Personal data processing policy

1. General provisions

This Personal Data Processing Policy (the “Policy”) sets out how ITKILLER LLC (the “Operator”) processes personal data and the measures taken to keep it secure. It is prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (“152-FZ”) and other applicable Russian law.

Operator: ITKILLER LLC, INN 9725196477, address: 115068, Moscow, Danilovsky municipal district, Peresvetov lane 2/3, unit 1/1. Data-processing contact: alexdolmat0vv@yandex.ru, +7 (926) 256-53-81.

Using the website itkiller.pro (the “Website”) and submitting requests through its forms means the user agrees with this Policy and the data-processing terms set out in it.

2. Key terms

• Personal data — any information relating, directly or indirectly, to an identified or identifiable individual (the data subject).
• Processing — any action or set of actions with personal data (collection, recording, organisation, storage, use, transfer, anonymisation, blocking, deletion, destruction).
• Operator — the party that organises and/or carries out processing and determines the purposes and scope of the data processed.
• Subject — a user of the Website whose personal data is processed.

3. Legal grounds for processing

• 152-FZ “On Personal Data” and its implementing regulations;
• Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”;
• the Civil Code of the Russian Federation;
• the subject’s consent to the processing of their personal data;
• agreements between the Operator and the subject and steps to conclude and perform them.

4. Categories of personal data processed

The Operator processes personal data that the subject voluntarily provides through the Website forms:

• name or other form of address provided by the user;
• contact details — email address;
• company name (optional);
• budget estimate (optional);
• the text of the request and any other information the subject provides at their own initiative.

When the Website is used, technical data may be collected automatically: IP address, browser and device information, date and time of the request, cookies. The Operator does not process special categories of personal data or biometric data.

5. Purposes of processing

• handling requests and communicating with the user;
• preparing proposals, concluding and performing service agreements;
• business correspondence and client records;
• improving the Website’s operation and security;
• complying with the requirements of Russian law.

6. Principles and conditions of processing

Processing is lawful and fair, limited to specific, predefined purposes and not excessive in relation to them. It is carried out with and without automation, on the basis of the subject’s consent and other grounds provided by Art. 6 of 152-FZ.

Databases containing the personal data of Russian citizens are hosted on servers located in the Russian Federation, in accordance with Part 5, Art. 18 of 152-FZ.

7. Processing and retention periods

Personal data is processed until the purposes are achieved or the subject withdraws consent. Once purposes are achieved or consent is withdrawn, data is destroyed or anonymised within the periods set by 152-FZ, unless the law requires otherwise. Correspondence relating to a request is kept for no more than 3 years, unless a longer period is required by law.

8. Transfer of personal data

The Operator does not sell personal data and does not disclose it to third parties, except where required by law or where processors are engaged on the Operator’s instructions (for example, a hosting provider or a message-delivery service). Such parties act on the Operator’s instructions and are obliged to maintain confidentiality and comply with 152-FZ.

The Operator does not carry out cross-border transfers of personal data. If a message-delivery service located outside the Russian Federation is engaged, such transfer is performed with the subject’s consent and after prior notification of the authorised data-protection authority as required by 152-FZ.

9. Cookies

The Website uses cookies necessary for its proper operation. The user may limit or disable cookies in their browser settings; this may affect the availability of certain Website features.

10. Data protection measures

The Operator takes the legal, organisational and technical measures needed to protect personal data from unlawful access, destruction, alteration, blocking, copying and distribution (Arts. 18.1, 19 of 152-FZ): appointing a person responsible for processing, restricting and segregating access, encrypting the communication channel (HTTPS/SSL), protecting against unauthorised access and malware, action logging, and backups.

11. Rights of the data subject

• obtain information about the processing of their personal data;
• require correction, blocking or destruction of data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the purposes;
• withdraw consent to the processing of their personal data;
• appeal the Operator’s acts or omissions to the data-protection authority (Roskomnadzor) or in court.

To exercise these rights, the subject sends a request to alexdolmat0vv@yandex.ru. The Operator reviews the request within the time limits set by 152-FZ.

12. Consent and its withdrawal

By submitting a form on the Website and ticking a separate consent box, the subject freely, by their own will and in their own interest, consents to the processing of the personal data they provide under this Policy. Consent may be withdrawn at any time by sending a written notice to alexdolmat0vv@yandex.ru. After withdrawal, processing stops unless there are other legal grounds to continue it.

13. Final provisions

The Operator may amend this Policy. A new version takes effect once published on the Website, unless the version provides otherwise. The current version is permanently available at itkiller.pro/legal/privacy.