Privacy Policy

1. General Provisions

This Personal Data Processing Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedures for processing personal data and the measures taken by Trade (hereinafter referred to as the “Operator”) to ensure the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and personal and family secrets, to be its primary goal and a prerequisite for conducting its activities.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://tsystem.pro.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — the processing of personal data using computer technology.

2.2. Blocking of personal data — the temporary suspension of the processing of personal data (except in cases where processing is necessary to verify the accuracy of the personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the web address https://tsystem.pro.

2.4. Personal data information system — a collection of personal data contained in databases, along with the information technologies and technical means that enable their processing.

2.5. Anonymization of personal data—actions that make it impossible to identify a specific User or other data subject without the use of additional information.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated means on personal data, including collection, recording, organization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

2.7. Controller — a state body, municipal body, legal entity, or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed on personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://tsystem.pro.

2.9. Personal data authorized by the data subject for disclosure — personal data to which an unlimited number of persons has been granted access by the data subject through consent to the processing of personal data authorized by the data subject for disclosure in accordance with the procedure provided for by the Personal Data Act (hereinafter referred to as “personal data authorized for disclosure”).

2.10. User — any visitor to the website https://tsystem.pro.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Disclosure of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or to make personal data available to an unlimited group of persons, including the publication of personal data in the media, posting on information and telecommunications networks, or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data—the transfer of personal data to the territory of a foreign state to a government authority of a foreign state, a foreign natural person, or a foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently restore the content of the personal data in the personal data information system, and/or the destruction of physical media containing personal data.

3. The Operator’s Key Rights and Responsibilities

3.1. The Operator has the right to:

— receive from the data subject accurate information and/or documents containing personal data;

— in the event that the data subject revokes consent to the processing of personal data, or submits a request to cease processing personal data, the Operator has the right to continue processing personal data without the data subject’s consent if there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The controller is obligated to:

— provide the data subject, upon request, with information regarding the processing of their personal data;

— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

— respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Protection Act;

— provide the authorized body for the protection of data subjects’ rights with the necessary information upon request within 10 days of receiving such a request;

— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, or dissemination of personal data, as well as from other unlawful actions regarding personal data;

— cease the transfer (distribution, disclosure, access) of personal data, cease processing, and destroy personal data in the manner and under the circumstances provided for by the Personal Data Law;

— perform other duties as provided for by the Personal Data Protection Act.

4. Key Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:

— receive information regarding the processing of their personal data, except as provided by federal law. The information is provided to the data subject by the Controller in an accessible form and must not contain personal data relating to other data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— to require the Operator to correct, block, or destroy their personal data if such data is incomplete, outdated, inaccurate, obtained unlawfully, or unnecessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;

— to require prior consent for the processing of personal data for the purpose of marketing goods, works, and services;

— to withdraw consent for the processing of personal data, as well as to submit a request to cease the processing of personal data;

— to appeal to the authorized body for the protection of the rights of data subjects or through the courts against unlawful actions or inaction by the Operator in the processing of their personal data;

— to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Data subjects are obligated to:

— provide the Operator with accurate information about themselves;

— notify the Operator of any corrections (updates, changes) to their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another data subject without the latter’s consent, shall be held liable in accordance with the laws of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predefined, and lawful purposes. The processing of personal data that is incompatible with the purposes for which the personal data was collected is not permitted.

5.3. It is not permitted to merge databases containing personal data that are processed for purposes incompatible with one another.

5.4. Only personal data that is relevant to the purposes of its processing shall be processed.

5.5. The content and scope of the personal data being processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of its processing is not permitted.

5.6. When processing personal data, the accuracy, adequacy, and, where necessary, relevance of the personal data to the purposes of processing are ensured. The controller takes the necessary measures and/or ensures that such measures are taken to delete or correct incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows for the identification of the data subject for no longer than is necessary to achieve the purposes of processing, unless the retention period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or in the event that the need to achieve such purposes ceases to exist, unless otherwise provided by federal law.

6. Purposes of processing personal data

Purpose of processing	the conclusion, performance, and termination of civil law contracts
Personal data	Last name, first name, middle name, email address, phone numbers
Legal Basis	Federal Law No. 149-FZ of July 27, 2006, “On Information, Information Technologies, and the Protection of Information”
Types of personal data processing	Transfer of personal data

7. Terms and Conditions for the Processing of Personal Data

7.1. The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the objectives set forth in an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties assigned to the controller by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the enforcement of a judicial order, or an order of another authority or official, which are enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the controller or third parties, or to achieve socially significant objectives, provided that this does not infringe upon the rights and freedoms of the data subject.

7.6. The processing of personal data to which an unlimited circle of persons has been granted access by the data subject or at their request (hereinafter referred to as “publicly available personal data”) is carried out.

7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedures for the collection, storage, transfer, and other processing of personal data

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

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.

8.3. If inaccuracies are found in the personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address privacy@thismywebsite.com with the subject line “Update of Personal Data.”

8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different duration is provided for by contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address privacy@thismywebsite.com with the subject line “Withdrawal of consent to the processing of personal data.”

8.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by such entities (Operators) in accordance with their Terms of Service and Privacy Policy. The data subject and/or with the specified documents. The Operator is not liable for the actions of third parties, including the service providers specified in this paragraph.

8.6. Restrictions on the transfer (other than granting access) and on the processing or conditions of processing (other than obtaining access) of personal data authorized for disclosure, as established by the data subject, do not apply in cases where personal data is processed in the state, public, or other public interests as defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows for the identification of the data subject for no longer than is necessary for the purposes of processing personal data, unless the retention period for personal data is established by federal law or by a contract to which the data subject is a party, beneficiary, or guarantor.

8.9. The processing of personal data may be terminated upon the achievement of the purposes of such processing, the expiration of the data subject’s consent, the withdrawal of consent by the data subject, a request to terminate the processing of personal data, or the discovery of unlawful processing of personal data.

9. List of actions taken by the Operator with regard to the personal data received

9.1. The Operator collects, records, organizes, accumulates, stores, updates (modifies), retrieves, uses, transfers (distributes, discloses, provides access to), anonymizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data, with or without the receipt and/or transmission of the information obtained via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Prior to commencing activities involving the cross-border transfer of personal data, the operator must notify the competent authority responsible for protecting the rights of data subjects of its intention to carry out such a transfer (this notification must be submitted separately from the notification of the intention to process personal data).

10.2. Prior to submitting the aforementioned notification, the operator is required to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.

11. Privacy of Personal Data

The data controller and other persons who have access to personal data are prohibited from disclosing such data to third parties or disseminating it without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. Users may obtain clarification on any questions regarding the processing of their personal data by contacting the Operator via email at privacy@thismywebsite.com.

12.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy remains in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://tsystem.pro/polite.