This Personal Data Processing Policy has been developed in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by individual entrepreneur Skurikhin Artem Olegovich (hereinafter referred to as the Operator).
The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data to be one of the most important conditions for carrying out its activities, including the protection of the rights to privacy, personal and family secrets.
This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors of the website https://transfer-sclass.com/.
2. Terms and Definitions2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at https://transfer-sclass.com/.
2.4. Information system of personal data — a set of personal data contained in databases and the information technologies and technical means that process them.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without additional information, the ownership of personal data by a specific User or another subject of personal data.
2.6. Processing of personal data — any action (operation) or 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), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state or municipal body, legal or natural person, independently or jointly with others organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing, the composition of personal data to be processed, and actions performed with personal data.
2.8. Personal data — any information related directly or indirectly to a specific or identifiable User of the website https://transfer-sclass.com/.
2.9. Personal data allowed for distribution by the subject of personal data — personal data to which an unlimited number of persons has been granted access by the subject of personal data by giving consent in the manner prescribed by the Personal Data Law.
2.10. User — any visitor of the website https://transfer-sclass.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer) or making personal data available to an unlimited number of persons, including publication in the media, posting in information and telecommunication networks, or otherwise providing access to personal data.
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 or legal person.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed without the possibility of further restoration, and/or material carriers of personal data are destroyed.
3. Rights and Obligations of the Operator3.1. The Operator has the right to:
  • receive accurate information and/or documents containing personal data from the subject of personal data;
  • continue processing personal data without the consent of the subject if there are grounds provided by the Personal Data Law;
  • independently determine the composition and list of measures necessary to ensure compliance with obligations under the Personal Data Law, unless otherwise provided by federal laws.
3.2. The Operator is obliged to:
  • provide the subject of personal data, upon request, with information regarding the processing of his/her personal data;
  • organize the processing of personal data in accordance with the current legislation of the Russian Federation;
  • respond to requests and inquiries of subjects of personal data and their legal representatives;
  • report required information to the authorized body for the protection of the rights of subjects of personal data within 10 days from receipt of such a request;
  • publish and provide unrestricted access to this Policy;
  • take legal, organizational, and technical measures to protect personal data;
  • cease transfer and processing of personal data and destroy them in cases provided by law;
  • fulfill other obligations as provided by the Personal Data Law.
4. Rights and Obligations of Subjects of Personal Data4.1. Subjects of personal data have the right to:
  • receive information related to the processing of their personal data (except as provided by law);
  • demand clarification, blocking, or destruction of their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing;
  • require prior consent for personal data processing for marketing purposes;
  • withdraw consent to the processing of personal data;
  • appeal to an authorized body or court regarding unlawful actions of the Operator;
  • exercise other rights under the laws of the Russian Federation.
4.2. Subjects of personal data are obliged to:
  • provide the Operator with reliable information about themselves;
  • inform the Operator about the clarification (updating, modification) of their personal data.
**4.3. Persons who provided inaccurate information about themselves or about another subject of personal data without consent bear responsibility under the laws of the Russian Federation.
  • 5. Principles of Personal Data ProcessingProcessing is carried out on a lawful and fair basis.
  • Processing is limited to specific, predetermined, and lawful purposes.
  • It is not allowed to process personal data incompatible with the purposes of their collection.
  • Only data relevant to the stated purposes are processed.
  • Accuracy, sufficiency, and relevance of personal data are ensured.
  • Personal data are stored no longer than required for the purposes of processing.
6. Purposes and Grounds of Data ProcessingPurpose of processing: informing the User by sending emails.
Personal data collected:
  • surname, name, patronymic;
  • phone numbers.
The website also collects anonymized visitor data (including cookies) using web analytics services (Yandex.Metrica, Google Analytics, etc.).
Legal grounds:
  • Federal Law “On Information, Information Technologies, and Information Protection” No. 149-FZ of July 27, 2006;
  • Consent to personal data processing.
Types of processing:
  • collection, recording, systematization, accumulation, storage, destruction, depersonalization;
  • sending informational emails;
  • sending informational messages via messengers (WhatsApp, Viber, Telegram, etc.).
7. Cases Allowing Processing Without ConsentProcessing may be carried out:
  • to fulfill obligations under Russian or international law;
  • to administer justice;
  • for contract execution with the subject;
  • to protect legitimate interests of the Operator or third parties;
  • when processing publicly available personal data;
  • when processing data subject to publication or mandatory disclosure by law.
  • 8. Ensuring the Security of Personal DataThe Operator ensures the security of personal data by implementing legal, organizational, and technical measures.
  • Personal data will never be transferred to third parties, except as required by law or with consent.
  • In case of inaccuracies, the User can update their data by sending a notice to Pilot2036@icloud.com with the subject “Updating Personal Data.”
  • The User may withdraw consent by sending an email to Pilot2036@icloud.com with the subject “Withdrawal of Consent.”
  • The Operator is not responsible for third-party services (e.g., payment systems, communication providers) that process personal data under their own agreements.
  • Confidentiality of personal data is ensured.
  • Data is stored no longer than required to achieve the processing purposes.
9. Methods of ProcessingThe Operator carries out collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction of personal data, both automated and non-automated.
10. Cross-Border Data TransferBefore cross-border transfer of personal data, the Operator must notify the authorized body and obtain relevant guarantees from foreign recipients of personal data.
  • 12. Final ProvisionsUsers may obtain clarifications regarding their personal data by contacting the Operator at Pilot2036@icloud.com.
  • Any changes to this Policy will be reflected in the updated version.
  • This Policy is valid indefinitely until replaced with a new version.
  • The current version is freely available at https://transfer-sclass.com/privacy.
Made on
Tilda