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Privacy Policy

Edited on: June 23, 2023

This privacy policy defines the procedure for processing personal data and measures to ensure the security of personal data taken by IP Bordei R. (OGRNIP – 322463200025039) (hereinafter referred to as the “Operator”). The document is drawn up in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (hereinafter – the Personal Data Law).

  • General Provisions

1.1. The following terms are used in this Policy:

Personal data – any information relating to directly or indirectly identified or identifiable individual (personal data subject);

Personal data processing – any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

Automated personal data processing – processing of personal data using computer technology;

Personal data distribution – actions aimed at disclosing personal data to an indefinite number of people;

Provision of personal data – actions aimed at disclosing personal data to a specific person or group of persons;

Blocking of personal data – temporary suspension of personal data processing (except cases where processing is necessary to clarify personal data);

Destruction of personal data – actions resulting in the impossibility of restoring the content of personal data in the personal data information system and (or) the destruction of material carriers of personal data;

Depersonalization of personal data – actions resulting in the impossibility, without the use of additional information, to determine the belonging of personal data to a specific personal data subject;

Personal data information system – a set of personal data contained in databases and ensuring their processing information technologies and technical means;

Personal data subject – an individual to whom personal data directly or indirectly relate.

1.1.1. Other terms not reflected in this Policy have the meanings defined in the current legislation, in particular in Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006.

1.2. By using the Services of, you agree that:

1.2.1. You have read the terms of this Policy in full before starting to use the Service.

1.2.2. Information processing is necessary to fulfill the Operator’s contractual obligations to you within the framework of the Service User Agreement, including ensuring the operation of the Service. Your use of the Service in any form signifies that you accept all the terms of this Policy in full without any exceptions or limitations on your part.

1.2.3. The Policy may be changed by the Operator without special notice and without payment of any compensation in connection therewith. The new version of the Policy comes into force from the moment of its placement on the website, posted in the domain at, unless otherwise provided by the new version of the Policy.

1.3. If you do not agree with the terms of this Policy, do not start or immediately stop using the Service.

1.4. By accepting the terms of this Policy, you consent to the processing of Information by the Operator for the purposes provided by this Policy.

1.5. This Policy is developed and used in accordance with the Service User Agreement for In case of discrepancies between this Policy and other documents of the Operator, this Policy shall apply.

1.6. When processing Information, the Operator follows Law No. 152-FZ, Law No. 149-FZ, and other applicable Russian legislation.

  • Principles of personal data processing

2.1. Personal data processing must be carried out on a legal and fair basis.

2.2. Personal data processing must be limited to achieving specific, predetermined, and legal purposes. Personal data processing incompatible with the purposes of collecting personal data is not allowed.

2.3. The User acknowledges and agrees that the User’s Personal Profile image and personal data may accompany materials published by the User in the course of using the Service and will be available to an unlimited number of people. The User agrees that the Service Administration may display the User’s Personal Profile image and Username in the Service.

2.4. The merging of databases containing personal data processed for incompatible purposes is not allowed.

2.5. Only personal data that corresponds to the purposes of their processing is subject to processing.

2.6. The content and volume of processed personal data must correspond to the stated purposes of processing. Processed personal data must not be excessive in relation to the stated purposes of their processing.

2.7. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing personal data must be ensured. The Operator must take necessary measures or ensure their adoption to delete or clarify incomplete or inaccurate data.

2.8. Storage of personal data must be carried out in a form that allows identifying the personal data subject no longer than is required for the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, the party to which, the beneficiary or guarantor of which is the personal data subject. Processed personal data must be destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the necessity to achieve these purposes, unless otherwise provided by federal law.

  • Composition of Information collected and processed by the Operator

3.1. The Operator collects and processes the following types of Information:

3.1.1. Personal data: Provided by Users about themselves independently when registering a Personal Profile in the Service interface. Personal data may include, in particular, name, date of birth, gender, telephone number, and/or email address of the User. Data provided when using the Service, including information about education, marital status, and other data available for editing in the Personal Profile. Other personal data that the User provides to the Operator through third-party websites or services, including when the User authorizes in the Service.

3.1.2. Data that are not personal data necessary for the functioning of the Service. Additional data obtained when accessing the Service, including data about technical devices, interaction of devices with the Service (including IP address, type and version of user’s operating system, browser type, geolocation, Internet service provider), and subsequent actions of the User within the Service;

The data are considered personal data if, based on these data, the Operator can identify the subject.

3.1.3. Other information about Users, the collection and/or processing of which are established by the Service Usage Agreement.

3.2. By using the Services via a web browser that accepts data from cookies, you agree to the collection and processing of data from cookies for the purposes provided by this Policy, and the transfer of data from cookies.

3.3. The User is prohibited from providing personal data of third parties without the consent obtained from third parties for such transfer.

3.4. As a general rule, the Operator does not verify the accuracy of personal data provided by Users and does not have the ability to assess the legal capacity of the User. In cases provided by the Service Usage Agreement, the User must provide confirmation of the accuracy of the personal data provided by him.

3.5. The Operator does not control and is not responsible for the processing of information by third-party websites that the User may visit through links available in the Service.

  • Purposes of Information Collection and Processing

4.1. The Operator processes information about Users, including their personal data, for the purpose of fulfilling the Operator’s obligations to Users regarding the use of the Service. The Operator collects and processes only the Information necessary to fulfill the obligations of providing the Service.

4.2. The Operator may use the Information for:

4.2.1. Identifying the contractual party between the User and the Operator;

4.2.2. User authorization/authentication in the Service by receiving a call or SMS containing a verification code for entering the Service using the communication operator and/or intermediary organizations providing services for sending SMS messages and making calls;

4.2.3. Providing Users with services using the Service and further improvement of the Service, developing new services based on feedback/information from Users;

4.2.4. Personalization of the Service content and improvement of user experience;

4.2.5. Responding to User requests to customer support, informing Users about the Service capabilities, directing requests related to the use of the Service;

4.2.6. Marketing;

4.2.7. Conducting statistical and other research based on anonymized data;

4.3. For using the User’s personal data for purposes not provided by this Policy, the Operator requests the User’s consent for such use.

4.4. The User acknowledges and agrees that personal data posted by the User independently in the personal profile may be displayed when publishing materials (content) as a result of using the Service and will be available to an unlimited number of people. The User agrees that the Operator may display the User’s personal data in the Services.

4.5. The personal data provided by the User and other information uploaded by the User available in the Service is intended for display to an unlimited number of people solely for the purposes of providing the corresponding Service and personalizing Users. This information is not intended for collection and further distribution by third parties except in cases where such purpose is expressly stated in the terms of the corresponding Service.

4.6. The Operator does not process special categories of personal data related to race, nationality, political views, religious beliefs, health status, as well as biometric personal data.

  • Information Processing

5.1. Information is processed in accordance with applicable law.

5.2. Information is not transferred to third parties except in the following cases:

5.2.1. The User has consented to such transfer.

5.2.2. The transfer is provided by applicable law.

5.2.3. The transfer is made to ensure the possibility of protecting the rights and legitimate interests of the Service and/or third parties in cases where the User violates the Service Usage Agreement.

5.2.4. User’s personal data, including name, surname, age, city, and other data specified in the Personal Profile, becomes available to all Service Users.

5.2.5. Transfer upon request of state or other authorities for the purpose of complying with legislative requirements.
5.3. The User hereby acknowledges and agrees that the Operator may use and transfer personal data of third parties provided by the User when using the Service to implement certain functions of the Service, provided that the User guarantees the consent of third parties to such use and transfer.

5.4. The User hereby acknowledges and agrees that when using the Service, the Operator may receive data about the applications installed on the User’s mobile device and use them to implement certain functions of the Service.

5.5. The User hereby acknowledges and agrees that the Operator may receive statistical anonymized (without binding to the User) data about the User’s actions when using the Service and about the settings established by the User in the Service.

5.6. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, destroys personal data of citizens of the Russian Federation using databases located in the territory of the Russian Federation. Personal data of Users are stored for the entire period of using the Personal Profile by the User and after its deletion for the period determined in accordance with Federal Law No. 149-FZ “On Information, Information Technologies and Protection of Information”, as well as until the goals of processing Personal Data are achieved or until the User withdraws consent to the processing of personal data and within the period determined in accordance with Law No. 149-FZ. The processing of personal data is carried out using automated tools.

5.7. Personal data is deleted by the Operator in accordance with Law No. 152-FZ.

  • Confidentiality of Personal Data

6.1. Information related to personal data obtained in connection with the implementation of labor relations, the fulfillment of provisions of a civil law contract, the party of which is the subject of personal data, and in connection with the provision of Services by the Operator, is confidential information and is protected by current legislation of the Russian Federation.

6.2. Persons who have access to processed personal data have signed a confidentiality agreement and have been informed of the possible disciplinary, administrative, civil, and criminal liability in case of violation of the norms and requirements of the current legislation of the Russian Federation in the field of personal data protection.

6.3. Persons who have access to processed personal data do not have the right to disclose the personal data of the data subject to a third party without the written consent of such subject, except in cases where it is necessary to prevent a threat to the life and health of the data subject, as well as in cases established by the legislation of the Russian Federation.

6.4. Persons who have access to personal data undertake not to disclose personal data for commercial purposes without the written consent of the data subject. Processing of personal data of data subjects for the purpose of promoting goods, works, services on the market by direct contacts with a potential consumer using means of communication is allowed only with his prior consent.

  • Users’ Rights

7.1. Users have the right to:

7.1.1. Exercise free access to information about themselves by uploading their personal pages within the provided Service using a login and password;

7.1.2. Independently make changes, additions to the information about themselves in the Personal Profile of the Service, provided that such changes update the information;

7.1.3. Delete Information about themselves provided within the Personal Profile of the Service. Deleting a Personal Profile, Information may lead to the impossibility of using certain functions of the Service;

7.1.4. Upon request, receive from the Operator information regarding the processing of their personal data;

  • Measures to Protect Information

8.1. The Operator takes all necessary and sufficient legal, organizational, and technical measures to protect the personal data of Users and third parties from unauthorized or accidental access to them, destruction, alteration, blocking, distribution, as well as from other illegal actions with them. These measures include, in particular, internal verification of processes for collecting, storing, and processing personal data and security measures, including appropriate encryption and measures to ensure physical security of personal data to prevent unauthorized access to systems storing personal data.

  • Final Provisions

9.1. This Policy, the relations between the User and the Operator arising in connection with the application of this Policy, as well as issues not regulated by this Policy, are governed by the current legislation of the Russian Federation.

9.2. All questions regarding this Policy should be directed to the Support Service through the Service interface or to the address: Kurskaya Oblast, Rylsky District, Ivanovskoye Village, Rylsky Shlyakh str., building 3, IP Bordey R;

9.3. If it is necessary to withdraw consent to the processing of personal data, to identify the fact of unlawful processing of personal data, or if there are other grounds, the data subject whose data are illegally used must send a written request to the Operator for deletion of such personal data. The application must indicate the surname, first name, patronymic of the data subject, series, and number of the main document certifying the identity, information about the date of issue of the specified document and the issuing authority, a list of personal data that are unlawfully used in the recall placed in the services without the consent of the data subject, the name of the User who placed the review. The application must be sent to the address indicated in clause 9.2. These conditions for submitting an application apply if another procedure for submitting an application by the data subject is not provided by the norms of the current legislation on personal data.

9.4. The current version of this Policy is posted on the Service’s website and is available on the Internet at: