Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ "On Personal Data" of 27.07.2006 (hereinafter, the "Personal Data Law"). It defines the procedure for processing personal data and the measures for ensuring personal data security taken by Limited Liability Company "Tsifrovye Akuly" (hereinafter, the "Operator").
1.1. The Operator's most important goal, and a condition of its activities, is to respect the rights and freedoms of individuals and citizens when processing their personal data. This includes protecting the rights to privacy and to personal and family secrecy.
1.2. This Operator's Personal Data Processing Policy (hereinafter, the "Policy") applies to all information that the Operator may obtain about visitors to the website http://actodesk.com.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means processing of personal data using computer technology.
2.2. Blocking of personal data means temporary suspension of personal data processing, except where processing is necessary to clarify the personal data.
2.3. Website means the set of graphic and informational materials, computer programs and databases that make them accessible on the Internet at http://actodesk.com.
2.4. Personal data information system means the set of personal data contained in databases, together with the information technologies and technical means used to process it.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine which specific User or other personal data subject the personal data belongs to.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data, with or without the use of automation tools. This includes collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator means a state body, municipal body, legal entity or individual that, alone or jointly with others, organizes and/or carries out the processing of personal data. The Operator also determines the purposes of processing, the composition of the personal data to be processed, and the actions (operations) performed with the personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website http://actodesk.com.
2.9. Personal data authorized by the subject for distribution means personal data to which the personal data subject has granted access to an unlimited number of persons. The subject grants such access by consenting to the processing of personal data authorized for distribution, in the manner provided for by the Personal Data Law (hereinafter, "personal data authorized for distribution").
2.10. User means any visitor to the website http://actodesk.com.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unlimited number of persons. This includes publication of personal data in the mass media, posting on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data means any actions that irreversibly destroy personal data, so that its content cannot be restored in the personal data information system, and/or that destroy the physical media containing the personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the personal data subject;
• continue processing personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law. This applies even if the personal data subject withdraws consent to processing or sends a request to stop processing;
• independently determine the composition and list of measures necessary and sufficient to fulfill the obligations under the Personal Data Law and the regulations adopted under it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject, at their request, with information concerning the processing of their personal data;
• organize the processing of personal data in the manner established by current legislation of the Russian Federation;
• respond to appeals and requests from 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, at its request, with the necessary information within 10 days of receiving such a request;
• publish this Personal Data Processing Policy or otherwise ensure unrestricted access to it;
• take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision or distribution, and against other unlawful actions in relation to personal data;
• stop the transfer (distribution, provision, access) of personal data, stop processing it and destroy it in the manner and in the cases provided for by the Personal Data Law;
• perform other obligations provided for by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator provides this information to the personal data subject in an accessible form. The information must not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• demand that the Operator clarify, block or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and take measures provided for by law to protect their rights;
• set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
• withdraw consent to the processing of personal data and send a demand to stop processing personal data;
• appeal against unlawful actions or omissions of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with reliable information about themselves;
• inform the Operator of any clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or with information about another personal data subject without that subject's consent, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data is processed on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of its collection is not permitted.
5.3. Databases containing personal data processed for mutually incompatible purposes may not be combined.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes.
5.6. When processing personal data, the Operator ensures that the data is accurate, sufficient and, where necessary, up to date in relation to the purposes of processing. The Operator takes, or ensures that others take, the necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than the purposes of processing require. This applies unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized once the purposes of processing are achieved or once achieving them is no longer necessary, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
7. Conditions for Processing Personal Data
7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform 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 or for the enforcement of a judicial act or an act of another body or official that is subject to enforcement 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 personal data subject is a party, beneficiary or guarantor. It is also necessary for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The Operator processes personal data to which the personal data subject has granted access to an unlimited number of persons, or which has been made accessible at the subject's request (hereinafter, "publicly available personal data").
7.7. The Operator processes personal data that is subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the Collection, Storage, Transfer and Other Types of Processing of Personal Data
The Operator ensures the security of the personal data it processes through legal, organizational and technical measures necessary to fully comply with current personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, with two exceptions:

• cases related to compliance with current legislation;
• cases where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil law contract.

8.3. If the User finds inaccuracies in their personal data, the User may update the data independently. To do so, the User sends a notice to the Operator's email address notaskmeagain@gmail.com marked "Personal Data Update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time. To do so, the User sends a notice to the Operator's email address notaskmeagain@gmail.com marked "Withdrawal of Consent to the Processing of Personal Data".
8.5. All information collected by third-party services, including payment systems, communication providers and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User shall review these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Some prohibitions set by the personal data subject do not apply where personal data is processed in state, public and other public interests as defined by the legislation of the Russian Federation. This applies to the following prohibitions concerning personal data authorized for distribution:

• prohibitions on its transfer (other than granting access);
• prohibitions on its processing, or conditions of its processing (other than obtaining access).

8.7. When processing personal data, the Operator ensures its confidentiality.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than the purposes of processing require. This applies unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Processing of personal data may be terminated upon:

• achievement of the purposes of processing;
• expiration of the personal data subject's consent;
• withdrawal of consent by the personal data subject;
• a demand by the subject to cease processing;
• detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the resulting information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before starting any cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such a transfer. This notice is sent separately from the notice of intention to process personal data.
10.2. Before submitting the above notice, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals and foreign legal entities to which the cross-border transfer is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data shall not disclose personal data to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarification on matters concerning the processing of their personal data by contacting the Operator by email at notaskmeagain@gmail.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at http://actodesk.com/privacy.