This is a translation of the Russian-language policy provided for convenience. [Legal review required before publication.]

Personal Data Processing Policy

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" of 27.07.2006 (hereinafter, the "Personal Data Law") and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by Individual Entrepreneur Aleksandr Vladimirovich Ivanov (hereinafter, the "Operator").

1.1. The Operator's most important goal and condition for carrying out its activities is the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family secrecy.

1.2. This Operator's policy on the processing of personal data (hereinafter, the "Policy") applies to all information that the Operator may obtain about visitors to the website https://jecheck.io.

2. Key terms used in this Policy

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).

2.3. Website — the collection of graphic and informational materials, as well as computer programs and databases, that makes them available on the internet at https://jecheck.io.

2.4. Personal data information system — the personal data contained in databases, together with the information technologies and technical means used to process them.

2.5. Depersonalization of personal data — actions as a result of which it becomes 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 — any action (operation) or set of actions (operations) performed on personal data, with or without the use of automation, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.

2.7. Operator — 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 and determines the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed on personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://jecheck.io.

2.9. Personal data authorized by the data subject for dissemination — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized for dissemination, in the manner provided for by the Personal Data Law (hereinafter, "personal data authorized for dissemination").

2.10. User — any visitor to the website https://jecheck.io.

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 number of persons, including publishing personal data in the mass media, posting it on information and telecommunications networks, or providing 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 public authority of a foreign state, or to a foreign individual or foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, making it impossible to restore the content of the personal data in the personal data information system, and/or the physical media containing personal data are destroyed.

3. Key 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;
if the personal data subject withdraws consent to the processing of personal data, or submits a request to stop processing personal data, continue processing the personal data without the subject's consent where there are grounds for doing so set out in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided for by 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 the applicable 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 or otherwise ensure unrestricted access to this Policy on the processing of personal data;
take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision or dissemination, as well as against other unlawful actions in relation to personal data;
stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
perform other obligations provided for by the Personal Data Law.

4. Key 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 information is 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, unless 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;
require the operator to clarify, block or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take legal measures to protect their rights;
make prior consent a condition 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 submit a request to stop the processing of personal data;
appeal against unlawful actions or inaction 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 accurate information about themselves;
inform the Operator of any clarification (updating, modification) 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 are processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes for which they were collected is not permitted.

5.3. Combining databases containing personal data processed for mutually incompatible purposes is not permitted.

5.4. Only personal data that meet the purposes of their processing may be processed.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Processing personal data in excess of the stated purposes is not permitted.

5.6. When processing personal data, their accuracy, sufficiency and, where necessary, relevance to the purposes of processing are ensured. The Operator takes, and/or ensures that others take, the necessary measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data are stored in a form that allows the personal data subject to be identified for no longer than the purposes of processing require, 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 are destroyed or depersonalized once the purposes of processing have been achieved or when it is no longer necessary to achieve them, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing: informing the User by sending emails.

Personal data:

last name, first name, patronymic;
email address.

Legal grounds:

contracts concluded between the operator and the personal data subject.

Types of personal data processing:

collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data;
sending informational emails to the email address.

7. Conditions for processing personal data

7.1. Personal data are 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 the enforcement of a judicial act, or an act of another body or official, 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, as well as for concluding 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 goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data are processed to which the personal data subject has given access to an unlimited number of persons, or at the subject's request (hereinafter, "publicly available personal data").

7.7. Personal data are processed that are 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 security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary to fully comply with the requirements of applicable legislation on personal data protection.

8.1. The Operator ensures the safety 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 compliance with applicable law, or where the personal data subject has consented to the Operator transferring the data to a third party in order to fulfil obligations under a civil-law contract.

8.3. If inaccuracies are found in the personal data, the User may update them by sending a notice to the Operator's email address [email protected] marked "Updating personal data".

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending a notice by email to the Operator's email address [email protected] 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 parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to review those 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. Prohibitions established by the personal data subject on the transfer (other than the provision of access) and on the processing, or conditions of processing (other than obtaining access), of personal data authorized for dissemination do not apply where personal data are processed in state, public or other public interests as defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures their 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, 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, expiry of the personal data subject's consent, withdrawal of consent by the personal data subject or a request to stop processing personal data, or upon detection of unlawful processing of personal data.

9. Actions performed by the Operator with the personal data received

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, 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 information obtained via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before starting cross-border transfers 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 cross-border transfers of personal data (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 public authorities, foreign individuals or foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have obtained access to personal data must not disclose personal data to third parties or disseminate them 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 relating to the processing of their personal data by contacting the Operator by email at [email protected].

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

12.3. The current version of the Policy is freely available online at https://jecheck.io/privacy.