USAD`BA

Privacy Policy (Personal Data Processing Policy)

1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with Federal Law of the Russian Federation No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Feoktistov Vladislav Alexandrovich (hereinafter referred to as the “Operator”).
1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of privacy, personal and family confidentiality, as a fundamental objective and condition of its activities.
1.2. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://forma61.ru.

2. Definitions
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is required to clarify personal data).
2.3. Website — a set of graphic and informational materials, software, and databases providing access via the Internet at https://forma61.ru.
2.4. Personal Data Information System — a set of databases containing personal data and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of identifying personal data as belonging to a specific User without the use of additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual who independently or jointly organizes and/or carries out the processing of personal data and determines the purposes and scope of such processing.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the Website.
2.9. Personal data permitted for dissemination — personal data made publicly available by the data subject through explicit consent in accordance with the Personal Data Law.
2.10. User — any visitor to the Website.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — actions aimed at disclosure of personal data to an indefinite group of persons, including publication in mass media or placement in information and telecommunication networks.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to foreign authorities, individuals, or legal entities.
2.14. Destruction of personal data — actions resulting in irreversible deletion of personal data without the possibility of restoration.

3. Rights and Obligations of the Operator
3.1. The Operator has the right to:obtain accurate information and/or documents containing personal data from data subjects;

• continue processing personal data without consent in cases provided by the Personal Data Law;
• independently determine necessary and sufficient measures to ensure compliance with personal data protection legislation.

3.2. The Operator is obliged to:provide information regarding personal data processing upon request;

• organize personal data processing in accordance with applicable Russian legislation;
• respond to requests from data subjects and authorized bodies within statutory time limits;
• ensure unrestricted access to this Policy;
• take legal, organizational, and technical measures to protect personal data;
• cease processing and destroy personal data in cases prescribed by law.

4. Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to:obtain information regarding the processing of their personal data;

• request clarification, blocking, or destruction of inaccurate or unlawfully processed personal data;
• withdraw consent to personal data processing;
• appeal unlawful actions or omissions of the Operator.

4.2. Data subjects are obliged to:provide accurate personal data;

• notify the Operator of changes to their personal data.

5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Processing is limited to specific, predetermined, and legitimate purposes.
5.3. Only personal data relevant to processing purposes is processed.
5.4. The volume and content of processed data correspond to declared purposes.
5.5. Personal data is stored no longer than required to achieve processing purposes unless otherwise required by law.

6. Purposes of Personal Data Processing
The processing of Users’ personal data is carried out for the purpose of providing information about the Operator’s services, promotional offers, and other events potentially of interest to the User.
6.1. Categories of personal data:full name;

• email address;
• phone number;
• links to personal websites and/or social media profiles;
• Internet session data (behavioral statistics).

6.2. Legal grounds for processing:Federal Law No. 152-FZ “On Personal Data”;

• consent of the personal data subject;
• civil law agreements concluded between the Operator and the data subject.

6.3. Types of personal data processing:collection, storage, systematization, depersonalization, and destruction;

• email communications;
• messenger communications (including WhatsApp, Telegram);
• social media interactions;
• phone calls related to services and offers;
• chatbots and automated messaging;
• remarketing and personalized advertising;
• partner-based promotional offers.

6.4. Depersonalized data collected through analytics services is used to improve website performance and content quality. 6.5. Users may withdraw consent by sending an email to forma61@bk.ru with the subject line “Withdrawal of consent to personal data processing”.

7. Conditions for Personal Data Processing
Personal data is processed based on consent, contractual necessity, legal obligations, or legitimate interests in accordance with Russian law.

8. Storage, Transfer, and Protection of Personal Data
8.1. The Operator ensures the security and confidentiality of personal data.
8.2. Personal data is not transferred to third parties except:

• as required by Russian law;
• when using services necessary for website operation and service provision (hosting, analytics, payment systems, communication services);
• with the consent of the data subject for the fulfillment of civil law agreements.

8.3. Users may request data updates via email.
8.4. Personal data is processed until processing purposes are achieved unless otherwise required by law.
8.5. The Operator is not responsible for third-party services processing data in accordance with their own policies.

9. Actions Performed with Personal DataThe Operator performs collection, storage, use, transfer, depersonalization, blocking, deletion, and destruction of personal data.

10. Cross-Border Transfer of Personal DataCross-border transfers are conducted in compliance with applicable Russian legislation and notification requirements.

11. ConfidentialityAll persons with access to personal data must ensure confidentiality unless disclosure is required by law.

12. Cookies and Electronic DataThe Operator may automatically collect cookies and similar technologies to ensure proper website functionality, analytics, and personalization. Users may manage cookie settings via browser preferences.

13. Final Provisions
13.1. Users may contact the Operator at forma61@bk.ru for any inquiries regarding personal data processing.
13.2. This Policy is effective indefinitely until replaced by a new version.
13.3. The current version is available at https://forma61.ru.