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Personal data processing policy

Designations in the document: TIN — Taxpayer Identification Number; OGRNIP — Primary State Registration Number of the Individual Entrepreneur; OGRN — Primary State Registration Number; LLC — Limited Liability Company; IP address — the network address from which the request comes; cookie — small records that a website saves in the browser.

1. General Provisions and Information about the Operator

1.1. Personal Data Operator — individual entrepreneur Andrey Viktorovich Svirin:

1.2. Application - the Customer's request through the Site, e-mail, telephone or other agreed channel with a description of the appeal. The application itself is not an acceptance of the Offer and does not oblige the Contractor to accept the order.

1.3. Order Invoice — a paper or electronic document, or an agreed message from the Service Provider, setting out the individual order terms: legal actions, source materials, price, payment procedure, timeframe and the form of the result. Once accepted, it forms part of the contract.

2. Legal grounds and principles of processing

2.1. The processing of personal data is carried out in accordance with the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Law on Personal Data) and other applicable normative legal acts of the Russian Federation. The terms "personal data," "processing of personal data," "operator," "provision of personal data," "anonymization of personal data," and "destruction of personal data" are used in the meanings established by Article 3 of the mentioned Law.

2.2. The processing of personal data is carried out on a lawful and fair basis and is limited to achieving specific, predetermined, and lawful purposes. The content and volume of the processed personal data must correspond to the stated purposes of processing; excessive processing and processing incompatible with the purposes of the original collection are not allowed.

2.3. The mere fact of visiting the Site does not constitute consent to the use of optional analytical tools. Consent to the processing of personal data in connection with the submission of an inquiry is provided separately from consent to analytics and does not extend to advertising mailings and advertising calls.

3. Purposes, data composition, and grounds for processing

3.1. Consideration of the inquiry and feedback

3.1.1. The purposes of processing are the acceptance and consideration of the Applicant's inquiry, clarification of circumstances related to the inquiry, preparation and sending of a response, provision of preliminary consultation, and calculation of the cost of requested services. Inquiries are accepted through forms on the Site, via telephone communication, email, personal messages in messengers and social networks.

3.1.2. The composition of the processed data: name or surname, first name and patronymic in the amount specified by the Applicant; telephone number; e-mail address; identifier or user name in the messenger or social network; selected method of communication; text of appeal; information provided during a telephone conversation; information about the subject of the order; personal data contained in the documents, files and subsequent correspondence submitted by the Applicant, exclusively to the extent necessary for the consideration of the application.

3.1.3. When a request is submitted through the form on the Site for its registration and review, the verification of correct submission, and confirmation of its circumstances, the address of the submission page, date and time, request identifier, and information about expressed consent are recorded. The notification to the Operator includes the IP address of the connection to the server, information about the browser and device transmitted by the browser, language settings, time from the preparation of the secure form to submission according to the server clock, and the approximate time from opening the current page to submission, if reported by the browser. This information does not establish the identity of the sender and does not determine the total duration of the Site visit. Based on the consent for the request, tracking of transitions between pages is not performed.

3.1.4. Legal grounds for processing: the consent of the Applicant, the fact of which is confirmed by the Operator, — paragraph 1 of part 1 of Article 6 of the Personal Data Law; when contacting for the conclusion of a contract at the initiative of the personal data subject themselves — paragraph 5 of part 1 of Article 6 of the mentioned Law, to the extent necessary for the conclusion of the contract. For such necessary processing, separate consent is not required. A call or sending a message in itself is not automatically considered received consent for data processing for other purposes.

3.1.5. Interaction with the Applicant is carried out using the contact information provided by them through mutually agreed communication channels exclusively on issues related to the received request. The information obtained during subsequent interaction is subject to the processing grounds, storage periods, and deletion procedures established by this Policy for the corresponding purpose.

3.1.6. Attached files are used for review, clarification of the circumstances of the request, preliminary assessment, and preparation of a response. For the provision of the service, the necessary processing of materials is carried out on the corresponding independent basis. The initial submission does not permit publication of files, their promotional use, or transfer for analytics. Conditions for the legality of receiving and transferring materials are defined in Terms of transfer and use of materials.

3.2. Verification of document authenticity

3.2.1. The purposes of processing are to consider a request for verification of the submitted document and related materials, preliminary assessment of their content and sending a response to the Applicant within the scope of the requested service.

3.2.2. The composition of the processed data: contact details of the Applicant, details of the document being verified, its copy, and other information necessary for conducting the verification.

3.2.3. The legal basis for processing the Applicant's personal data is their consent or another applicable basis provided by the Personal Data Law. The processing of personal data of third parties contained in the document is allowed if there is an independent legal basis regarding the respective persons. Having a contract with the Applicant is not sufficient grounds for processing any personal data of third parties.

3.2.4. When communicating the result of the verification, disclosure to the Applicant of third parties' personal data is allowed exclusively if there is an appropriate legal basis.

3.3. Conclusion and execution of the contract

3.3.1. The purposes of processing are the coordination of conditions and the provision of mediation services and coordinated assistance in resolving the dispute, analysis of documents, preparation of consultations, appeals and other agreed results, organization of calculations and interaction with the Customer.

3.3.2. Composition of the processed data: surname, first name and patronymic; contact details, including identifier or user name in the agreed communication channel; addresses; information related to the order, reported during a telephone conversation or in correspondence; information about the subject of the order; documents and materials necessary for the provision of services; payment details. When interacting through a representative, information about the representative and documents confirming his credentials are processed.

3.3.3. Passport data and other identification information are requested solely in cases when they are necessary to perform a specific action or to issue the relevant document.

3.3.4. Legal grounds for processing: paragraph 5 of part 1 of Article 6 of the Personal Data Law — concerning a person who is a party, beneficiary, or guarantor under a contract, as well as when concluding a contract on the initiative of the subject themselves; paragraph 2 of part 1 of Article 6 — to fulfill obligations provided by law. For the data of representatives and other persons, an independent applicable basis is determined.

3.4. Fulfillment of obligations established by law

3.4.1. The purposes of processing are maintaining records provided for by law, preparing settlements, and fulfilling lawful demands and requests of authorized bodies.

3.4.2. The composition of the processed data is determined by the content of the relevant obligation established by the legislation of the Russian Federation.

3.4.3. Legal basis for processing: paragraph 2 of part 1 of Article 6 of the Personal Data Law and the requirements of the legislation establishing the corresponding obligation.

3.5. Consideration of claims and protection of rights

3.5.1. The purposes of processing are the consideration of claims, resolution of disputes, exercise and protection of the Operator's rights and legitimate interests, confirmation of the content of interactions, and the presence of a legal basis for processing personal data.

3.5.2. The composition of the processed data: documents and correspondence related to the relevant dispute, necessary information about interactions, as well as minimal records confirming the receipt of consent.

3.5.3. Legal grounds for processing: requirements of legislation and paragraph 7 of part 1 of article 6 of the Personal Data Law — exercising the rights and legitimate interests of the Operator, provided that the rights and freedoms of the personal data subject are not violated.

3.6. Operation and security of the website

3.6.1. The purposes of processing are to ensure the functioning of the Website and feedback forms, prevent automated and unlawful submissions, identify technical errors and abuses, preserve and apply the visitor's choices regarding analytics.

3.6.2. The composition of the processed data: IP address, date and time of the request, requested page address, technical information about the browser, session identifier, and information about the visitor's choices.

3.6.3. Legal basis for processing: paragraph 7 of part 1 of Article 6 of the Personal Data Law — ensuring the operation and security of the website, exercising the rights and legitimate interests of the Operator, provided that the rights and freedoms of visitors are not violated. This information is not used on this basis for optional analytics or advertising.

3.7. Visit analytics

3.7.1. The purposes of processing are to assess the website's traffic, sources of visits, page usage and website convenience, as well as to compare the corresponding indicators over different periods.

3.7.2. The composition of the processed data is determined by section 6 of the Policy.

3.7.3. Legal basis for processing: paragraph 1 of part 1 of Article 6 of the Personal Data Law — separate consent of the visitor, expressed through a banner or analytics settings panel on the website.

3.8. Advertising messages via email

3.8.1. The purposes of processing are promoting the Operator's services through direct email contacts, managing subscriptions, and executing the settings selected by the subscriber.

3.8.2. Data processed: email address, subscription identifier, consents given, subscription status and withdrawal information. Registration also records technical information about submission: the IP address connecting to the server, browser and device information (User-Agent), browser language (Accept-Language), the approximate interval between opening the current page and submitting it as reported by the browser, and the interval between preparation of the protected form and submission according to the server clock. This information records the circumstances of submission and helps investigate technical failures and misuse. It is not used for behavioural analytics or advertising profiling and does not establish identity or the duration of a visit to the entire Site. Inquiry materials and information about assignments are not used for this purpose.

3.8.3. The legal basis for processing is the separate prior consent of the subject in accordance with paragraph 1 of part 1 of Article 6 and part 1 of Article 15 of the Personal Data Law. Sending advertising is allowed in the presence of the prior consent of the recipient in accordance with part 1 of Article 18 of the Federal Law of 13.03.2006 No. 38-FZ "On Advertising".

3.8.4. Refusal of an advertising subscription is not a reason to refuse consideration of an appeal, conclusion of a contract, or provision of services. Advertising processing and sending of advertising messages are immediately terminated at the request of the subject or recipient.

3.8.5. When submitting the unsubscribe form, the email address and minimal information about the refusal are recorded. Additionally, technical information about this submission may be recorded: the IP address of the connection to the server, information about the browser and device (User-Agent), browser language (Accept-Language), the approximate time from opening the current page to submission, and the time from preparing the secure form to submission according to the server's clock. They are used to verify the circumstances of the refusal, technical failures, and unauthorized submissions; the Operator receives them in an internal notification. The grounds for processing the information about the refusal are the fulfillment of statutory obligations regarding the cessation of advertising and advertising processing; technical information — ensuring form safety and protecting legitimate interests while respecting the rights and freedoms of the subject (points 2 and 7 of part 1 of Article 6 of the Personal Data Law in the relevant part). This processing is not based on revocable advertising consent and is not used for continuing advertising or behavioral analytics.

4. Procedure for personal data processing and involvement of third parties

4.1. Depending on the purpose and legal basis, the Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, and destruction. Processing is carried out using automated means, without using such means, or in a mixed manner.

4.2. Access to personal data is granted exclusively to persons who require such access for the performance of their respective functions, within the necessary scope of data.

4.3. For the placement of the Site and delivery of electronic correspondence, the Operator uses the necessary means of hosting and postal communication. Information about the processors involved and the conditions of their participation are provided upon request by the Operator’s contacts. When ordering processing, the requirements of paragraph 4.6 apply; when collecting data from citizens of the Russian Federation, the localization requirements established by paragraph 4.10 are complied with.

4.5. Yandex Metrica - Yandex LLC can be used for visiting analytics. The choice of the visitor is saved by means of the Site. The meter is loaded only with consent and after checking the data storage settings.

4.6. In cases of assigning the processing of personal data to a third party, the corresponding assignment is executed in compliance with the requirements of part 3 of Article 6 of the Personal Data Law. The provision of data to such persons is carried out exclusively to the extent necessary to perform the corresponding assignment. Engaging third parties does not release the Operator from the legal obligations established towards the personal data subjects.

4.7. When executing the contract, personal data may be provided to agreed specialists, delivery services, credit institutions and other participants of execution in the amount necessary for the provision of the relevant service, if there is an applicable legal basis.

4.8. The provision of personal data to courts and government authorities is carried out in cases and in the manner prescribed by the legislation of the Russian Federation.

4.9. The provision of Applicants' contact data to third parties for them to independently carry out advertising mailings without a separate legal basis is not allowed.

4.10. When collecting personal data of citizens of the Russian Federation, the Operator ensures compliance with the requirements of part 5 of article 18 of the Personal Data Law regarding the use of databases on the territory of the Russian Federation.

4.11. Before the start of cross-border transfer, the Operator complies with the requirements of Article 12 of the Personal Data Law and provides the subjects with the necessary information about such processing. Consent to analytics by itself does not cancel the requirements for localization and cross-border transfer.

5. Terms of processing and storage of personal data

5.1. Personal data related to inquiries for which a contract has not been concluded, including correspondence and attachments, are processed and stored for the period necessary to consider the inquiry, but no more than 90 calendar days from the date of the last substantive message or phone call regarding the corresponding inquiry. In the absence of further interaction, the period is counted from the date the inquiry was received. Sending automatic messages and service notifications does not change the start of the specified period.

5.2. Personal data in documents related to concluded contracts are stored for the period necessary to fulfill the contract, as well as for the periods of storage of the respective documents established by law. After the expiration of these periods, further storage is allowed only if there is an independent legal basis.

5.3. The storage period for ordinary technical safety logs is no more than 30 calendar days. Information related to a specific incident may be stored beyond the specified period only for the duration necessary to investigate the incident or to protect rights and legitimate interests.

5.4. The minimal record confirming the receipt of consent can be stored on an independent legal basis for no more than three years from the date it was given, if such storage is necessary to confirm the legality of processing or to protect rights and legitimate interests. The record of consent to the processing of an inquiry includes contact details that allow matching the record with the inquiry, the inquiry identifier, the date and time of submission, the page address of submission, the selection result, and information about the consent version. The full text of the inquiry and attachments are not included in this record.

5.5. Regarding consent for analytics, the minimal record includes the selection result, the date and time it was given, information about the consent version, and the required technical identifier. This record is not linked to the visitor's name, phone number, or email address.

5.6. The period for processing and storing analytical data that allows associating visits with a specific visitor or browser is limited to the time required for analyzing and comparing metrics over different periods and cannot exceed three years from the date of collection of the respective data. After this period, the data must be deleted or converted into aggregated statistical indicators that exclude the possibility of identifying a specific visitor. In the event of earlier achievement of the processing purpose or withdrawal of consent, the provisions on early termination of processing apply. Aggregated indicators that do not allow the identification of a specific visitor may be retained for statistical purposes.

5.7. The specifics of data processing and storage periods within Yandex's infrastructure are determined by the Terms of Service of Yandex Metrica (https://yandex.ru/legal/metrica_termsofuse/ru/), Section 8 of Yandex Privacy Policy (https://yandex.ru/legal/confidential/ru/) and the documentation of the corresponding functions. The three-year maximum term established by the Operator is a limitation of processing for the stated purpose and does not change the service conditions. The Operator ensures compliance with this maximum term by deleting the data or converting it into summary statistical indicators, excluding the possibility of identifying a specific visitor. Reference to the service conditions does not cancel the retention limit established by this document.

5.8. The storage period for Webvisor records in the service is 15 days, including the current day, in accordance with Yandex documentation: https://yandex.ru/support/metrica/ru/webvisor/requirements.html. The specified period applies separately from the overall maximum period for storing analytical data. The cookie expiration periods provided for in Section 6 of the Policy do not determine the data storage periods on the service servers.

5.9. Upon achieving the purpose of processing, expiration of the established storage period, or loss of the legal basis, personal data must be deleted or destroyed, unless legislation or another applicable legal basis provides for their further storage. These requirements apply to all copies of data in the used information systems and email. In cases provided by law, the Operator ensures the cessation of processing and destruction of data also by persons acting on its behalf.

5.10. Upon receiving a withdrawal of consent, the processing carried out on the basis of such consent is terminated. If the retention of personal data is no longer required for the purposes of processing and there is no other legal basis, the Operator ensures their destruction within the period provided for in part 5 of Article 21 of the Personal Data Law: as a general rule — no more than 30 days from the date of receipt of the withdrawal, taking into account the exceptions established by the mentioned provision.

5.11. The processing period for advertising subscription data shall not exceed three years from the date of giving consent in a separate subscription form and is limited to the actual necessity of processing for the stated purpose. A confirmation letter for the address is not sent. Upon withdrawal of any consent or termination of the subscription, processing for advertising mailings ceases prematurely. After the subscription ends, minimal information about consents and refusals may be stored on a separate legal basis for no longer than three years, solely to confirm the lawfulness of processing, to fulfill the refusal of advertising, or to protect rights and lawful interests, provided that the rights and freedoms of the subject are respected. These periods are selected by the Operator's rules and do not imply a legal obligation to store information for the entire specified period.

5.11.1. Refusal of advertising and withdrawal of consent to the processing of data for advertising mailings are possible through a separate form, via the link in the promotional email or through the Operator's contacts. For the form, it is sufficient to provide an email address; a new consent and confirmation by email are not required. Upon successful submission, the subscription is immediately deactivated. The address, subscription and refusal identifiers, date and time, method and page of refusal, and termination of subscription are recorded. The Operator is sent an internal notification of the refusal; the failure to deliver such a notification does not cancel the deactivation. The minimal record and its postal copy are retained within and on the basis of clause 5.11. Technical information from the refusal notification is retained separately within the limits of clause 5.12. For an address not listed in the registry, a new subscription or a separate long-term refusal record is not created.

5.12. Technical information included in the notice of handling is stored together with it within the term specified in clause 5.1 and is not included in the three-year minimum consent log. A minimum record when transferring files may additionally contain the fact of acceptance of the terms of material transfer, a reference to them, and their version, without the content and names of files. Files received with the handling, and their copies, must be deleted within the same limits as the handling, in the absence of an independent legal basis for retention. Ordinary separate technical safety logs are kept within the limits of clause 5.3. Technical information of the initial sending of the subscription form or refusal form and internal notices containing them, including postal copies, are kept no longer than 30 calendar days from the date of the corresponding sending; in the minimum consent records kept for up to three years, they are not included.

6. Use of cookies and web analytics tools

Cookies — small records that the browser saves on the device when visiting the Site and can send to the Site with subsequent requests. They allow, for example, to provide a technical session for a form and remember the visitor's settings.

Browser local storage (localStorage) — a mechanism for saving data on the device between visits to the Site. Unlike cookies, such records are not automatically sent to the server with each request and do not have a built-in expiration date. The duration of a selection and the check of its expiration are determined by the Site's code.

6.1. Required technologies

6.1.1. To ensure the functioning of contact forms, protection of submissions, and saving visitor settings on the Site, the necessary technical means are used.

6.1.2. The FORMSESSID cookie contains an identifier of the technical form session and is used for the functioning of the request submission protection mechanism. The specified cookie is not used for visit analytics. The cookie is valid for the duration of the browser session.

6.1.3. The visitor’s choice regarding analytics is recorded by the means of the Site in the jm_analytics_choice cookie and the jm-analytics-choice-v1 local storage record solely for the purpose of preserving and applying such selection. The duration of the selection is 180 days from the date of preservation. Cookies are given the same validity period. The local record contains information about the end of the term: after its expiration, the choice is not applied, the entry is deleted by the code of the Site at the next visit or check the deadline on the open page. If the Site is not open, the code cannot delete the entry from the browser remotely; it can be saved until the next check or deletion by the user. These records alone are not used to analyze behavior.

6.1.4. The validity period of cookies in the browser and the retention period of the associated data in the information system are independent periods and may differ.

6.1.5. You can change your choice or opt out of analytics through the "Analytics Settings" button in the website footer. In the browser's privacy settings, you can also delete cookies and specific site data, including local storage, or configure cookie blocking. To delete local records, you should select the deletion of site data for mediacia.moscow: deleting only cookies may not clear the local storage. The names of the settings items depend on the browser.

6.1.6. After deleting the Site data, the selection panel may reappear. The deletion of data itself does not imply consent to analytics and is not a requirement to delete previously obtained data from the Operator's systems or the analytics service; such requests should be directed to the contacts specified in the Policy.

6.1.7. Blocking necessary cookies or browser storage may prevent the preparation of a secure form, the submission of an inquiry, and the saving of preferences. Refusing optional analytics does not prevent browsing the Site or submitting an inquiry.

6.2. Optional Analytics

6.2.1. The connection and use of the Yandex.Metrica service is carried out only after obtaining separate consent from the visitor for data processing for analytical purposes.

6.2.2. Within the framework of analytics, the IP address when the service receives a request, cookie identifiers and visits, technical information about the browser and device, addresses of visited pages, date, time and duration of the visit, referral source, and events of interaction with the Site may be processed.

6.2.3. When the Webvisor function is enabled, the sequence of visitor actions and the display of Site pages, including transitions, clicks, and scrolling, are additionally recorded.

6.2.4. The operator ensures the exclusion of the content of inquiries, contact details from forms, and uploaded documents from being transmitted as analytical parameters and from recording by means of Webvisor. Personal data of such content are not included in the pages' addresses, titles, transition labels, and event parameters transmitted to the service.

6.2.5. The main cookies of Metrica include:

6.2.6. Depending on the functions of the service, other records in cookies and browser storage may be used. The full list and purpose are provided in the documentation: https://yandex.ru/support/metrica/ru/general/cookie-usage.

6.2.7. Refusal to give consent to analytics does not restrict the ability to use the Site and submit requests.

6.2.8. Changing the choice and withdrawing consent are carried out through the "Analytics Settings" element available on the Site. After refusal or withdrawal, sending new analytical requests ceases. Deleting the choice record or using another browser may cause the banner to appear again; such actions in themselves do not constitute an expression of consent.

6.2.9. Requests related to previously processed data are sent to the Operator at the address privacy@mediacia.moscow. The Operator considers such requests and takes measures provided by law, taking into account the possibility of matching relevant data with the applicant.

6.2.10. Additional information:

7. Rights of the personal data subject

7.1. The personal data subject has the right to receive information about the processing of their personal data, to request its clarification, blocking, or destruction in cases provided by law, to withdraw consent to processing, as well as to appeal against the actions or inaction of the Operator in the manner prescribed by law.

7.2. Requests and inquiries from personal data subjects are accepted at the email address privacy@mediacia.moscow or at the correspondence address specified in section 1 of the Policy.

7.3. For identification of the request, it is recommended to indicate the contact details used when sending it, the approximate date of sending, and the request identifier, if available. The Operator has the right to request proportionate proof of the subject’s identity or the authority of their representative. Requests provided for in Article 14 of the Personal Data Law are subject to the requirements for the content of the request established by that Article.

7.4. Information about the processing of personal data is provided to the subject or their representative within 10 working days from the date of the request or inquiry. If there are grounds provided by law, this period may be extended by no more than five working days with the sending of a motivated notification containing the reasons for the extension.

7.5. Withdrawal of consent does not affect the legality of processing carried out prior to its receipt. If the processing of certain data continues on an independent legal basis, the Operator informs the subject about such processing and its legal basis.

7.6. The subject has the right to seek protection of their rights from the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court.

8. Processing of personal data of third parties

8.1. The provision of documents and information through the initial form of appeal should be limited to the amount necessary for the consideration of the appeal. Before sending the materials, it is recommended to exclude or hide excessive passport, financial, medical, and other personal data.

8.2. The Applicant's consent applies to his personal data and does not constitute consent from other individuals whose personal data is contained in the submitted materials.

8.3. When materials are sent by a representative or personal data of third parties is provided, the Operator verifies the presence of the appropriate authority and legal basis for processing. In the absence of a sufficient legal basis, the data is not used for providing services and is subject to blocking and deletion within the timeframes prescribed by law.

8.4. The processing of special categories of personal data and biometric personal data is carried out in compliance with the requirements of Articles 10 and 11 of the Personal Data Law. Expressing consent by marking a form of request does not replace written consent in cases where such form is expressly required by law.

8.5. When transferring files, the Applicant separately confirms the legality of their receipt and the right to transfer them to the Operator for review and consideration of the request. Such confirmation does not replace the legal basis for processing personal data of other persons and does not release the Operator from the duties provided by law. In case of doubt, the Operator has the right to request documents on authority or the basis of the transfer, to restrict access, and to refuse to use the materials.

9. Protection of personal data and final provisions

9.1. The operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions. Such measures include access restriction, ensuring secure data transmission, control over storage periods, and compliance with requirements by engaged processors.

9.2. Destruction of personal data is carried out in ways that exclude the possibility of restoring its content in the information system and/or provide for the destruction of physical media containing personal data. The operator ensures documentary confirmation of destruction in cases and in the manner established by law.

9.3. The current version of the Policy is posted on the Website with the indication of the revision date. Changes to the Policy do not alter the scope of previously given consent. If subsequent processing requires new consent, such consent is obtained separately before the start of the relevant processing.

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