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Privacy Policy

Privacy Policy of DELIVERTU LLC

DELIVERTU LLC · revision dated 22.07.2026

1. General Provisions and Terms Used in the Policy

1.1. This document defines the policy of the Limited Liability Company "DELIVERTU" (DELIVERTU LLC, TIN 7733418105, PSRN 1277700521321, address: 125481, Moscow, Svobody St., 99, building 1, apt./office 1, hereinafter — the "Company") regarding the processing of personal data and the implementation of personal data protection requirements (hereinafter — the "Policy") in accordance with the requirements of Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data".

1.2. The following basic concepts are used in this Policy:

personal data — any information relating to a directly or indirectly identified or identifiable natural person (personal data subject);
processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data;
automated processing of personal data — processing of personal data using computer technology;
distribution of personal data — actions aimed at disclosing personal data to an indefinite circle of persons;
provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons;
blocking of personal data — temporary suspension of personal data processing (except for cases where 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 as a result of which the physical media of personal data are destroyed;
anonymization of personal data — actions that make it impossible without using additional information to determine the ownership of personal data to a specific personal data subject;
personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing;
personal data subject — a natural person to whom personal data directly or indirectly relates.

2. Principles of Personal Data Processing in the Company

2.1. Processing of personal data is carried out on a lawful and fair basis.

2.2. Processing of personal data is limited to achieving specific, pre-defined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

2.3. Merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

2.4. Only personal data that meet the purposes of their processing are subject to processing; processing of personal data incompatible with the purposes of collecting personal data is not allowed.

2.5. The content and volume of processed personal data correspond to the stated purposes of processing and are not excessive in relation to the stated purposes of their processing.

2.6. When processing personal data, the accuracy of personal data, their sufficiency, and in necessary cases, their relevance in relation to the purposes of processing personal data, are ensured. Necessary measures are taken to delete or clarify incomplete or inaccurate data.

2.7. Storage of personal data is carried out in a form that allows identifying the personal data subject, no longer than the purposes of processing personal data require, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor.

2.8. Processed personal data upon achievement of processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law, are subject to destruction.

2.9. When collecting personal data, including through the information and telecommunications network "Internet", recording, systematization, accumulation, storage, clarification (updating, changing), extraction of personal data of citizens of the Russian Federation are ensured using databases located on the territory of the Russian Federation.

2.10. Processing of personal data is not used for the purpose of causing property and/or moral harm to personal data subjects, or hindering the exercise of their rights and freedoms.

3. Legal Grounds for Processing Personal Data

3.1. Processing of personal data in the Company is carried out in accordance with Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter also — the "Personal Data Law"), the Labor Code of the Russian Federation, Federal Law No. 402-FZ dated December 6, 2011 "On Accounting", Federal Law No. 27-FZ dated April 1, 1996 "On Individual (Personalized) Registration in the Mandatory Pension Insurance System", Decree of the Government of the Russian Federation No. 1119 dated November 1, 2012 "On Approval of Requirements for the Protection of Personal Data during Their Processing in Personal Data Information Systems", Decree of the Government of the Russian Federation No. 687 dated September 15, 2008 "On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out without the Use of Automation Means", the Company's Charter and other regulatory legal acts in the field of personal data protection.

3.2. The basis for processing is:

3.2.1. Contracts concluded between the Company and the personal data subject, as well as contracts for which the subject is a beneficiary or guarantor, as well as the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
3.2.2. Consent of personal data subjects to the processing of personal data;
3.2.3. Protection of the rights and legitimate interests of the Company and third parties or achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;
3.2.4. Participation of the Company in constitutional, civil, administrative, criminal proceedings, proceedings in arbitration courts;
3.2.5. Achievement of goals provided for by an international treaty of the Russian Federation or law, for the implementation and performance of functions, powers and duties assigned to the Company by the legislation of the Russian Federation;
3.2.6. Processing of personal data is necessary for 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;
3.2.7. Processing of personal data is carried out for statistical purposes subject to mandatory anonymization of personal data;
3.2.8. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

4. Purposes of Personal Data Processing

4.1. The Company processes only those personal data that are necessary for the provision of services and the implementation of its activities, as well as for ensuring the rights and legitimate interests of third parties, provided that the rights of the personal data subject are not violated. The purposes of personal data processing and the list of personal data of the Company are specified in Appendix No. 1 to the Policy.

4.2. The Company does not process special categories of personal data concerning racial, national origin, political views, religious beliefs, health status, as well as biometric personal data. Processing of information about the health status of employees is carried out exclusively in accordance with current legislation, including the Labor Code of the Russian Federation.

5. Conditions for Termination of Personal Data Processing

The conditions for termination of personal data processing in the Company may be:

achievement of the purposes of personal data processing;
expiration of the consent to the processing of personal data or the contract with the personal data subject;
withdrawal by the subject of consent to the processing of personal data (in the absence of other legal grounds for processing);
detection of unlawful processing of personal data;
liquidation of the Company.

6. Conditions for Personal Data Processing

6.1. Processing of personal data of personal data subjects is carried out for the purpose of proper provision of services to Users of the Deliver-2.com website, ensuring compliance with laws and other regulatory legal acts of the Russian Federation, maintaining personnel and accounting records, ensuring personal safety of personal data subjects and other purposes specified in Appendix No. 1.

6.2. Processing of personal data is carried out by the Company with the consent of personal data subjects, both with and without the use of automation means.

6.3. The Company does not provide or disclose information containing personal data of subjects to third parties without the written consent of the personal data subject, except in cases where this is necessary to prevent a threat to life and health, as well as in cases established by the current legislation of the Russian Federation.

6.4. Upon a motivated request of an authorized body and in accordance with current legislation, personal data of the subject without his/her consent may be transferred:

to judicial authorities in connection with the administration of justice;
to the federal security service authorities;
to the prosecutor's office authorities;
to the police authorities;
to other bodies and organizations in cases established by regulatory legal acts binding on the Company.

6.5. In case of obtaining consent to the processing of personal data from a representative of the personal data subject, the authority of this representative to give consent on behalf of the personal data subject is verified by the Company.

6.6. In case of withdrawal by the personal data subject of consent to the processing of personal data, the Company has the right to continue processing personal data without the consent of the subject if there are grounds specified in the current legislation.

6.7. Publication (distribution) of personal data for an unlimited circle of persons, including on the Deliver-2.com website, may be carried out only on the basis of a separate consent of the personal data subject, drawn up taking into account regulatory requirements. If subjects establish additional conditions/prohibitions on further processing of personal data, the Company brings this information to the public notice by posting conditions/prohibitions on the relevant pages of the website where personal data is distributed.

6.8. Processing of personal data is carried out by the Company, as well as by other third parties who are engaged by the Company for processing or to whom personal data is transferred for the above purposes in accordance with the legislation of the Russian Federation. Such third parties may include, in particular:

counterparties of the Company providing hosting and database placement services (in particular, REG.RU LLC);
providers of payment services ensuring payment acceptance on the website;
providers of web analytics services (Yandex.Metrica, Google Analytics, Mail.ru Rating), processing data to the extent necessary for statistics and website improvement;
other contractors engaged by the Company for the purposes specified in Appendix No. 1 (for example, technical support services, advertising and information services).

The Company may carry out cross-border transfer of personal data in cases provided for by the legislation of the Russian Federation, a contract to which the personal data subject is a party, beneficiary or guarantor, as well as a contract at the initiative of the personal data subject. As of the date of approval of this version of the Policy, the Company does not carry out cross-border transfer of personal data; if it becomes necessary to carry out such transfer in the future (in particular, in connection with plans to launch the BRICS cross-border channel), the Company undertakes to notify the authorized body and personal data subjects in the manner and within the time limits provided for by Article 12 of the Personal Data Law before the start of such transfer.

6.9. The Company has the right to engage third parties in the processing of received personal data and/or transfer received data to them, as well as receive data from them for the specified purposes without additional consent of the subject, provided that such third parties ensure the confidentiality and security of personal data during processing. Processing of personal data by a third party may be carried out only on the basis of a contract that defines the list of actions (operations) to be performed with personal data and the purposes of processing, as well as provisions for ensuring the security of personal data, including requirements not to disclose or distribute personal data without the consent of the subject, unless otherwise provided by the legislation of the Russian Federation, as well as requirements in accordance with Article 19 of the Personal Data Law.

6.10. The Company undertakes to take the necessary legal, organizational and technical measures to protect the received personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, other unlawful actions in relation to personal data and to comply with the principles and rules of personal data processing provided for by the Personal Data Law and other relevant regulations.

Organization of Personal Data Storage

6.11.1. Processing, including storage, of personal data in the Company is carried out no longer than required by the purposes of personal data processing; personal data is automatically deleted or anonymized after 1 year from the moment of the subject's last interaction with the Deliver-2.com website, unless a longer period is provided by law (more details — section 7 of the Website Privacy Policy).

6.11.2. Storage of personal data is carried out on physical (paper) media and in electronic form, using databases located on the territory of the Russian Federation (in particular, on servers of the REG.RU LLC data center in Moscow).

6.11.3. The right of access to certain personal data of subjects is granted to employees of the Company who need it to perform their job duties and who are vested with appropriate powers and rights of access to personal data in accordance with the Company's internal regulatory document.

6.11.4. When organizing the storage of physical media of personal data, conditions are observed that ensure the safety of personal data and exclude unauthorized access to them.

6.11.5. Storage of personal data may be carried out for the period established by the contract to which the personal data subject is a party, beneficiary or guarantor, the consent of the personal data subject, applicable legislation of the Russian Federation, or a local regulatory act of the Company regulating the procedure and terms for storing documents containing personal data.

6.11.6. The Company organizes the storage of personal data for the time established by the requirements of legislation regulating archival storage and other regulatory acts containing norms on the storage of personal data.

6.12. Upon achievement of the purposes of personal data processing, as well as in case of withdrawal of consent to processing, personal data shall be destroyed, unless otherwise provided by the contract to which the personal data subject is a party, beneficiary or guarantor, or the legislation of the Russian Federation, or unless the Company is entitled to carry out processing without the consent of the personal data subject on the grounds provided for by the Personal Data Law or other federal laws.

6.13. Destruction of documents containing personal data is carried out in a manner that excludes the possibility of third parties becoming acquainted with the destroyed materials and the possibility of restoring their text. Based on the results of the destruction, an act on the destruction of personal data is drawn up and a corresponding entry is made in the personal data information system.

Specifics of Personal Data Processing on the Website

6.14.1. The personal data subject may independently provide his/her personal data to the Company during registration (creation of a Personal Account), placing an order or application for the purchase of document templates and consulting services, sending a cooperation request, or requesting feedback on the website.

6.14.2. During visits to the Deliver-2.com website by personal data subjects and use of its functionality, technical information may be collected using various technologies, including the "cookies" technology, which allows tracking the quality of the website and the characteristics of its use, as well as optimizing marketing activities on the Internet. The procedure for processing cookies on the Deliver-2.com website is defined in Section 5 of the Website Privacy Policy, which is an integral part of this Policy in the part concerning the website.

7. Confidentiality of Personal Data

7.1. Information related to personal data that has become known in connection with the implementation of labor relations, the performance of provisions of a civil law contract to which the personal data subject is a party, and in connection with the provision of services by the Company, is confidential information and is protected by the current legislation of the Russian Federation.

7.2. Persons who have gained access to processed personal data sign an obligation not to disclose confidential information, and are also warned about possible disciplinary, administrative, civil and criminal liability in case of violation of the norms and requirements of the current legislation of the Russian Federation in the field of personal data protection.

7.3. Persons who have gained access to processed personal data do not have the right to communicate personal data of the personal data subject to third parties without the written consent of such subject, except in cases where this is necessary to prevent a threat to the life and health of the personal data subject, as well as in cases established by the legislation of the Russian Federation.

7.4. Persons who have gained access to personal data undertake not to communicate personal data for commercial purposes without the written consent of the personal data subject. Processing of personal data of personal data subjects for the purpose of promoting goods, works, services on the market through direct contacts with a potential consumer using means of communication is allowed only with his/her prior consent.

8. Implementation of the Rights of Personal Data Subjects

8.1. The personal data subject has the right to receive information concerning the processing of his/her personal data, including containing:

8.1.1. confirmation of the fact of personal data processing by the Company;
8.1.2. legal grounds and purposes of personal data processing;
8.1.3. purposes and methods of personal data processing used by the Company;
8.1.4. name and location of the Company, information about persons (except for employees of the Company) who have access to personal data or to whom personal data may be disclosed on the basis of a contract with the Company or on the basis of federal law;
8.1.5. processed personal data relating to the relevant personal data subject, the source of their receipt, unless a different procedure for providing such data is provided for by the Personal Data Law or other federal law of the Russian Federation;
8.1.6. terms of personal data processing, including terms of their storage;
8.1.7. the procedure for the personal data subject to exercise the rights provided for by the Personal Data Law;
8.1.8. information on carried out or proposed cross-border data transfer;
8.1.9. name or surname, first name, patronymic and address of the person processing personal data on behalf of the Company, if processing is or will be entrusted to such person;
8.1.10. other information provided for by Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" or other federal laws of the Russian Federation.

8.2. The personal data subject has the right to demand from the Company clarification of his/her personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his/her rights.

8.3. The personal data subject has the right, including, to withdraw consent to the processing of personal data by sending a corresponding request to the Company's email address info.deliver2@gmail.com, or by sending a corresponding application to the Company's postal address: 125481, Moscow, Svobody St., 99, building 1, apt./office 1. Based on the personal data subject's application with withdrawal of consent/request to terminate personal data processing, the Company shall terminate the processing of personal data within the time period established by applicable law.

8.4. Upon receipt of a request from the personal data subject for information concerning the processing of personal data, the Company undertakes to provide such information to the subject free of charge in an accessible form within the time period established by law.

8.5. The Company blocks personal data for the period of internal verification in case of detection of: unlawful processing of personal data; inaccurate personal data; inability to destroy personal data within the time period established by legislation in the field of personal data or in local regulations.

8.6. If the personal data subject believes that the Company processes his/her personal data in violation of legal requirements or otherwise violates his/her rights and freedoms, the personal data subject has the right to file a complaint with the Company, as well as to appeal the Company's actions or inaction to the body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.

8.7. Any questions and requests related to the processing of personal data can be sent by the personal data subject to the email address info.deliver2@gmail.com. The person responsible for organizing the processing of personal data in the Company is Yulia Sergeevna Zinovieva (Director).

9. Measures Aimed at Ensuring the Company's Fulfillment of Obligations Provided for by Articles 18.1, 19 of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data"

9.1. The Company takes all legal, organizational and technical measures provided for by relevant regulatory legal acts to ensure the security of personal data during their processing in the Company's personal data information systems.

9.2. When processing personal data, the Company:

9.2.1. appoints a person responsible for organizing the processing of personal data (Yulia Sergeevna Zinovieva, Director);
9.2.2. adopts local regulations defining the policy and issues of personal data processing and protection;
9.2.3. conducts internal scheduled and unscheduled inspections on a regular basis and monitors that personal data processing processes comply with legislation;
9.2.4. regularly assesses the harm that may be caused to personal data subjects in case of violation of their rights and legal requirements;
9.2.5. determines the procedure for access to information resources and keeps records of the positions of the Company's employees whose access to personal data processed both with and without the use of automation means is necessary for the performance of official (labor) duties;
9.2.6. keeps records of categories and lists of personal data processed in the Company, categories of subjects whose personal data are processed, storage periods and procedures for destruction of such personal data;
9.2.7. keeps records of machine media of personal data and information systems of the Company in which personal data are processed;
9.2.8. determines the required level of security of personal data processed in personal data information systems and determines threats to the security of personal data during their processing in information systems.

9.3. Within the framework of the personal data protection system, the Company implements, in particular:

use of anti-virus protection tools and their regular updating;
encryption of data transmission channels (SSL/TLS protocol) when exchanging information through the website;
backup of processed data;
differentiation of employee access rights to personal data depending on job responsibilities;
use of firewalls and means of protection against unauthorized access;
logging of actions performed with personal data to the extent necessary for audit and incident response.

9.4. When processing personal data carried out without the use of automation means, the requirements established by Decree of the Government of the Russian Federation No. 687 dated September 15, 2008 "On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out without the Use of Automation Means" are fulfilled.

9.5. The Company ensures that employees directly involved in the processing of personal data are familiarized with the provisions of the legislation of the Russian Federation on personal data (including the requirements for personal data protection) and local acts on personal data processing. The Company provides regular training to its employees and brings to their attention the requirements of the legislation of the Russian Federation.

9.6. The Company is liable for violation of obligations to ensure the security and confidentiality of personal data during their processing in accordance with the legislation of the Russian Federation.

9.7. To ensure unlimited access to the Company's Policy on personal data processing and information on the implemented measures for personal data protection, the text of this Policy is published on the Company's official website (https://deliver-2.com/).

10. Liability

Liability of employees and officials of the Company who have access to personal data for failure to comply with the requirements of norms regulating the processing and protection of personal data is determined in accordance with the current legislation of the Russian Federation and the Company's internal regulatory documents.

Appendix No. 1 to the Policy on Personal Data Processing and Implementation of Personal Data Protection Requirements

Purpose 1

User registration on the Deliver-2.com website, provision of access to the Personal Account and User identification

Categories of personal data: surname, first name, patronymic; email address; phone number; login and password (in protected form); postal address, city; TIN (for registered individual entrepreneurs — information about the state registration number)
Categories of subjects whose personal data are processed: Website users who have registered a Personal Account
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy

Purpose 2

Provision of services on the Deliver-2.com website: access to legal news, articles, analytical materials, judicial decisions feed, purchase of document templates, consulting services, use of the legal services marketplace, subscription management

Categories of personal data: surname, first name, patronymic; email address; phone number; order/application data; when paying for services — necessary payment details (processed to the extent necessary for payment processing through the payment provider)
Categories of subjects whose personal data are processed: clients who have concluded a service agreement with the Company; website visitors placing an order or application; potential clients
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy

Purpose 3

Processing of user inquiries, applications and feedback (including cooperation requests and requests through contact forms)

Categories of personal data: surname, first name, patronymic; email address; phone number; content of the request
Categories of subjects whose personal data are processed: Website users, website visitors who have sent a request
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy

Purpose 4

Improving the quality of the website, analyzing user experience, statistical and marketing analysis, including using cookies

Categories of personal data: technical data (IP address, browser type and version, operating system); cookie identifiers; information collected through Yandex.Metrica, Google Analytics, Mail.ru Rating services; anonymized data on website usage
Categories of subjects whose personal data are processed: visitors to the Deliver-2.com website
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy

Purpose 5

Informing about new products and services, sending advertising and informational newsletters, participation in partner programs (upon separate consent of the subject)

Categories of personal data: email address; phone number; surname, first name, patronymic
Categories of subjects whose personal data are processed: Website users and visitors who have given separate consent to receive the newsletter
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy

Purpose 6

Conclusion and execution of contracts with the User (User Agreement and other service agreements)

Categories of personal data: surname, first name, patronymic; date of birth; TIN; passport data or other identity document data (if necessary to identify the contracting party); bank details; email address; phone number
Categories of subjects whose personal data are processed: Users who have concluded an agreement with the Company or placed an order on a paid basis
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy

Purpose 7

Maintenance of personnel and accounting records

Categories of personal data: surname, first name, patronymic; date and place of birth; marital status; gender; email address; residential and registration address; phone number; SNILS; TIN; citizenship; identity document data; driver's license data; bank details; profession, position; employment history; military registration status; education information; health status information (to the extent provided for by the Labor Code of the Russian Federation)
Categories of subjects whose personal data are processed: employees of the Company, job applicants, dismissed employees of the Company, counterparties and representatives of the Company's counterparties
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy

Purpose 8

Compliance with the requirements of the legislation of the Russian Federation, including responses to requests from authorized state bodies

Categories of personal data: minimum necessary personal data corresponding to the content of a specific lawful request or legal requirement
Categories of subjects whose personal data are processed: individuals against whom a lawful request from an authorized body has been received; employees and Users whose data are processed for accounting and tax reporting purposes
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy

Purpose 9

Interaction with the Company's counterparties (hosting provider, payment systems, providers of analytical and advertising-information services, other contractors) within the framework of concluded contracts

Categories of personal data: surname, first name, patronymic; position; contact phone number; email address of the counterparty's representative
Categories of subjects whose personal data are processed: representatives and employees of the Company's counterparties
List of actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision, access), blocking, deletion, destruction
Processing and storage periods: until the purpose of processing is achieved or until the expiration of the consent/withdrawal of the consent provided by the personal data subject for the processing of his/her personal data, unless otherwise established by law; for Website Users — no more than 1 year from the moment of the last interaction with the website (clause 6.11.1 of this Policy)
Methods of processing: mixed — automated, with transfer via the Company's internal network and via the Internet, as well as non-automated in cases provided for by law
Procedure for destruction: defined in clauses 6.12–6.13 of this Policy