Privacy and Personal Data Processing Policy

1. General Provisions
1.1. This Privacy and Personal Data Processing Policy (hereinafter referred to as the "Policy") is an official document of Viktor Gennadievich Evchatov, Sole Proprietor (TIN 543311638231, OGRNIP 321774600534499), registered at: 7 Oleko Dundicha St., Apt. 121096, Moscow. 328 (hereinafter referred to as the "Administration"), which is the administrator of the website https://evchatov-partners.ru/, including all pages of this Site and its subdomains at any level), as well as the Personal Data Operator, which determines the procedure for processing and protecting information (including the procedure for protecting and processing their personal data) about individuals using the website https://evchatov-partners.ru/ (hereinafter referred to as the "Site") (hereinafter referred to as Users).
1.2. This Privacy and Personal Data Processing Policy applies to all information and data that Viktor Gennadievich Evchatov, Sole Proprietor, may receive about the user of the global Internet (the User) using the Site, and is aimed at regulating the proper protection of information about Users, including their personal data, from unauthorized access and disclosure. Issues related to the collection, storage, distribution, and protection of User information may be supplemented and set forth in other official documents of the Site Administration and in the provisions of current Russian legislation.
1.2.1. FOR THE PROCESSING OF PERSONAL DATA PERMITTED FOR DISTRIBUTION BY THE USER, THE LAW PROVIDES FOR SPECIAL PROCESSING TERMS AND PROCEDURES (Article 10.1 of Federal Law No. 152-FZ of July 27, 2006). THEREFORE, THE PROCESSING OF PERSONAL DATA PERMITTED FOR DISTRIBUTION BY THE USER IS CARRIED OUT BY THE OPERATOR SOLELY BASED ON THE INFORMED CONSENT OF THE PERSONAL DATA SUBJECT TO THE PROCESSING OF PERSONAL DATA PERMITTED FOR DISTRIBUTION BY THE SUBJECT.
1.3. The Consent to the Processing of Personal Data (https://evchatov-partners.ru/polzovatelskoe) is an integral part of this Policy.
1.4. Use of the Website is governed by this Privacy Policy and the processing of personal data of the Website (https://evchatov-partners.ru/polzovatelskoe), Consent to the processing of personal data (https://evchatov-partners.ru/polzovatelskoe), Consent to the processing of personal data permitted by the subject of personal data for distribution (additionally executed in cases established by current legislation), and the User Agreement of the Website (https://evchatov-partners.ru/polzovatelskoe).
1.5. If the User does not agree with the terms of this Policy, then in order to terminate the Policy in relation to him/her, the User must stop using the Site, including by visiting the Site.
1.6. By using the Website, in any manner and in any form within the limits of its declared functionality, including: (a) registration/authorization on the Website; (b) access to the Website; (c) other use of the Website's functionality or any of its services, the User confirms that:
a) They have read the terms of this Policy in full before using the Website or any of its services.
b) They accept all the terms of this Policy in full, without any exceptions or limitations on the part of the User, and undertake to comply with them. If the User disagrees with any of the terms of this Policy, they must completely refrain from using the Website or any of its services in any form.
c) Checking the appropriate box during registration/authorization on the Website, along with other implicit actions of the User, are recognized by the Parties as equivalent to the User's handwritten signature when executing (via software) electronic documents sent by the User to the Administration, including obtaining any necessary consents (including Consent to the processing of personal data) and confirmations from the User, and/or exchanged between the Parties. This also constitutes compliance with the written form of the transaction, subject to the requirement for a signature, in the event that the transaction is concluded by a person using electronic or other technical means that allow the content of the transaction to be reproduced unchanged on a tangible medium. The above actions of the User are considered a method agreed upon by the Parties that allows for the reliable identification of the person who expressed their will in concluding the transaction.
1.7. The Policy (including any of its parts) may be changed by the Administration without any special notice to Users. The new version of the Policy shall take effect upon posting on the Website or communicating it to the User in another convenient form, at the discretion of the Administration. Unless otherwise provided in the new version of the Policy, the User is solely responsible for verifying changes and/or additions to the Policy. The current version is always available at the following address: https://evchatov-partners.ru/polzovatelskoe.
1.8. The Policy uses the following key concepts:
a) automated processing of personal data — processing of personal data using computer technology;
b) blocking of personal data — temporary suspension of processing of personal data (except in cases where processing is necessary to clarify personal data);
c) personal data information system — a set of personal data contained in databases and the information technologies and technical means that support their processing;
d) depersonalization of personal data — actions that make it impossible to determine the ownership of personal data by a specific data subject without the use of additional information;
e) personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automated means with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data;
f) operator (in the terminology of the General Data Protection Regulation (GDPR) adopted by Regulation (EU) 2016/679: controller) — a state body, municipal authority, legal entity, or natural person that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data;
g) Personal data — any information relating to a directly or indirectly identified or identifiable natural person (the subject of personal data);
h) Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons;
i) Dissemination of personal data — actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data;
k) Destruction of personal data — actions as a result of which it is impossible to restore the content of personal data in a personal data information system and/or as a result of which tangible media containing personal data are destroyed.
l) Processor — a natural or legal person, government agency, agency, or other body that processes personal data on behalf of and at the direction of the controller.
1.9. Legal basis for processing personal data:
Personal data is processed in accordance with Federal Law No. 152-FZ of July 27, 2006, "On Personal Data," Article 53 of Federal Law No. 126-FZ of July 7, 2003, "On Communications," the Labor Code of the Russian Federation, RF Government Resolution No. 1119 of November 1, 2012, "On Approval of Requirements for the Protection of Personal Data When Processed in Personal Data Information Systems," RF Government Resolution No. 687 of September 15, 2008, "On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out Without the Use of Automation," and other regulatory legal acts in the field of personal data protection.
2. Personal Information of Users Received and Processed by Viktor Gennadievich Evchatov, Sole Proprietor.
2.1. For the purposes of this Policy, "Personal Information of a User" means:
2.1.1. Personal information, including personal data that a User provides about themselves upon registration/authorization on the Website.
2.1.2. Mandatory information, marked as such, includes:
a) a valid mobile phone number and/or a valid email address;
b) agreement to the terms of the User Agreement, the Privacy and Personal Data Processing Policy, and the Consent to the Processing of Personal Data.
c) personal data that may be collected and processed by the owner of the personal database (Site Administration) may include, among other things (the specific list of personal data will be determined solely on the basis of the data in the registration and accounting forms of the Site and the Site services):
last name, first name, patronymic (if any); contact information (mobile telephone subscriber number, landline telephone subscriber number, email address, etc.); city; gender; job title; information on registration with the tax authority (taxpayer identification number (if any)); area of ​​interest; IP address of Users' devices (a unique network address of a node in a computer network built using the IP protocol); information from cookies (a small piece of data sent by the web server and stored on the User's computer, which the web client or web browser sends to the web server in an HTTP request each time they try to open a page of the corresponding site); User-Agent, including the browser and its version through which the User accesses the Site and/or any service of the Site (or other program that provides access to the display of advertising); time of access to the Site and/or any service of the Site; the address of the Internet page on which the advertising unit is located; referrer (address of the previous page); data from geolocation services; anonymized user identifier in an automated system, the identification of an individual by which is impossible without additional information; characteristics of user interaction with the web resource, including use of keyboard, mouse, navigation on the web resource (including search query history, as well as characteristics of interaction with the content of the web resource in the context of various measurement metrics, for example, but not limited to: time of visit, number of bounces, browsing depth, interaction with the start button, viewing time, bounce, viewing, etc.); javascript code loaded onto the pages of the web resource; structure and attributes of web forms placed on the pages of the web resource; attributes of the following HTML elements: iframe, object, embed, applet; URL requests made from web pages to third-party domains; the content of the DOM model of the web page or its individual elements; the operating system and its version; the bit depth of the operating system; the name and model of the client's device; Accept-Encoding (an HTTP protocol header that specifies the list of supported methods for encoding the content of an entity during transmission); Accept-Language (an HTTP protocol header that specifies the list of supported natural languages); screen resolution; color depth; ActiveX availability; time zone; any other information entered/provided by the User of the Site (or from his device) on his own initiative, and which may be classified as personal data.
Moreover, the User is prohibited from including any data that poses a particular risk to the User's rights and freedoms (so-called "sensitive personal data") in the personal data transferred, including data on racial or ethnic origin, political, religious, or ideological beliefs, membership in political parties and trade unions, data concerning health, sex life, biometric, or genetic data. The User should be aware that the Administration cannot request the User's consent for such processing, as it is not aware in advance of the potentially sensitive nature of the personal data that the User may publish.
2.1.3. The Administration does not deliberately collect "sensitive personal data," and the Administration cannot request the User's consent for such processing, as it is not aware in advance of the potentially sensitive nature of such personal information.
2.2. This Policy applies only to Viktor Gennadievich Evchatov, Sole Proprietor. Viktor Gennadievich Evchatov, Sole Proprietor, does not control and is not responsible for third-party websites or software accessed by the User via links available on the Site, or the use of personal information provided by the User on third-party websites.
2.3. The methods for obtaining (collecting) personal data from Users are:
2.3.1. The User's provision of data when completing electronic forms and questionnaires in cases of participation in or registration for programs, promotions, events, and services.
3. Purposes of collecting and processing Users' personal information. Legitimate interests
3.1. The sole purpose of collecting and processing personal data within the framework of this Policy is to enable the User to be identified within the Site and/or its services, so that Viktor Gennadievich Evchatov, Sole Proprietor, can use the Site and/or its services.
To implement the stated Single Purpose of personal data processing, the Site Administration has the right to perform the following necessary and integral actions, namely:
a) registration and identification of the User within the Site and its services;
b) enabling Site Users to use the Site and the Administration's Services;
c) using cookie technology to analyze and research User preferences for the purpose of improving the Site and/or any Site service, for conducting measurements, collecting statistics, analytics, and using other business services, including for the purpose of providing such anonymized data to third parties (for example, but not limited to: targeted metrics on the types, kinds, and number of views, advertising materials, and the effectiveness of advertising campaigns, User actions outside the Site, as a result of redirecting to the advertiser's website after interacting with advertising on the Site and/or any Site service; other summarized statistics in the form of analytical reports and measurement reports);
d) sending/posting news, advertising, surveys, statistical, marketing, and other information about the Website and/or any service of the Website, including for the personalization of the functions of the Website and/or any service of the Website, content, content preferences, advertising, promotional offers and other sponsored content, offering recommendations (e.g., subscriptions, channels, groups, events that may be of interest to the User, etc.); for the development, testing, and improvement of the Website Administration's products and/or any service of the Website, including by conducting surveys and research, as well as testing new products and functions and troubleshooting them;
e) sending informational messages;
f) conducting marketing, statistical, and audience research, including satisfaction surveys for the User of the Website and/or any service of the Website;
g) promoting and monitoring the quality of the services provided by the Website Administration, their usability, and developing new services;
h) providing the subject of personal data with information about the services provided by the Website Administration, and about the development of new products and services.
3.2. The Administration's legitimate interests include:
(i) maintaining and administering the Website;
(ii) offering Users other services, tools, and products that, in the Administration's opinion, may be of interest to the User (this includes, among other things, taking into account the interests of the User: the operation of recommendation technologies, or the display of advertisements, or relevant search results, including those based on the User's previous queries);
(iii) collecting, processing, and presenting statistical data, big data, and other research;
(iv) complying with any contractual, legal, or regulatory obligations under applicable law.
4. Terms of Processing the User's Personal Information and Transferring It to Third Parties
4.1. The processing of the User's personal data (the User's Personal Information) is carried out by Viktor Gennadievich Evchatov, Sole Proprietor, in accordance with the legislation of the Russian Federation.
4.2. Principles of Personal Data Processing
4.2.1. The Operator processes personal data based on the following principles:
a) the Operator processes personal data lawfully and fairly and is limited to achieving specific, predetermined, and legitimate purposes. Only personal data that meets the purposes of their processing may be processed. The content and volume of personal data processed by the Operator correspond to the stated processing purposes; excessive processing is not permitted;
b) the processing of personal data is limited to achieving specific, predetermined, and legitimate purposes;
c) ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of personal data processing;
d) preventing the merging of databases containing personal data processed for incompatible purposes;
e) processing only personal data that meets the purposes of their processing;
f) the content and volume of personal data processed correspond to the stated processing purposes;
g) preventing the processing of personal data that is excessive in relation to the stated processing purposes;
h) destruction or anonymization of personal data upon achieving the processing purposes or if the need to achieve these purposes is no longer necessary, if the Operator is unable to rectify any personal data violations committed, unless otherwise provided by federal law;
i) personal data must be stored in a form that allows identification of the personal data subject, for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law, or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are subject to destruction or anonymization upon achieving the processing purposes or if the need to achieve these purposes is no longer necessary, unless otherwise provided by federal law.
4.3. The User's Personal Information is kept confidential, except in cases where the User voluntarily provides information about themselves for general access.
4.4. Transfer is carried out to any third party to ensure the legal protection of the Administration or third parties in the event of a User's violation of the Site's use, or in a situation where there is a threat of such a violation.
4.5. The Administration reserves the right to transfer anonymized data to third parties. In this case, if there is a possibility of aggregation of such data with corresponding personal data held by the third party, the Administration will take all necessary steps to ensure the protection of the transferred data by the third party.
4.6. The Administration stores personal data in a form that allows identification of the personal data subject, for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are subject to destruction or anonymization upon achieving the processing purposes, unless otherwise provided by federal law.
4.7. Personal data is processed automatically in personal data information systems.

4.8. Unless otherwise provided in this Policy, the Administration does not carry out cross-border transfers of personal data and does not make decisions regarding personal data subjects based solely on automated processing.
4.9. Taking into account the above, and taking into account the Administration's compliance with the processing purposes, the User agrees and instructs the Administration to perform the following actions:
- processing, including collecting, recording, systematizing, accumulating, storing, clarifying (updating, modifying), comparing, retrieving, using, blocking, deleting/destroying the User's Personal Information;
4.10. The User agrees to the processing of data collected by the Website/Services, to the extent specified in the Website Policy.
5. Measures taken to protect Users' Personal Information
5.1. Viktor Gennadievich Evchatov, Sole Proprietor, takes the necessary and sufficient organizational and technical measures to protect the User's Personal Information from unauthorized access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions by third parties.
5.2. The Administration does not guarantee the security of data transmitted by the User to the Site and its services, as unauthorized access to this data may be obtained by third parties as a result of any illegal actions. Any data transfer is made by the User at their own risk.
5.3. When processing the User's Personal Information, the Administration takes the necessary legal, organizational, and technical measures to protect it from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other illegal actions in relation to such data. Such measures, in accordance with Federal Law No. 152-FZ "On Personal Data" of July 27, 2006, include, in particular, the following:
- a person responsible for organizing the processing and ensuring the security of personal data has been appointed;
- This Policy, internal regulations on personal data processing, and internal regulations establishing procedures aimed at preventing and identifying violations of Russian Federation legislation and eliminating the consequences of such violations have been developed;
- Internal control over the compliance of personal data processing with the requirements of the Federal Law and the regulatory legal acts adopted in accordance therewith has been organized;
- Administration employees directly involved in the processing of personal data are familiar with the provisions of Russian Federation legislation on personal data, including personal data protection requirements, this Policy, and the Administration's internal regulations on personal data processing;
- The Administration conducts periodic audits of compliance with the processing procedures and ensures the security of personal data.
6. Procedure for Storing Users' Personal Information
6.1. The recording, systematization, accumulation, storage, clarification (updating, modification), and retrieval of personal data of citizens of the Russian Federation is carried out by the Administration exclusively on server facilities located within the Russian Federation.
6.2. Consent to the processing of personal data may be revoked by the User by submitting a written statement, signed by the User and delivered, or sent by registered mail with acknowledgment of receipt to "IP Evchatov Viktor Gennadievich" to the address specified at the beginning of this Consent. Consent to the processing of personal data may also be revoked by the User by any legal means, including in information systems using automated tools.
7. Other Terms
7.1. The Website does not control and is not responsible for third-party websites and services accessed by the User via links/buttons available on the Website, or for the content of such websites and services.
7.2. Any changes to this Policy will take effect upon publication of the new Policy on the Website. Continued use of the Website after the publication of the new Policy on the Website will constitute the User's acceptance of the changes to the Policy. If the User disagrees with the effective changes to the Policy, the User is obligated to discontinue use.
7.3. The applicable law for this Policy is the law of the Russian Federation. All disputes regarding this Policy will be resolved in accordance with the current legislation of the Russian Federation at the location of the Administration.Book design is the art of incorporating the content, style, format, design, and sequence of the various components of a book into a coherent whole. In the words of Jan Tschichold, "Methods and rules that cannot be improved upon have been developed over centuries. To produce perfect books, these rules must be revived and applied." The front matter, or preliminaries, is the first section of a book and typically has the fewest pages. While all pages are counted, page numbers are generally not printed, whether the pages are blank or contain content.