Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy (hereinafter referred to as the “Policy”) sets out the procedures for processing personal data (hereinafter referred to as “PD”) of visitors to the website debetcredit.ru, operated by Individual Entrepreneur S.G. Gobarev (hereinafter referred to as the “Operator”).

This Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006, “On Personal Data”, and other regulatory legal acts of the Russian Federation governing the protection of personal data.

By using the website debetcredit.ru, visitors agree to the terms of this Policy and consent to the processing of their personal data by submitting contact forms and questionnaires on the website. If you do not agree, please do not use the website.

2. Categories of Personal Data Subjects

In the course of operating the website, the Operator processes PD belonging to the following categories of individuals:

• Website visitors, including individuals using contact forms;
• Job applicants submitting applications for vacancies through the website;
• Contractors and potential partners contacting the Operator through the website.

3. Categories of Personal Data Processed

The following categories of PD may be processed through the website:

• Identification data: surname, first name, and patronymic (if provided by the visitor in website forms);
• Contact details: telephone number and email address;
• Employment-related data (for job applications): CV, work experience, education, desired position, marital status, and other relevant information;
• Technical data: IP address, browser type and version, operating system, screen resolution, website referral source, pages visited, and visit time;
• Cookies: session identifiers and analytics cookies.

4. Purposes of Personal Data Processing

• Processing inquiries and requests from website visitors;
• Providing information about the Operator’s activities and services;
• Reviewing applications for open vacancies and recruiting employees;
• Entering into and performing contracts with counterparties;
• Analyzing website traffic and user behavior to improve website performance;
• Complying with the requirements of the legislation of the Russian Federation.

5. Legal Grounds for Processing

• Consent of the personal data subject to the processing of their PD, expressed by submitting forms on the website;
• Entering into and performing contracts with counterparties and employees;
• Requirements of employment, tax, and other legislation of the Russian Federation;
• The Operator’s legitimate interests, including ensuring the operation and security of the website.

6. Processing Methods and Retention Periods

PD are processed both by automated means (using the Operator’s information systems) and without the use of automation.

PD are processed from the time they are received until the purposes of processing have been achieved or the personal data subject withdraws their consent. Upon expiration of the applicable processing periods, PD are destroyed or anonymized. Retention periods for specific categories of PD are established in accordance with the legislation of the Russian Federation, including the requirements of the Labor Code and archival legislation concerning personnel records.

7. Measures to Protect Personal Data

The Operator takes the necessary legal, organizational, and technical measures to protect PD against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, and other unlawful actions, including:

• Appointing a person responsible for organizing personal data processing;
• Using information security measures that have undergone the prescribed conformity assessment procedure;
• Restricting access to PD to employees who require such access for official duties;
• Transmitting data through secure communication channels (HTTPS);
• Regularly monitoring the security of information systems.

8. Disclosure of Personal Data to Third Parties

The Operator does not disclose PD to third parties except in cases expressly provided for by the legislation of the Russian Federation, such as providing data to government authorities upon request within the scope of their legal powers.

The Operator does not carry out cross-border transfers of personal data. All PD are processed and stored within the territory of the Russian Federation.

9. Use of Cookies and Analytics Services

The website uses cookies, which are small text files stored in the visitor’s browser, to ensure the website functions properly and to analyze website traffic.

Users may disable cookies at any time through their browser settings. Some website features may become unavailable if cookies are disabled.

10. Rights of Personal Data Subjects

A personal data subject has the right to:

• Obtain information concerning the processing of their PD in accordance with Article 14 of Federal Law No. 152-FZ;
• Request that the Operator clarify, block, or destroy their PD if the data are incomplete, inaccurate, or outdated;
• Withdraw previously given consent to the processing of their PD;
• Appeal the Operator’s actions or omissions to the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or through the courts.

11. Amendments to the Policy

The Operator reserves the right to amend this Policy. The current version of the Policy is permanently available at https://debetcredit.ru/eng/policy

12. Contact Information

Email address: info@kappa-consulting.ru