Personal Data Processing Policy

1General Provisions

This Personal Data Processing Policy (hereinafter — the Policy) has been developed in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure and conditions for processing the personal data of visitors and users of the krasconsultant.ru website.

Use of the website, including submitting feedback forms, constitutes the user’s consent to this Policy. In all cases where the consent of the personal data subject is required for the processing of personal data, such consent is requested separately and is confirmed by the user when submitting the form.

The Policy applies to all personal data processed by the operator, including data obtained through the website forms.

2Information about the Operator

The operator of personal data is: ООО «ЮК «Консультант»», INN 2465119147, legal address: Krasnoyarsk, ul. Rozhdestvenskaya, 10.

Operator contact details: phone 8 905 976-99-94, email mail@krasconsultant.ru.

3Basic Terms

Personal data — any information relating to a directly or indirectly identified or identifiable natural person (personal data subject).

Processing of personal data — any action (operation) or set of actions (operations) performed with personal data using or without the use of automation tools.

Consent to the processing of personal data — a freely given, specific, informed and unambiguous expression of will by the personal data subject, confirmed by an active action (ticking a dedicated form field) before submitting the request.

4Categories of Personal Data Subjects

The operator processes the personal data of the following categories of subjects:

• users of the krasconsultant.ru website who have submitted a request through the feedback forms;
• individual entrepreneurs seeking legal services and individuals seeking such services on behalf of legal entities;
• other persons interacting with the operator in the course of its activities.

5List of Processed Personal Data

When submitting a request through the website forms, the operator may process the following personal data:

• name;
• phone number;
• email address (when filling in the contact form);
• content of the request (message text);
• information specified by the user in additional form fields: client type, request topic, dispute stage, dispute amount, selected tariff, number of participants, company state, nature of activity, required procedure, property information, information on the availability of documents, product type, platform (marketplace), bank client information;
• technical information about the request: source page, page path, service identifier, referrer address, UTM tags.

6Purposes of Personal Data Processing

Personal data is processed for the following purposes:

• processing the user’s request and providing feedback to them;
• reviewing the request for a legal service;
• subsequent interaction with the user regarding their request;
• improving the quality of the website (to the extent of technical information about the request, without creating user profiles).

7Legal Grounds for Processing

The legal grounds for the processing of personal data are:

• the Constitution of the Russian Federation, the Civil Code of the Russian Federation, Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”;
• the consent of the personal data subject to the processing of personal data (issued as a separate document and confirmed by the user’s active action when submitting the form);
• actions taken at the initiative of the personal data subject aimed at obtaining information about the operator’s legal services and applying for such services.

8Actions with Personal Data

The operator carries out the collection, recording, systematization, accumulation, storage, updating (renewal, amendment), extraction, use, transfer (to the extent provided for in Section 12 of the Policy), depersonalization, blocking, deletion and destruction of personal data.

Personal data is processed both with the use of automation tools and without their use.

9Methods of Personal Data Processing

Personal data is processed by the operator using information systems deployed on the territory of the Russian Federation, as well as within the platform on which the operator’s website is hosted.

Processing includes collecting data from the website forms, storing it in a structured form, updating it and using it to contact the personal data subject regarding their request.

10Terms of Processing and Storage of Personal Data

Personal data is processed and stored no longer than required by the purposes of processing and the applicable legislation of the Russian Federation.

Specific storage periods for personal data are determined by the operator’s internal documents, taking into account the purposes of processing and legal requirements. Upon achieving the purposes of processing or losing the need to achieve them, personal data is subject to deletion or depersonalization, unless otherwise provided by law.

11Procedure for Terminating Processing and Deleting Personal Data

Processing of personal data is terminated upon achieving the purposes of processing, upon withdrawal of consent by the personal data subject, and in other cases provided for by law.

When grounds for termination of processing arise, the operator ceases processing of personal data and ensures its deletion within a period not exceeding thirty days from the date of the corresponding ground, unless otherwise provided by law or by an agreement with the personal data subject.

12Transfer of Personal Data to Third Parties and Processors

The operator does not transfer personal data to third parties, except in cases provided for by the legislation of the Russian Federation.

Within the confirmed actual architecture, personal data is processed using the platform on which the website is hosted (including data storage and the platform’s CRM functionality for managing client requests). The operator does not transfer personal data to other external services (including by email or to messengers).

13Processing of Personal Data within the Platform and CRM

The operator’s website is hosted on the Chatium platform. Data obtained through the website forms is stored in a structured form in the platform’s information systems deployed on the territory of the Russian Federation.

To manage requests, the operator uses the platform’s CRM functionality: on the basis of a request, a client card is created with the contact details (name, phone, email if provided) and information about the request. This information is used exclusively to contact the personal data subject regarding their request and is not transferred to third parties.

Other methods of data transfer (email, messengers, webhooks) are not currently used by the operator.

14Cookies and Technical Data

The operator does not collect or process information about users’ IP addresses, user-agent and other technical data, except for information that the user voluntarily provides through the website forms (source page, page path, service identifier, referrer, UTM tags).

The use of cookies and other analytics tools may be additionally described on the operator’s website; their use is not a mandatory condition for submitting a request.

15Rights of the Personal Data Subject

The personal data subject has the right to:

• receive information about the personal data processed by the operator and the conditions of its processing;
• require the updating, blocking or deletion of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
• withdraw consent to the processing of personal data;
• appeal the actions or inaction of the operator to the authorized body for the protection of the rights of personal data subjects or in court.

16Procedure for Withdrawal of Consent

The personal data subject has the right to withdraw consent to the processing of personal data at any time by sending the operator an application in any form to the email address mail@krasconsultant.ru or to the operator’s legal address.

Upon receipt of the withdrawal of consent, the operator ceases processing of personal data and deletes it within a period not exceeding thirty days from the date of receipt of the withdrawal, unless otherwise provided by law.

17Operator Contacts

Questions related to the processing of personal data can be sent:

• by email: mail@krasconsultant.ru;
• by phone: 8 905 976-99-94;
• to the legal address: Krasnoyarsk, ul. Rozhdestvenskaya, 10.

18Personal Data Protection Measures

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, as well as from other unlawful actions.

Personal data is processed in information systems with restricted access; persons with access to personal data are obliged to maintain confidentiality.

19Procedure for Updating the Policy

The operator has the right to make changes to this Policy. When changes are made, the revision date of the Policy and the technical version identifier are updated.

The current version of the Policy is always available on the website at: https://юкконсультант.рф/politika-obrabotki-personalnyh-dannyh.