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PERSONAL DATA PROCESSING POLICY

  1. GENERAL PROVISIONS

1.1.

This Personal Data Processing Policy (hereinafter referred to as the «Policy») has been drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, «On Personal Data» and defines the procedure for processing personal data and measures to ensure the security of personal data received by Letunovskiy Petr Vladimirovich, TIN 781428093185 (hereinafter referred to as the «Operator»).

The Operator considers observance of human and civil rights and freedoms when processing personal data, including protection of the rights to privacy and personal and family secrets, to be the most important purpose and condition of its activities.

1.2.

The principal terms used in this Policy:

Personal Data means any information relating directly or indirectly to an identified or identifiable natural person (personal data subject).

User means a natural person who is a personal data subject.

Cookie means a small fragment of data relating to personal data that is stored in the browser of a computer, mobile phone, or other device after the User visits the Website.

Automated Processing of Personal Data means processing of personal data using computing equipment.

Blocking of Personal Data means the temporary cessation of personal data processing, except where processing is necessary to clarify personal data.

Website means a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at letupro.com.

Personal Data Information System means a collection of personal data contained in databases and the information technologies and technical means that ensure its processing.

Depersonalization of Personal Data means actions that make it impossible, without the use of additional information, to determine that personal data belong to a particular User or another personal data subject.

Processing of Personal Data means any action (operation), or a set of actions (operations), performed on personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating or modification), extraction, use, transfer (distribution, provision, or access), depersonalization, blocking, deletion, and destruction of personal data.

Provision of Personal Data means actions aimed at disclosing personal data to a particular person or an indefinite number of persons.

Distribution of Personal Data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the mass media, posting it on information and telecommunications networks, or providing access to personal data in any other way.

Destruction of Personal Data means any actions as a result of which personal data are irreversibly destroyed, making it impossible to restore the content of the personal data in the Personal Data Information System, and/or as a result of which physical media containing personal data are destroyed.

1.3.

The personal data subjects whose personal data are processed by the Operator in accordance with this Policy include:

  1. clients and counterparties of the Operator who are natural persons
  2. representatives/employees of the Operator’s clients and counterparties that are legal entities
  3. Website visitors.

2. PURPOSES AND CONDITIONS OF PERSONAL DATA PROCESSING AND THE CORRESPONDING LISTS OF PERSONAL DATA PROCESSED

2.1. Personal data permitted to be processed under this Policy are provided voluntarily by the User by completing the User data form on the Website or by providing information directly to the Operator through electronic correspondence.

2.2. The personal data of the persons specified in Subparagraphs 1–2 of Clause 1.3 of this Policy are processed for the following purposes:

  • identifying a party under agreements and contracts concluded with the Operator;
  • providing the User with services and access to the Website and its services;
  • communicating with the User, sending the User emails when payment is received from the User, and sending the User notifications and requests;
  • conducting mutual settlements with the User under agreements concluded with the User;
  • transferring the results of the performance of an agreement—photographs and/or other works created under agreements concluded between the User and the Operator.

2.3. For the purposes specified in Clause 2.2 of this Policy, the following personal data of the persons specified in Subparagraphs 1–2 of Clause 1.3 of this Policy are processed:

  1. surname, first name, and patronymic, if any;
  2. contact telephone number
  3. email address
  4. residential address
  5. TIN
  6. date of birth
  7. passport details
  8. photographic image
  9. names of the User’s personal accounts on social networks or messaging services
  10. position, when processing the personal data of employees/representatives of counterparties that are legal entities

2.4. The personal data specified in Clause 2.3 of this Policy are processed with the consent of the personal data subject to the processing of their personal data, except where personal data processing is necessary for the performance of an agreement to which the User is a party, beneficiary, or guarantor; for entering into an agreement at the initiative of the User or an agreement under which the User will be a beneficiary or guarantor; or where personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, or to exercise and perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

2.5. The personal data of the persons specified in Subparagraph 3 of Clause 1.3 of this Policy (Website visitors) are processed for the following purposes:

  • arranging access to information about the Operator’s activities posted on the Internet;
  • communicating with the User and sending the User emails when the User registers on the Website;
  • promoting the Operator’s services and informing new clients about the quality of the services by providing information about prior work experience when the User publishes a review of their work with the Operator on the Website;
  • conducting research and analyzing data that make it possible to maintain and improve the Website’s services and sections, as well as develop new Website services and sections;
  • conducting statistical and other research based on depersonalized data.

2.6. For the purposes specified in Clause 2.5 of this Policy, the following personal data of the persons specified in Subparagraph 3 of Clause 1.3 of this Policy are processed:

  1. surname and first name;
  2. email address
  3. telephone number
  4. names of the User’s personal accounts on social networks or messaging services
  5. Cookies. The collection and processing of Cookies are governed by Section 7 of this Policy.

2.7. The personal data specified in Clause 2.6 of this Policy are processed with the consent of the personal data subject to the processing of their personal data.

2.8. Consent to the processing of Personal Data is given by the User by checking the box next to the statement: «I consent to the processing of my personal data in accordance with the Personal Data Processing Policy.»

2.9. For Users who use the Website to obtain information about the Operator’s activities, consent to the processing of Personal Data that include Cookies is given by using the Website and clicking the «OK» button, or a button with a similar meaning, in the notice concerning the collection of Cookies in accordance with this Privacy Policy.

2.10. The personal data specified in Clauses 2.3 and 2.6 of this Policy are collectively referred to hereinafter as Personal Data.

2.11. Special categories of personal data are not processed.

3.PROCEDURE FOR PROCESSING PERSONAL DATA

3.1. Personal data are processed with or without the use of automation tools. Personal data processing without the use of automation tools may be carried out in the form of paper documents and electronically (files and databases) on electronic storage media.

3.2. The Operator does not transfer personal data across national borders.

3.3. The Operator does not transfer personal data to third parties, except:

  • where transfer is necessary for the performance of an agreement with the personal data subject;
  • in cases provided for by law, including at the request of government authorities, courts, inquiry and investigative authorities, and other authorized bodies on the grounds provided for by the applicable legislation of the Russian Federation.

3.4. The Operator and other persons who have obtained access to personal data must not disclose personal data to third parties or distribute such data without the consent of the personal data subject, unless otherwise provided for by federal law.

3.5. The Operator has the right to store, including archive, and compile documents and personal data.

3.6. Personal data are processed until the purposes of personal data processing have been achieved. The User may withdraw their consent to personal data processing at any time by sending a notice to the Operator at info@letupro.com with the subject line «Withdrawal of Consent to Personal Data Processing.»

3.7. The Operator must cease processing personal data:

  • if unlawful processing of personal data by the Operator is identified, within a period not exceeding three business days from the date on which it is identified;
  • if the personal data subject withdraws their consent to the processing of their personal data;
  • when the purpose of personal data processing is achieved, and must destroy the personal data within a period not exceeding thirty days from the date on which the purpose is achieved. If it is impossible to destroy the personal data within that period, the Operator blocks such personal data and ensures their destruction within a period not exceeding six months, unless another period is established by federal law.

4.RIGHTS AND OBLIGATIONS OF THE PARTIES

4.1. The Operator has the right to:

  • receive reliable information containing personal data from the User;

4.2. The Operator must:

  • process personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
  • consider the User’s requests concerning personal data processing and provide reasoned responses;
  • take measures to clarify or destroy the User’s personal data in response to lawful and justified requests from the User or their legal representative;
  • arrange for personal data protection in accordance with the requirements of the legislation of the Russian Federation.

4.3. The User has the right to:

  • receive complete information about their personal data processed by the Operator;
  • clarify their personal data or have them blocked or destroyed if the personal data are incomplete, outdated, inaccurate, obtained unlawfully, or unnecessary for the stated purpose of processing;
  • withdraw consent to personal data processing;
  • if the User believes that the Operator processes their personal data in violation of applicable law or otherwise violates their rights and freedoms, appeal the Operator’s actions or inaction to the authorized body for the protection of the rights of personal data subjects or in court;
  • protect their rights and legitimate interests, including by seeking compensation for losses and/or moral damages in court;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.4. The User must:

  • provide the Operator only with accurate information about themselves.

5.PROCEDURE FOR HANDLING REQUESTS FROM PERSONAL DATA SUBJECTS

5.1. The persons specified in Clause 1.3 of this Policy have the right to receive information concerning the processing of their personal data, including:

  1. confirmation that the Operator is processing personal data;
  2. the legal grounds and purposes of personal data processing;
  3. the purposes and methods of personal data processing used by the Operator;
  4. the personal data being processed that relate to the relevant personal data subject and the source from which they were obtained;
  5. the periods for which personal data are processed, including their storage periods;
  6. information about the ways in which the Operator performs the obligations established by Article 18.1 of the Federal Law «On Personal Data»;
  7. other information provided for by the Federal Law «On Personal Data» or other federal laws.

The Operator must provide the personal data subject or their representative, free of charge, with an opportunity to review the personal data relating to that personal data subject.

5.2. The persons specified in Clause 1.3 of this Policy have the right to require the Operator to clarify, block, or destroy their personal data if the personal data are incomplete, outdated, inaccurate, obtained unlawfully, or unnecessary for the stated purpose of processing, and to take measures provided for by law to protect their rights.

5.3. The information specified in Clause 5.1 of this Policy must be provided by the Operator to the personal data subject in an accessible form and must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data.

5.4. The information specified in Clause 5.1 of this Policy must be provided to the personal data subject or their representative within ten business days from the date of the request or from the Operator’s receipt of a request from the personal data subject or their representative. The request must contain:

  1. the number of the principal identity document of the personal data subject or their representative, information about the date of issue of that document, and the issuing authority;
  2. information confirming the personal data subject’s participation in relations with the Operator, including the agreement number, date of conclusion, a conventional verbal designation and/or other information, or information otherwise confirming that the Operator processes their personal data
  3. the signature of the personal data subject or their representative. The request may be sent as an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.

5.5. If inaccuracies are identified in personal data, the User may update them independently by sending a notice to the Operator at info@letupro.com with the subject line «Updating Personal Data.» Within a period not exceeding seven business days from the date on which the personal data subject or their representative provides information confirming that the personal data are incomplete, inaccurate, or outdated, the Operator must make the necessary changes.

5.6. Within a period not exceeding seven business days from the date on which the personal data subject or their representative provides information confirming that such personal data were obtained unlawfully or are unnecessary for the stated purpose of processing, the Operator must destroy such personal data. The Operator must notify the personal data subject or their representative of the changes made and measures taken.

6.MEASURES TO ENSURE THE SECURITY OF PERSONAL DATA DURING PROCESSING

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

Such protection measures include, in particular:

  • using antivirus information security tools;
  • identifying and authenticating the User by password when logging into the information system;
  • restricting unauthorized persons’ access to premises intended for personal data processing;
  • storing personal data on secure media;
  • detecting unauthorized access to personal data and taking measures, including measures to detect, prevent, and eliminate the consequences of computer attacks against personal data information systems and to respond to computer incidents in such systems;
  • restoring personal data modified or destroyed as a result of unauthorized access.

6.2. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

7.COOKIES

7.1. The following Cookies are collected on the Website:

7.1.1. Technical Cookies—the collection of these files cannot be disabled when visiting the Website because they are necessary for its proper operation and for providing the Website’s full functionality;

7.1.2. Analytical Cookies—collected through web analytics tools for the purpose of conducting a general analysis of Website use and obtaining data about Users’ actions on the Website in order to improve its functionality:

  • IP address;
  • browser information;
  • access time;
  • referrer, meaning the address of the previous page.

7.2. The purposes of collecting Cookies are:

  • authenticating Website Users;
  • serving as part of the security measures used to protect User accounts, including preventing fraudulent use of login credentials, and protecting the Website as a whole;
  • data analytics.

7.3. How the collection of Cookies on the Website can be disabled:

7.3.1. If the User does not want Cookies to be stored on their device, this option can be disabled in the browser settings. Stored Cookies can also be deleted at any time in the browser’s system settings. The User may change their browser settings to accept or reject all Cookies, or Cookies from the Website, by default.

7.3.2. PLEASE NOTE THAT IF COOKIES ARE DISABLED, THE USER WILL NOT BE ABLE TO USE SOME OF THE WEBSITE’S FUNCTIONS AND TOOLS.

Cookies are processed for statistical or other research purposes, subject to the mandatory depersonalization of personal data.

8.FINAL PROVISIONS

8.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator by email at info@letupro.com.

8.2. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.

8.3. The current version of the Policy is freely available on the Internet at: https://letupro.com/legal-privacy

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