PERSONAL DATA PROCESSING

3.1. The Operator processes personal data taking into account the need to ensure the protection of the rights and freedoms of personal data subjects, including the protection of the right to privacy, personal and family secrets, based on the following principles:
personal data is processed on a lawful and fair basis;
personal data processing is limited to achieving specific, predetermined and legitimate goals;
personal data processing that is incompatible with the purposes of collecting personal data is not allowed;
databases containing personal data processed for purposes incompatible with each other are not allowed to be combined;
only personal data that meet the purposes of their processing are subject to processing;
the content and volume of personal data being processed correspond to the stated purposes of processing. Excessive amounts of personal data processed in relation to the stated purposes of their processing are not allowed;
when processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured;
personal data is stored in a form that allows identifying the subject of personal data, for no longer than required for the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor;
processed personal data are destroyed or depersonalized upon achieving the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
3.2. Processing of personal data https://sever-yug.com is carried out for the purpose of:
identification of the Subject for the purpose of concluding any agreements and their subsequent execution;
conducting by the Operator of promotions, surveys, interviews, testing and research on the website https://sever-yug.com
establishing feedback with the Subject, including, but not limited to: sending mailings, notifications in the form of SMS messages, emails, oral and written requests, processing requests and applications from the Subject;
confirmation of the accuracy and completeness of personal data provided by the Subject;
for statistical and other research purposes, subject to the anonymization of the personal data of the Subjects,
fulfillment of the powers and duties imposed on the Operator by the legislation of the Russian Federation.

4. VOLUME AND CATEGORIES OF PROCESSED PERSONAL DATA, CATEGORIES OF PERSONAL DATA SUBJECTS

4.1. The Operator may process personal data of the following personal data subjects:
clients and counterparties (individuals);
visitors to the website https://sever-yug.com
4.2. The personal data processed by the Operator include:
last name, first name, patronymic name of the personal data subject;
place of residence;
specialty/area of professional interests;
mobile phone number;
e-mail address (e-mail);
history of requests and views on the Website and its services (for visitors to the Websites);
other information (the above list may be shortened or expanded depending on the specific case and purposes of processing).
4.3. The Operator ensures that the content and volume of the processed personal data correspond to the stated purposes of processing and, if necessary, takes measures to eliminate their redundancy in relation to the stated purposes of processing.

5. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA

5.1. The Operator processes personal data in the following ways:
non-automated processing of personal data;
automated processing of personal data with or without the transfer of the received information via information and telecommunications networks;
mixed processing of personal data.
5.2. The list of actions performed by the Operator with personal data: collection, systematization, accumulation, storage, clarification (updating, modification), use, distribution (including transfer), depersonalization, blocking, destruction, as well as the implementation of any other actions in accordance with the current legislation of the Russian Federation.
5.3. The subject of personal data makes a decision on the provision of his personal data and gives Consent freely, of his own free will and in his own interests.
5.4. The Operator does not process biometric personal data.
5.5. The Operator does not carry out cross-border transfer of personal data.
5.6. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. The termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the Consent or revocation of Consent by the personal data subject, as well as the detection of unlawful processing of personal data.
5.8. The period of personal data processing is unlimited. The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator's e-mail address: saeed.jalalifarr1962@gmail.com with the subject line "Revocation of consent to the processing of personal data".

6. MAIN RIGHTS AND RESPONSIBILITIES

6.1. The Operator has the right to:
6.1.1. receive reliable information and/or documents containing personal data from the personal data subject;
6.1.2. require the personal data subject to promptly clarify the personal data provided.
6.2. The Operator is obliged to:
6.2.1. process personal data in the manner prescribed by the current legislation of the Russian Federation;
6.2.2. consider requests from the personal data subject (his or her legal representative) regarding the processing of personal data and provide reasoned responses;
6.2.3. provide the personal data subject (his or her legal representative) with the opportunity to access his or her personal data free of charge;
6.2.4. take measures to clarify or destroy the personal data of the personal data subject in connection with his or her (his or her legal representative’s) appeal with legal and justified demands;
6.2.5. organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation.
6.3. Personal data subjects have the right to:
6.3.1. full information about their personal data processed by the Operator;
6.3.2. to access their personal data, including the right to receive a copy of any record containing their personal data, except for cases provided for by federal law;
6.3.3. to clarify their personal data, block it or destroy it in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
6.3.4. to revoke consent to the processing of personal data;
6.3.5. to take measures provided by law to protect their rights;
6.3.6. to exercise other rights provided for by the legislation of the Russian Federation.
6.4. Subjects of personal data are obliged to:
6.4.1. provide the Operator only with reliable data about themselves;
6.4.2. provide documents containing personal data in the amount necessary for the purpose of processing;
6.4.3. inform the Operator about clarification (updating, changing) of their personal data.
6.5. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter are liable in accordance with the legislation of the Russian Federation.

7. FINAL PROVISIONS

7.1. The Operator has the right to make changes to this Policy. When making changes to the current version, the date of the last update is indicated. The new version of the Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Policy. The current version is always available on the Site at: https://sever-yug.com