I, being a personal data subject, freely, of my own will and in my own interest, give individual entrepreneur Andrey Viktorovich Svirin, TIN 772872317733, OGRNIP 322774600176722 (hereinafter referred to as the Operator), specific, subject-matter, informed, conscious, and unequivocal consent to the processing of my personal data under the conditions set out below.
Operator's address for correspondence: 117647, Moscow, P.O. Box 15.
Email for personal data inquiries: privacy@mediacia.moscow.
Operator's website: https://mediacia.moscow/ (hereinafter — the Site).
Designations in the document: TIN — Taxpayer Identification Number; OGRNIP — Primary State Registration Number of an Individual Entrepreneur; OGRN — Primary State Registration Number; LLC — Limited Liability Company.
1. Purpose and legal basis of processing
1.1. Consent is given for the purpose of promoting the Operator's services through direct contacts via email, subscribing to and managing advertising subscriptions, executing my selected settings for receiving advertising messages, recording the circumstances of the form submission, and checking for technical failures or unauthorized submissions when subscribing.
1.2. Processing is carried out based on clause 1 of part 1 of article 6, article 9, and part 1 of article 15 of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter — the Personal Data Law).
1.3. Advertising is allowed only if separate prior consent to receive it has been provided in accordance with part 1 of article 18 of the Federal Law of 13.03.2006 No. 38-FZ "On Advertising." This consent itself does not constitute consent to receive advertising.
2. Composition of personal data
2.1. The consent applies to the following personal data:
- a) email address;
- b) subscription identifier;
- c) information on given consents: choice result, dates and times of the corresponding actions, document versions;
- d) subscription status and information on its withdrawal, including the date of withdrawal;
- e) technical information about the submission of the subscription form: IP address of the server connection, browser and device information (User-Agent), browser language (Accept-Language), approximate time from opening the current page to submission as reported by the browser, and the time from preparation of the secure form to submission according to server hours.
2.2. Processing is carried out exclusively to the extent necessary for the purpose specified in clause 1.1.
2.3. This consent does not cover using inquiry text, documents, photographs or other inquiry attachments, or information about the assignment, for advertising mailings or advertising profiling.
3. Actions with data and methods of processing
3.1. Within the specified purpose, the Operator has the right to collect, record, systematize, accumulate, store, clarify (update, modify), retrieve, use, transfer (provide, access) to persons specified in section 4, to the necessary extent, block, delete, and destroy personal data.
3.2. Processing is carried out using automation tools, without using such tools, or in a mixed manner.
3.3. The expression of current consent is carried out by independently setting a separate, previously unset mark in the form of a subscription on the Site, containing a link to this document, and clicking the "Subscribe" button. The possibility of reviewing the document is provided before expressing consent. Consent takes effect from the moment the corresponding form is submitted.
3.4. The sending of advertising messages is allowed only with separately expressed prior consent to receive advertising. Providing an address in the contact form does not, by itself, constitute the formation of an advertising subscription.
4. Persons involved in processing
4.1. For hosting the Site and the mail server, the Operator uses the infrastructure of LLC "TIMEWEB.CLOUD" (TIN 7810945525, OGRN 1227800052215). The server is located in the territory of the Russian Federation, in St. Petersburg, at the SPB-3 site.
4.2. For electronic correspondence, a mail service provided by LLC "VK" is also used.
4.3. Only information necessary for performing the respective technical task is provided to the indicated persons. In cases of commissioning the processing of personal data, such a commission is executed in compliance with the requirements of Part 3 of Article 6 of the Personal Data Law. Engaging third parties does not release the Operator from the legal obligations towards the personal data subject.
4.4. This consent does not permit the transfer of my address to third parties for the independent advertisement of their goods, works, or services.
5. Term of consent and storage periods
5.1. Subscription is completed via a separate form on the Website after expressing both consents: for receiving advertising and for the processing of data for the advertising mailing. No confirmation letter is sent for the address when subscribing.
5.2. Consent is valid for no more than three years from the date it is given, unless it is previously withdrawn, the purpose of processing is achieved, or the relevant subscription is terminated. Data is processed for no longer than necessary for the stated purpose. Extension of the term is allowed solely on the basis of new consent.
5.3. Upon achieving the purpose, expiration of the consent, or termination of the subscription, processing for advertising mailing is stopped. In the absence of an independent legal basis for further storage, the Operator ensures the destruction of data in the manner and within the time limits established by the Personal Data Law.
5.4. Minimal information necessary to confirm obtained consents, execution of advertising opt-outs, or protection of rights and lawful interests may be stored on an independent basis provided for in paragraph 7 of part 1 of article 6 of the Personal Data Law, provided that the rights and freedoms of the subject are respected. The composition of such information is limited to the address or other necessary subscription identifier, its status, information about consents and opt-out.
5.5. Information specified in paragraph 5.4 is stored exclusively for the period of actual necessity, but not more than three years from the date of subscription termination. The use of this information for resuming advertising messages is not allowed. Its storage is carried out on an independent legal basis and does not imply the continuation of the validity of this consent.
5.6. Technical information specified in subparagraph "d" of clause 2.1 is stored for no more than 30 calendar days from the date of subscription, including in copies of internal notifications to the administrator. This information is not included in the minimal consent records, which are kept for up to three years. They are not used for behavior analytics or advertising profiling and do not confirm the identity of the sender or the duration of visit to the entire Site.
6. Procedure for withdrawal of consent
6.1. I have the right to withdraw this consent at any time by sending a notification to privacy@mediacia.moscow or to the Operator's correspondence address. For subscription identification purposes, it is recommended to indicate the corresponding email address.
6.2. Using the "Unsubscribe" link in an advertising email or successful sending unsubscribe forms simultaneously means refusal to receive advertising and withdrawal of the actual consent to data processing for the purposes of advertising mailings. Submission of an additional application and confirmation by email are not required.
6.3. Upon receiving the request, the Operator immediately ceases processing personal data for the purposes of promoting services through direct contacts. The period provided by law for data destruction does not grant the right to continue advertising processing or sending advertisements after receiving the request.
6.4. If the retention of data is no longer required for processing purposes and there is no independent legal basis, the Operator ensures their destruction within the periods provided by law; upon withdrawal of consent, part 5 of article 21 of the Personal Data Law applies. Retention of minimal information is allowed only under the conditions of paragraphs 5.4 and 5.5.
6.5. Withdrawal of consent does not affect the legality of processing carried out before its receipt.
7. Voluntariness and final provisions
7.1. Providing this consent is voluntary and is not a condition for reviewing an inquiry, receiving a response, concluding a contract, or providing services. Refusal to provide it or withdrawal does not limit the ability to use the Website and submit inquiries.
7.2. This consent is made separately from consent to receive advertising, consent to process an inquiry, and consent to optional analytics. It does not replace the aforementioned consents and does not expand their scope.
7.3. Changes to this document do not alter the scope of consent previously given. If processing is required for other purposes or if the data set is expanded, new consent is obtained before the start of the corresponding processing.
7.4. The procedure for exercising the rights of the personal data subject and general protective measures are set out in the Personal Data Processing Policy: https://mediacia.moscow/legal/privacy-policy/.