1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by ANO DO "SFC "START" (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.

1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://sfsstart.ru.

2. Key Concepts Used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology.

2.2. Blocking of personal data - temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://sfsstart.ru.

2.4. Personal data information system - a set of personal data contained in databases and ensuring their processing using information technologies and technical means.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://sfsstart.ru.

2.9. Personal data permitted by the personal data subject for dissemination - personal data to which an unlimited number of persons have access provided by the personal data subject by giving consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).

2.10. User - any visitor to the website https://sfsstart.ru.

2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right to:

— receive reliable information and/or documents containing personal data from the personal data subject;

— in case the personal data subject withdraws consent to the processing of personal data, as well as submits a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the personal data subject, upon request, with information regarding the processing of their personal data;

— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

— respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— provide the authorized body for the protection of the rights of personal data subjects with the necessary information within 10 days from the date of receipt of such request;

— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;

— cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

— perform other duties provided for by the Personal Data Law.

4. Key Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— require the operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take statutory measures to protect their rights;

— set the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;

— withdraw consent to the processing of personal data, as well as submit a request to terminate the processing of personal data;

— appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in processing their personal data;

— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

— provide the Operator with reliable data about themselves;

— inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent shall bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. It is not allowed to combine databases containing personal data processed for incompatible purposes.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows identification of the personal data subject, for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing	informing the User by sending emails
Personal data	last name, first name, patronymic email address phone numbers
Legal grounds	Federal Law "On Information, Information Technologies and Information Protection" dated 27.07.2006 N 149-FZ
Types of personal data processing	Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data Sending informational emails to the email address

7. Conditions for Personal Data Processing

7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

7.2. Processing of personal data is necessary to achieve the objectives provided for by an international treaty of the Russian Federation or by law, to carry out the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant objectives, provided that this does not violate the rights and freedoms of the personal data subject.

7.6. Processing of personal data is carried out to which an unlimited number of persons have access provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has consented to the Operator transferring the data to a third party to fulfill obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address team-start@yandex.ru with the note "Updating personal data".

8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address team-start@yandex.ru with the note "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is obliged to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Prohibitions established by the personal data subject on the transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data

9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

Personal Data Processing Policy