Personal Data Processing Policy

1. General Provisions

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

This Personal Data Processing Policy is compiled in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by SERVICE TECHNOLOGY IT LIMITED LIABILITY COMPANY (hereinafter referred to as the Operator) to ensure the security of personal data.

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://stit.tech.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data – the processing of personal data using computer technology;

2.2. Blocking of personal data – the temporary cessation of processing 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://stit.tech;

2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means that ensure their processing;

2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine, without using additional information, the belonging of personal data to a specific User or other subject of personal data;

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

2.7. Operator – a state authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, and also 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://stit.tech;

2.9. Personal data permitted by the subject of personal data for dissemination – personal data, access to which by an unlimited number of persons has been provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data 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://stit.tech;

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, placement in information and telecommunications 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 destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

3. Rights and Obligations of the Operator

3.1. The Operator has the right:

3.1.1. To receive from the subject of personal data reliable information and/or documents containing personal data;

3.1.2. In the event of the subject of personal data revoking consent to the processing of personal data, as well as submitting a request to cease processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;

3.1.3. To independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated 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:

3.2.1. To provide the subject of personal data, upon his request, with information concerning the processing of his personal data;

3.2.2. To organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

3.2.3. To respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;

3.2.4. To communicate, at the request of the authorized body for the protection of the rights of subjects of personal data, the necessary information within 10 days from the date of receipt of such request;

3.2.5. To publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

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

3.2.7. To cease the transfer (distribution, provision, access) of personal data, to cease processing, and to destroy personal data in the manner and cases provided for by the Personal Data Law;

3.2.8. In case of detection of an unlawful or accidental transfer (provision, distribution, access) of personal data that has resulted in a violation of Users' rights, to notify the authorized body of the incident within 24 hours from the moment of detection, and to take other measures within the legally established timeframe in connection with the identified incident;

3.2.9. To fulfill other obligations stipulated by the Personal Data Law.

4. Main Rights and Obligations of Subjects of Personal Data

4.1. Subjects of personal data have the right:

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

4.1.2. To require the Operator to clarify his personal data, to block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, and to take legal measures to protect his rights;

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

4.1.4. To withdraw consent to the processing of personal data, as well as to submit a request to cease processing personal data;

4.1.5. To appeal to the authorized body for the protection of the rights of subjects of personal data or to a court of law the unlawful actions or inaction of the Operator in processing his personal data;

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

4.2. Subjects of personal data are obliged:

4.2.1. To provide the Operator with reliable data about themselves;

4.2.2. To inform the Operator about the clarification (updating, modification) of their personal data;

4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the latter's consent shall be liable 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 that is incompatible with the purposes of collecting personal data is not allowed;

5.3. The merging of databases containing personal data whose processing is carried out for purposes incompatible with each other is not allowed;

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

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of 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, their 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 the identification of the subject of personal data 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 subject of personal data is a party, beneficiary, or guarantor. Processed personal data are destroyed or anonymized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law

6. Purposes of Personal Data Processing

6.1. Purpose of processing: Providing additional information about the Operator's goods and services at the User's request

Personal data: Last name, first name, patronymic, phone number, email address.

Categories of users whose data is processed: Website visitors.

Legal basis: The Operator's charter (founding) documents.

Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.

Methods of personal data processing: Mixed processing of personal data (non-automated and using automation tools, with or without transmission of the received information over the Internet).

Processing and storage periods for personal data: For 3 years from the date of fulfillment of obligations by the Parties under the concluded agreement (provided it is concluded, taking into account the statute of limitations for claims regarding the fulfillment of contracts), or until the purpose of personal data processing is achieved, or until the moment the Subject withdraws consent to the processing of personal data/the Operator receives a request to cease processing personal data, if there are no other grounds for continuing the processing of the Subject's personal data.

Storage of personal data: On physical media in special places that prevent unauthorized access. On electronic media – using software tools to restrict data access.

Achievement of personal data processing purposes: Upon achieving the purposes of personal data processing or the occurrence of other grounds for ceasing personal data processing, physical media containing personal data are destroyed, and personal data are deleted from electronic media without the possibility of recovery.

6.2. Purpose of processing:Conclusion, execution, and termination of civil-law contracts.

Personal data: Conclusion, execution, and termination of civil-law contracts.

Categories of users whose data is processed: Website visitors who have concluded or intend to conclude a civil-law contract for the sale and purchase of goods (services) presented on the Site with the Operator.

Legal basis: The Operator's charter (founding) documents, contracts concluded between the operator and the subject of personal data.

Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.

Methods of personal data processing: Mixed processing of personal data (non-automated and using automation tools, with or without transmission of the received information over the Internet).

Processing and storage periods for personal data: For 3 years from the date of fulfillment of obligations by the Parties under the concluded agreement (provided it is concluded, taking into account the statute of limitations for claims regarding the fulfillment of contracts), or until the purpose of personal data processing is achieved, or until the moment the Subject withdraws consent to the processing of personal data/the Operator receives a request to cease processing personal data, if there are no other grounds for continuing the processing of the Subject's personal data.

Storage of personal data: On physical media in special places that prevent unauthorized access. On electronic media – using software tools to restrict data access.

Achievement of personal data processing purposes: Upon achieving the purposes of personal data processing or the occurrence of other grounds for ceasing personal data processing, physical media containing personal data are destroyed, and personal data are deleted from electronic media without the possibility of recovery.

6.3. Purpose of processing: Collection of statistical information about the User's actions on the Site using internet statistics services (metric programs).

Personal data: Cookie files (information collected through metric programs).

Categories of users whose data is processed: Website visitors.

Legal basis: Consent of the Personal Data Subject to the processing of personal data.

Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction of personal data, transfer of personal data with the User's consent.

Methods of personal data processing: Automated processing of personal data with receipt and/or transmission of the received information over the Operator's internal network, with transmission over the Internet.

Processing and storage periods for personal data: Until the purpose of personal data processing is achieved, or until the moment the Subject withdraws consent to the processing of personal data/the Operator receives a request to cease processing personal data, unless a different period is stipulated by the contract or current legislation.

Storage of personal data: Personal data is stored in information systems (services), using software tools to restrict data access.

Achievement of personal data processing purposes: Upon achieving the purposes of personal data processing or the occurrence of other grounds for ceasing personal data processing, physical media containing personal data are destroyed, and personal data are deleted from electronic media without the possibility of recovery.

7. Conditions for Processing Personal Data

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;

7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or a law, for the performance of the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation;

7.3. The processing of personal data is necessary for the administration of justice, the 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. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or a beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor;

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;

7.6. The processing is carried out on personal data, access to which by an unlimited number of persons has been provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data);

7.7. The processing is carried out on personal data subject to publication or mandatory disclosure in accordance with federal law

8. Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data

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 persons from accessing 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 subject of personal data has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil-law contract. If you have given your consent to the collection of cookies using the Yandex.Metrica web analytics service, and you are actually using the Website, this means that you have also given your consent to the transfer of this data to the company Yandex (Yandex LLC; OGRN 1027700229193, 119021, Russia, Moscow, Lva Tolstogo St., 16) for the processing of your data by Yandex in the manner and for the purposes specified below.

A cookie is a small text file placed on your computer for the purpose of analyzing your user activity.

The information collected using cookies cannot identify you, but it can help us improve the website's performance. Information about your use of the website collected using cookies will be transmitted to Yandex and stored on Yandex's servers in the EU and the Russian Federation. Yandex will process this information to evaluate your use of the website, compile reports for us on website activity, and provide other services. Yandex processes this information in the manner established in the terms of use of the Yandex.Metrica service. You can refuse the use of cookies by selecting the appropriate settings in your browser. You can also use the tool: https://yandex.ru/support/metrika/general/opt-out.html. However, this may affect the operation of some website functions.

8.3. In case inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator's email address info@stit.online with the note "Updating personal data."

8.4. The period for processing personal data is determined by achieving the purposes for which the personal data were collected, unless a different period is stipulated by the contract or current legislation. The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email at the Operator's email address example@mail.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 means, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or is obliged to familiarize himself with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access) and on the 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 subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.

8.9. Conditions for the termination of personal data processing may include the achievement of the purposes of personal data processing, the expiration of the validity period of the subject's consent to personal data processing, the withdrawal of consent by the subject of personal data or a request to cease processing personal data, as well as the identification of unlawful processing of personal data.

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

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

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

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 subjects of personal data of its intention to carry out the 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, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User can obtain any clarifications on questions of interest regarding the processing of his personal data by contacting the Operator via email at info@stit.online;

12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version;

12.3. The current version of the Policy is freely available on the Internet at https://stit.tech/en/privacy.