Personal Data Processing Policy
- General Provisions
1.1. This Personal Data Processing Policy (hereinafter — the Policy) has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure their security taken by the Operator.
1.2. Operator: LLC "KONTSPACE", TIN 9722025593, location: Moscow, intracity territory Municipal District Lefortovo, Borovaya St., building 7, structure 10, ATTIC floor, room 15 (RM9).
1.3. This Policy applies to all information that the Operator may obtain about visitors and users of the website https://contspace.ru/ (hereinafter — the Site).
1.4. By using the Site, filling out feedback forms, or giving consent to the processing of personal data, the user expresses their full and unconditional consent to the terms of this Policy.
1.5. In case of disagreement with the terms of the Policy, the user must immediately stop using the Site. - Basic Concepts Used in the Policy
The following concepts are used in this Policy:
– Personal data — any information relating directly or indirectly to a specific or identifiable individual (the personal data subject).
– Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
– User — any visitor of the Site https://contspace.ru/ who has provided their personal data to the Operator.
– Cookies — small pieces of data sent by a web server and stored on the user's device, which are used to identify the user, store their settings, and collect statistics on their actions on the Site.
– Automated processing — processing of personal data using computer technology. - Principles of Personal Data Processing
The Operator processes personal data on the basis of the following principles:
– lawfulness and a fair basis;
– limiting processing to the achievement of specific, predetermined, and lawful purposes;
– conformity of the content and scope of the processed data to the stated purposes of processing;
– ensuring the accuracy, sufficiency, and relevance of data;
– storing data in a form that allows identification of the subject for no longer than required by the purposes of processing;
– destruction or depersonalization of data upon achievement of the purposes of processing or in case of loss of the need to achieve them. - Categories and List of Processed Personal Data, Purposes and Terms of Processing
The Operator may process users' personal data for the following purposes:
4.1. Processing of inquiries and requests (the "We'll call you back" form)
Categories of subjects: Site visitors who have submitted a callback request.
List of data: Last name, First name, Patronymic (if provided); phone number.
Purpose of processing: Processing of incoming requests, consulting, providing information about goods and services, performing a callback.
Methods of processing: Collection, recording, storage, use, deletion.
Storage period: 3 (Three) years from the moment of the last interaction with the user, or until the purpose of processing is achieved or consent is withdrawn.
Procedure for destruction: Automatic deletion of records from the CRM system and email archives upon expiration of the storage period or at the user's request.
4.2. Analytics of the Site's operation and improvement of the user experience
Categories of subjects: All Site visitors.
List of data: IP address; browser and device data; cookies; time and date of visit; pages viewed; information about transitions and clicks (depersonalized data).
Purpose of processing: Analysis of user activity, improvement of the Site's operation, evaluation of the effectiveness of advertising campaigns.
Methods of processing: Automatic collection using web analytics services (Yandex.Metrica, etc.).
Storage period: 24 (Twenty-four) months from the moment of the last visit.
Procedure for destruction: Automatic deletion or depersonalization of data upon expiration of the storage period.
4.3. Distribution of marketing information (upon obtaining separate consent)
Categories of subjects: Users who have given separate consent to receive mailings.
List of data: Email address, phone number (depending on the mailing channel).
Purpose of processing: Informing about new products, promotions, and special offers.
Methods of processing: Collection, recording, systematization, use for sending messages.
Storage period: Until consent is withdrawn by the user, but no more than 3 (Three) years from the date of the last interaction.
Procedure for destruction: Deletion of the user's record from the mailing database based on a request or upon expiration of the period. - Conditions for Processing Personal Data
5.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data. Consent is given through an active action (checking a checkbox) when filling out a form on the Site.
5.2. The Operator processes only those personal data that are necessary to achieve the stated purposes.
5.3. Personal data is processed both with and without the use of automation tools (on paper media).
5.4. The Operator has the right to transfer personal data to third parties engaged to achieve the purposes specified in Section 4 (for example, hosting providers, CRM systems, analytics services), provided that such persons ensure the confidentiality and security of personal data in accordance with the legislation of the Russian Federation.
5.5. Localization of databases. The collection, recording, systematization, accumulation, storage, and clarification of personal data of citizens of the Russian Federation are carried out using databases located on the territory of the Russian Federation.
5.6. The Operator does not carry out cross-border transfer of personal data. - Rights of Personal Data Subjects
The user, as a personal data subject, has the right to:
6.1. Receive information concerning the processing of their personal data in the manner, form, and time established by law.
6.2. Demand that the Operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing.
6.3. Withdraw their consent to the processing of personal data at any time by sending a written notice to the Operator at the email address or postal address specified in Section 10.
6.4. Appeal against the actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court. - Measures to Ensure the Security of Personal Data
The Operator takes the necessary and sufficient legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions.
Such measures include:
– Appointment of a person responsible for organizing the processing of personal data.
– Application of organizational and technical measures to ensure data security during their processing in information systems.
– Restriction of access to personal data.
– Control over the security measures taken. - Use of Cookies and Web Analytics Systems
8.1. The Site uses cookies and web analytics services (for example, Yandex.Metrica) to collect information about users' actions on the Site. This information relates to personal data in accordance with the interpretation of the law.
8.2. On the first visit to the Site, the user is shown a banner with a notice about the use of cookies, containing a link to this Policy, and their active consent to their use is requested (the "Accept" button).
8.3. The user can manage cookies using their browser settings, as well as opt out of using analytics services. Refusal to use cookies may lead to incorrect operation of some Site functions.
8.4. Data collection using cookies is carried out only with the explicit consent of the user. Tacit consent (continued use of the site without an active action) is not allowed. - Procedure for Destroying Personal Data
Personal data is destroyed in the following cases:
– upon achievement of the purposes of processing or in case of loss of the need to achieve them;
– upon expiration of the established storage periods;
– upon withdrawal by the personal data subject of their consent to processing, unless otherwise provided by law;
– upon detection of unlawful processing of personal data.
Destruction of data on electronic media is carried out by deleting records or formatting media with guaranteed impossibility of recovery. Destruction of data on paper media is carried out by shredding. - Operator's Contact Information
Users may send their requests concerning the processing of their personal data, withdrawal of consent, clarification, or deletion of data using the following contacts:
– Email address: info@contspace.ru.
– Postal address: Moscow, intracity territory Municipal District Lefortovo, Borovaya St., building 7, structure 10, ATTIC floor, room 15 (RM9). - Final Provisions
11.1. This Policy is an internal document of the Operator and is available to an unlimited number of persons on the Site at: https://contspace.ru/en/politics/.
11.2. The Operator has the right to make changes to this Policy with notification to users by publishing a new version on the Site. The new version comes into force from the date of its publication, unless otherwise established by law.
11.3. The current version of the Policy is always available at the address indicated above.
