1.1. This Personal Data Processing Policy (hereinafter – the Policy) has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter – the Personal Data Law) and defines the procedure for processing personal data as well as the measures undertaken by JSC “Intellectual Initiatives” (hereinafter – the Operator) to ensure the security of personal data.
1.2. The Operator considers the respect for human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family privacy, as its primary goal and condition for conducting its activities.
1.3. This Policy of the Operator with respect to personal data processing applies to all information that the Operator may receive about visitors of the website https://intel-in.ru
 (hereinafter – the Website).
1.4. In accordance with part 2 of Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”, the current version of this Policy is published for free access in the information and telecommunication network Internet on the Operator’s Website at: https://intel-in.ru/privacypolicy.
1.5. Personal data processed by the Operator includes:
·      surname, first name, patronymic of the personal data subject;
·      email address;
·      telephone numbers;
·      data automatically transmitted to the Website Services in the course of their use through the software installed on the User’s device, namely: IP address, cookie data, information about the User’s browser (or other software used to access the Services), technical characteristics of the hardware and software used by the User, date and time of access to the Services, addresses of requested pages, browsing and query history on the Website and its Services;
·      other personal data provided by Users for the purposes determined by this Policy.
1.6. The Operator does not process biometric personal data or special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or personal life.

2.1. Automated processing of personal data - processing of personal data by means of computer technology.
2.2. Blocking of personal data - temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website - a collection of graphical and informational materials, as well as software and databases, ensuring their availability on the Internet at the Website.
2.4. Personal data information system - a set of personal data contained in databases, as well as information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data - actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belong to a specific User or another personal data subject.
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, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator - a state authority, municipal authority, legal entity, or natural person that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the scope of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a defined or definable User of the Website.
2.9. Personal data allowed by the personal data subject for dissemination - personal data to which an unlimited number of persons is granted access by the personal data subject through the provision of consent to the processing of personal data allowed for dissemination in accordance with the procedure provided for by the Personal Data Law (hereinafter - personal data allowed for dissemination).
2.10. Personal data subject (User) - any visitor of the Website.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including the publication of personal data in mass media, placement in information and telecommunication networks, or granting access to personal data in any other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign natural person, or foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or resulting in the destruction of tangible media containing personal data.
2.15. Other terms are used in this Policy in the meaning provided in Article 3 of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data.” of the Russian Federation.

3.1. The Operator has the right to:
·      receive from the personal data subject reliable information and/or documents containing personal data;
·      in the event that the personal data subject withdraws consent to the processing of his/her personal data, the Operator shall cease processing such data and, if the retention of personal data is no longer required for the purposes of processing, shall destroy the personal data within a period not exceeding thirty (30) days from the date of receipt of such withdrawal, unless otherwise provided for by an agreement with the personal data subject or if the Operator is not entitled to process personal data without the consent of the personal data subject on the grounds provided for by this Federal Law or other federal laws;
·      independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations established by the Personal Data Law and regulatory legal acts adopted in accordance therewith, unless otherwise provided for by the Personal Data Law or other federal laws;
·      require the User to timely clarify the personal data provided.
3.2. The Operator shall:
·      process personal data and/or organize processing solely for the purposes specified in this Policy, and in accordance with the procedure established by the legislation of the Russian Federation;
·      provide the personal data subject, upon his/her request, with information regarding the processing of his/her personal data;
·      respond to appeals and requests of 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, upon its request, with the necessary information within ten (10) days from the date of receipt of such request;
·      publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
·      take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as against other unlawful actions with respect to personal data;
·      cease the transfer (distribution, 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 obligations established by the Personal Data Law.
3.3. The Operator has other rights and bears other obligations as established by the legislation of the Russian Federation.

4.1. Personal data subjects have the right to:
·      obtain information relating to the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects. The list of information and the procedure for obtaining it shall be established by the Personal Data Law;
·      require the Operator to clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
·      require prior consent for processing personal data for marketing purposes;
·      withdraw their consent to the processing of personal data and submit a demand 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 acts or omissions of the Operator in the processing of their personal data;
·      exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
·      provide the Operator with accurate information about themselves as necessary for the purposes of processing;
·      notify the Operator of information for clarifying (updating, amending) their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without that subject’s consent, shall be liable in accordance with the legislation of the Russian Federation.
4.4. Personal data subjects have other rights and bear other obligations as established by the legislation of the Russian Federation.

5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data shall not be permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, shall not be permitted.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and scope of personal data processed shall correspond to the declared purposes of processing. Excessive processing of personal data in relation to the declared purposes of processing shall not be permitted.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure the adoption of such measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a longer retention period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Personal data being processed shall be destroyed or anonymized upon achievement of the purposes of processing or in cases where it is no longer necessary to achieve such purposes, unless otherwise provided for by federal law.

6.1. Purposes of personal data processing:
·      Providing Users with information about the Operator’s products and services, including through electronic messages.
·      Informing about the operation of the Website, monitoring, and improving the quality of the Services.
·      Providing the User with access to personalized resources of the Website.
·      Establishing feedback with the User, including sending notifications, requests related to the use of the Website, provision of services, performance of works, processing of requests and applications from the User.
·      Determining the User’s location in order to ensure security and prevent fraud involving the User’s personal data on the Website.
·      Creating a user account for the performance of implied (conclusive) actions through the Website Services, provided the User has given consent to the creation of such account.
·      Providing the User with effective customer and technical support in case of issues related to the use of the Website.
·      Sending advertising materials to the User, provided that the Operator of personal data processing has obtained prior consent.
6.2. The Operator shall carry out automated processing of personal data, with or without receipt and/or transmission of the received information via information and telecommunication networks.
6.3. The list of actions performed by the Operator with the User’s personal data includes:
·      Collection;
·      Recording;
·      Systematization;
·      Accumulation;
·      Storage;
·      Clarification (updating, modification);
·      Use;
·      Transfer (distribution, provision of access), including cross-border transfer of personal data;
·      Anonymization;
·      Blocking;
·      Deletion;
·      Destruction.
6.4. Upon achieving the purpose of personal data processing, the Operator shall destroy the personal data or ensure their destruction within a period not exceeding thirty (30) days from the date of achievement of the purpose of personal data processing, unless the Operator is entitled to process personal data without the User’s consent on the grounds provided for by Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, or by other federal laws.
6.5. Legal grounds for personal data processing:
·      The Constitution of the Russian Federation;
·      Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006;
·      Decree of the President of the Russian Federation No. 188 dated March 6, 1997 “On Approval of the List of Confidential Information”;
·      Resolution of the Government of the Russian Federation No. 1119 dated November 1, 2012 “On Approval of Requirements for the Protection of Personal Data During Their Processing in Personal Data Information Systems”;
·      The Operator’s statutory (founding) documents.

7.1. Personal data shall be processed subject to obtaining the consent of the personal data subject to the processing of his/her personal data.
7.2. Processing of personal data is necessary for the achievement of the purposes provided for by an international treaty of the Russian Federation or by law, as well as for the performance of 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 exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of the personal data subject.
7.4. Personal data shall be processed if such data has been made publicly available by the personal data subject or at his/her request (hereinafter - publicly available personal data).
7.5. Personal data shall be processed if such data is subject to publication or mandatory disclosure in accordance with federal law.
7.6. Recording, systematization, accumulation, storage, clarification (updating, modification), and retrieval of personal data of citizens of the Russian Federation shall be carried out within the territory of the Russian Federation.
7.7. The User shall make the decision to provide his/her personal data and shall grant Consent freely, by his/her own will, and in his/her own interest.

8.1. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the applicable legislation in the field of personal data protection.
8.2. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by third parties.
8.3. The User’s personal data will not be transferred to third parties, except as required by applicable law or with the User’s consent.
8.4. In the event of discrepancies in personal data, the User may update them independently by sending the Operator a notification to the Operator’s email address info@intel-in.ru with the subject line “Personal Data Update Request.”
8.5. The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another term is established by a contract or by applicable legislation.
The User may withdraw his or her Consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator’s address info@intel-in.ru with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.6. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties, including those of the service providers specified in this paragraph.
8.7. Restrictions established by the data subject on the transfer (except granting access), as well as on the processing or conditions of processing (except access) of personal data permitted for dissemination, shall not apply in cases of processing personal data in the state, public, or other public interests as defined by the legislation of the Russian Federation.
8.8. When processing personal data, the Operator ensures the confidentiality of personal data.
8.9. The Operator stores personal data in a form that allows the identification of the data subject for no longer than is required for the purposes of processing personal data, unless the storage period is established by federal law or by a contract to which the data subject is a party, a beneficiary, or a guarantor.
8.10. Grounds for termination of personal data processing may include: achievement of the purposes of personal data processing; expiration of the validity period of the data subject’s Consent; withdrawal of Consent by the data subject; a demand to terminate the processing of personal data; or the detection of unlawful processing of personal data.
8.11. Conditions and timeframes for the destruction of personal data by the Operator:
·      achievement of the purpose of personal data processing or loss of necessity to achieve that purpose – within 30 days;
·      expiration of maximum retention periods for documents containing personal data – within 30 days;
·      provision by the data subject (or his/her representative) of confirmation that personal data were obtained unlawfully or are not necessary for the declared purpose of processing – within seven business days;
·      withdrawal by the data subject of Consent to the processing of his/her personal data, where retention is no longer required for the purpose of processing – within 30 days.
8.12. The Operator, together with the User, takes all necessary measures to prevent losses or other adverse consequences caused by the unlawful or accidental transfer (provision, dissemination, access) of the User’s personal data.

9.1. Prior to commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer of personal data (such notification shall be submitted separately from the notification of the intention to process personal data).
9.2. Prior to submitting the above-mentioned notification, the Operator shall obtain from the authorities of the foreign state, foreign natural persons, or foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.

10.1. The Operator and other persons who have gained access to personal data shall not disclose or disseminate such personal data to third parties without the Consent of the personal data subject, unless otherwise provided by federal law.

11.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at info@intel-in.ru.
11.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.
11.3. The Operator shall have the right to make amendments to the Policy without the consent of the User.